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Irrefutable Health Privacy Notice – June 2018

Why we collect your personal data and what we do with it

We’re Irrefutable Health (IH) and we’re dedicated to protecting your privacy. We are part of Tri-Health Group (THG) which also comprises of The Willow Kingston, Bluesky Connexions and Function 365 (F365).

When you supply your personal details to Irrefutable Health, they are stored and processed for 6 reasons (the bits in bold are the relevant terms used in the Data Protection Act 2018, which includes the General Data Protection Regulation (GDPR),i.e. the law):

  1. We need to collect personal information about you and your health in order to provide you with the best possible treatment. Your request for treatment and our agreement to provide that care constitutes a contract. You can, of course, refuse to provide the information, but if you were to do that we would not be able to provide treatment.
  2. We have a “Legitimate Interest” in collecting that information, because without it we couldn’t do our job effectively and safely.
  3. We also think that it is important that we can contact you in order to confirm your appointments with us or to update you on matters related to your medical care. This again constitutes “Legitimate Interest”, but this time it is your legitimate interest.
  4. When we provide you with care, you become an IH Practice Member and are also entitled to receive THG membership. THG membership permits and controls your THG KeyCard which gives you access to a) the building at authorised times, b) your patient portal via the screens in the clinic, and c) the THG loyalty points programme when it is launched. Your THG KeyCard’s unique identification number enables your access to the building but your personal or medical details are NOT stored on the card. A separate Privacy Notice applies to THG Membership and your THG KeyCard and can be found under the ‘THG Privacy Notice’ tab on this page.
  5. Provided we have your consent, we may also send you emails with relevant information, news, offers and updates from the companies within THG.  You may unsubscribe from these emails at any time by clicking on the unsubscribe link included in each email. A separate Privacy Notice relating to the use of the Irrefutable Health website including the use of “cookies” can be found under the ‘IH Website Privacy Notice’ tab on this page.
  6. Your anonymised information may also be used to give direction to the development of events, functions and programmes to promote health and wellness for the individual and the community.

We have a legal obligation to retain your records for 8 years after your most recent appointment (or age 25, if this is longer), but after this period you can ask us to delete your records if you wish. Otherwise, we will retain your records indefinitely in order that we can provide you with the best possible care should you need to see us at some future date.

Your records are stored as follows:

  • on paper, in locked filing cabinets, and the office is always locked and alarmed out of working hours.
  • electronically (“in the cloud”), using a specialist medical records service called F365. This service is fully compliant with GDPR. Access to this encrypted data is password-protected, and the passwords are changed regularly.
  • on our office computers. These are password-protected, backed up regularly, and the office is locked and alarmed out of working hours.

We will never share your data with anyone who does not need access without your written consent, and we will never share, rent or sell your contact or health details to any other third parties or companies outside THG for marketing purposes. Only the following people/agencies will have routine access to your data:

  • The medical records service F365 which stores and processes our files
  • Your practitioner(s) so that they can provide you with treatment
  • Our reception staff, because they organise our practitioners’ diaries, and coordinate appointments and reminders
  • Other administrative staff, such as our bookkeeper. Administrative staff will not have access to your medical notes, just your essential contact details.
  • We also use Mailchimp to coordinate our marketing emails, so your name and email address may be saved on their server.

Anonymised health information may also be provided to medical research processing service providers who process your information on our behalf in accordance with our instructions or as necessitated by law or functions of the business.

From time to time, we may have to employ consultants to perform tasks which might give them access to your personal data (but not your medical notes). We will ensure that they are fully aware that they must treat that information as confidential, and we will ensure that they sign a non-disclosure agreement.

You can view the contact details we have for you and your IH health records including your individualised lifestyle recommendations, laboratory test results, medications and supplements usage charts by logging in to your patient portal. You can access the patient portal in 2 ways:

  1. On the screens in the clinic reception using your THG card
  2. At home using a password chosen by and known only to you. If you forget your password, you can use the link on the login screen to reset it.

Full details of how to access your patient portal will be supplied when you become a Practice Member.

You have the right to see what personal data of yours we hold, and you can also ask us to correct any factual errors. Provided the legal minimum period has elapsed, you can also ask us to erase your records.

We want you to be absolutely confident that we are treating your personal data responsibly, and that we are doing everything we can to make sure that the only people who can access that data have a genuine need to do so.

Of course, if you feel that we are mishandling your personal data in some way, you have the right to complain.

Requests for personal data or complaints need to be sent in writing to what is referred to in the jargon as the “Data Controller”. Here are the details you need for that:

Data Controller

16 The Triangle

Kingston-upon-Thames

Surrey

KT1 3RT

If you are not satisfied with our response, then you have the right to raise the matter with the Information Commissioner’s Office.

Irrefutable Health Website Privacy Notice

This Privacy Policy applies to the Irrefutable Health website. The Irrefutable Health website is provided for information and educational purposes and may contain links to other sites. Once you enter another website (whether through an advertisement, service, or content link), be aware that Irrefutable Health is not responsible for the privacy practices of such other sites. We encourage you to look for and review the privacy statements of each and every website that you visit.

We believe that transparency is the key to any healthy relationship. At Irrefutable Health, we’re all about healthy. We appreciate that you are trusting us with information that is important to you, and we want to be transparent about how we use it. Here we describe the privacy practices for our website and you will learn about the data we collect, how we use it, the controls we give you over your information, and the measures we take to keep it safe.

Specifically, we’ll cover:

Information We Collect and How We Use Information


We collect the following personal information from you on the Irrefutable Health website forms.

  • First and Last name
  • Email address
  • Phone number

By entering this information, you are providing personal information that will be used by Irrefutable Health for the sole purpose of scheduling your appointment or returning your contact request.

If you choose to enroll as a subscriber of our website or subscribe to our blog, you will receive recurring practice newsletters, announcements and occasional promotional information via email. These emails will be of a general nature and will in no way disclose your unique health characteristics. At the time you subscribe or any time thereafter, you can choose to opt-out of receiving these emails from us.

To subscribe to our website, we need certain contact information, such as your name and email address. We may also store any provided demographic information (such as gender, birth date and address), but it is not required. You can unsubscribe from the newsletters by simply clicking on the “unsubscribe” link at the bottom of our emails; you will be immediately unsubscribed.

Passive Information We Collect

Like many other websites, we also automatically collect and log other non-identifying information when you interact with the Irrefutable Health website:

Device data. We collect data from the device and application you use to access the Irrefutable Health website, such as your Internet protocol (IP) addresses, operating system, device type, browser type and timestamps.

Usage data. We collect usage data that may include which Irrefutable Health webpages you visit, what you click on, when you performed those actions, and so on. Emails sent by Irrefutable Health collect information about who opened those emails and clicked on links in them. We do this to measure the performance of the Irrefutable Health email messaging and to monitor and improve email deliverability and open rates.

How Information Is Shared


Except as set forth in this Privacy Policy or as specifically agreed to by you, Irrefutable Health will not disclose any Personally Identifiable or Personal Health Information it gathers from you on our website. We will only release Personally Identifiable or Personal Health Information to third parties:

(i) to comply with valid legal requirements such as a law, regulation, search warrant, subpoena or court order.

(ii) in special cases, such as a physical threat to you or others. In the event that we are legally compelled to disclose your Personally Identifiable or Personal Health Information to a third party, we will attempt to notify you unless doing so would violate the law or court order. In addition, we may disclose Personal Information as described below.

Your Rights To Access and Control Your Personal Data


You may ask us at any time for information about any personal data we hold about you, or ask us to correct or delete that information. We will complete this request within 30 days of the initial request for information being received. Please complete this form to start this process. If you need further assistance regarding your rights, please contact our Data Protection Officer at dataprotection@vortala.com, and we will consider your request in accordance with applicable laws.

Data Retention


We keep the information we have about you and your use of the Services for as long as necessary for our legitimate business interests, for legal reasons, historical research and to prevent harm, including as described in the How We Use Information and How Information Is Shared sections.

Analytics and Advertising Services Provided by Others


  • Google Analytics. In addition, our website uses Google Analytics, a web analytics service provided by Google, Inc. (“Google”). The information generated by the cookie about your use of our website (including your IP address) will be transmitted to and stored by Google on servers in the United States. Google will use this information for the purpose of evaluating your use of our website, compiling reports on website activity for website operators and providing other services relating to website activity and internet usage. Google may also transfer this information to third parties where required to do so by law, or where such third parties process the information on Google’s behalf. Google will not associate your IP address with any other data held by Google. Further information may be obtained by visiting Google’s privacy policy.
  • AdWords Remarketing. We use Google AdWords Remarketing to advertise Irrefutable Health across the Internet, in particular on the Google Display Network. We use a Google AdWords Remarketing code to log when website visitors view specific pages or take specific actions on our website. Google AdWords Remarketing can display ads to you based on what parts of the Irrefutable Health website you have viewed by placing a cookie on your web browser. This does not in any way identify you or give access to your computer or mobile device.

    Google AdWords Remarketing allows us to tailor our online marketing to better suit your needs and only display ads that are relevant to you. If you do not wish to see ads from Irrefutable Health you may opt out in the following ways:

    1. Opt out of Google’s use of cookies by visiting Google’s Ads settings.
    2. Opt out of a third-party vendor’s use of cookies by visiting the Network Advertising Initiative opt-out page.
  • Facebook Remarketing. We use the Facebook pixel for occasional remarketing advertising. We do this to understand and deliver ads and make them more relevant to you. Facebook may use cookies, web beacons, and other storage technologies to collect or receive information on the Smile Marketing website and elsewhere on the internet and use that information to provide measurement services and target ads. If you do not wish to see ads from Smile Marketing on Facebook you may opt out by visiting Facebook’s Ad Preferences settings.

    To learn more about your choices and the steps you can take to protect your privacy on the internet visit http://www.aboutads.info/choices or http://www.youronlinechoices.eu/.

We use this information to conduct research and analysis to better understand how visitors are using the Irrefutable Health website, so that we can improve our website experience. From time to time, Irrefutable Health or it’s operations contractors acting on their behalf, conduct online research in order to gather feedback about our site through online or email surveys.

Participation in these surveys is completely voluntary and you may choose whether or not to participate and disclose information. Personally Identifiable Information collected through market research will only be used by Irrefutable Health and its operations contractors and will never be given or sold to a third party.

Cookie Policy


We use cookies and other technologies to ensure that everyone who uses Irrefutable Health website has the best possible experience. By continuing to visit or use our services, you are agreeing to the use of cookies and similar technologies for the purposes we describe in this policy. You can find more information about cookies at: cookiesandyou.com.

Most browsers allow you to control cookies through their settings preferences. However, if you limit the ability of websites to set cookies, you may worsen your overall user experience, since it will no longer be personalized to you.

Our cookie table lists some of the third party cookies on our sites. Please note that the names of cookies, pixels and other technologies may change over time. Please note that third parties (including, for example, advertising networks and providers of external services like web traffic analysis services) may also use cookies, over which we have no control. These cookies are likely to be analytical/performance cookies or targeting cookies.

List of cookies used by Irrefutable Health

Cookie Name Purpose Expiration Privacy
__vor_npt__s
__vor_npt__t
__vor_npt__v
New Patient Tracker. Collects device data such as your Internet protocol (IP) address, operating system, device type, browser type and timestamps. Persistent https://www.irrefutablehealth.co.uk/info/privacy
Set By Or On Behalf Of Purpose Expiration Privacy
Google Analytics Website analytics cookie for visitor information and source. 2 years https://policies.google.com/privacy
responsivevoice.org Used by the content network, Cloudflare, to identify trusted web traffic. 1 year https://www.cloudflare.com/security-policy
Userway Accessibility widget remembers which accessibility features were enabled. Persistent https://userway.org/privacy
Hotjar Video Recording and Heatmap testing tool. 1 year https://www.hotjar.com/privacy
Wistia Embedding interactive videos on our website and measuring engagement. 1 year https://wistia.com/privacy/
MaxCDN Content Delivery Network. 1 year https://www.maxcdn.com/legal/
Facebook To enable the visitors to share the page in Facebook and stores page share count. Persistent https://www.facebook.com/about/privacy/
YouTube Embedding videos on our website and measuring engagement. 1 year https://policies.google.com/privacy
Formstack Provides embedded online form functionality. 1 year https://www.formstack.com/privacy

Our Policies for Children


We are committed to protecting the privacy of children. Neither Irrefutable Health nor any of its services are designed or intended to attract children under the age of 13.

Information Security


We work hard to keep your data safe. We use a combination of technical, administrative, and physical controls to maintain the security of your data. This includes using Transport Layer Security (“TLS”) to encrypt many of our Services. No method of transmitting or storing data is completely secure, however, if you have a security-related concern, please contact customer support at dataprotection@vortala.com.

Our International Operations and Data Transfers


Our website hosting company, Perfect Patients, operate internationally and transfer information to the United States for the purposes described in this policy. They rely on multiple legal bases to lawfully transfer personal data around the world. These include your consent, the EU-US and EU Commission approved model contractual clauses, which require certain privacy and security protections.

Perfect Patients complies with the Privacy Shield principles regarding the collection, use, sharing, and retention of personal information as described in Privacy Shield certifications. Learn more about Privacy Shield here.

Changes to This Policy


We will inform you if a material change to the Privacy Policy is made that involves the use of your Personally Identifiable Information. Your continued use of the Irrefutable Health site will indicate acceptance of the changes. Please exit the site immediately if you do not agree to the terms of this Privacy Policy or any revised policy.

Who We Are and How To Contact Us


If you have questions, suggestions, or concerns about this policy, or about our use of your information, please contact us.

Irrefutable Health

16 The Triangle

Kingston Upon Thames, Surrey KT1 3RT

Phone: 020 3034 3000


This Privacy Policy does not protect you when you send content, questions or ideas to Irrefutable Health via email. If you want to keep them private or proprietary, do not send them in an email. We try to answer every email within 48 business hours, but are not always able to do so.

Last Updated: May 21, 2018

Tri-Health Group Privacy Notice – June 2018

Why we collect your personal data and what we do with it

We’re Tri-Health Group (THG) and we’re dedicated to protecting your privacy. This Privacy Notice sets out how we handle your personal information if you are registered with THG or have subscribed to our email newsletters. It applies across the companies which comprise THG: Irrefutable Health (IH), The Willow Kingston, Bluesky Connexions and Function 365 (F365). THG manages the interests for these companies and inter-company co-ordination of events, functions and the development of programmes to promote health and wellness for the individual and the community. A separate Privacy Notice relating to the provision of care at Irrefutable Health can be found under the ‘IH Privacy Notice’ tab on this page.

When you supply your personal details to THG, they are stored and processed for 2 reasons:

  1. To provide you with THG membership. THG membership permits and controls your THG KeyCard which gives you access to a) the building at authorised times, b) your patient portal via the screens in the clinic if you are an IH Practice Member, and c) the THG loyalty points programme when it is launched. Your information will be used to process your requests for THG KeyCard assistance, loyalty points and membership renewal.
  2. Provided we have your consent, we may send you emails with relevant information, news, offers and updates from the companies within THG.  You may unsubscribe from these emails at any time by clicking on the unsubscribe link included in each email.

We will keep your personal information to provide the above services, and for no longer than is necessary if your THG membership comes to an end.

Your information is stored as follows:

  • electronically (“in the cloud”), using a specialist medical records service called F365. This service is fully compliant with General Data Protection Regulation. Access to this encrypted data is password-protected, and the passwords are changed regularly.
  • on our office computers. These are password-protected, backed up regularly, and the office is locked and alarmed out of working hours.

We will never share your data with anyone who does not need access without your written consent, and we will never share, rent or sell your contact or health details to any other third parties or companies outside THG for marketing purposes. Only the following people/agencies will have routine access to your data:

  • The medical records service F365 which stores and processes our files
  • Our reception staff, because they organised the distribution and management of THG KeyCards.
  • Other administrative staff, such as our bookkeeper.
  • We also use Mailchimp to coordinate our marketing emails, so your name and email address may be saved on their server.

From time to time, we may have to employ consultants to perform tasks which might give them access to your personal data. We will ensure that they are fully aware that they must treat that information as confidential, and we will ensure that they sign a non-disclosure agreement.

You have the right to see what personal data of yours we hold, and you can also ask us to correct any factual errors.

We want you to be absolutely confident that we are treating your personal data responsibly, and that we are doing everything we can to make sure that the only people who can access that data have a genuine need to do so.

Of course, if you feel that we are mishandling your personal data in some way, you have the right to complain.

Requests for personal data or complaints need to be sent in writing to what is referred to in the jargon as the “Data Controller”. Here are the details you need for that:

Data Controller

16 The Triangle

Kingston-upon-Thames

Surrey

KT1 3RT

If you are not satisfied with our response, then you have the right to raise the matter with the Information Commissioner’s Office.

Tri-Health Group Terms & Conditions – May 2018

Terms & Conditions pertaining to the use of the THG KeyCard

THG is comprised of several companies: Irrefutable Health (IH), The Willow, Bluesky Connexions and Function 365 (F365). THG manages the interests for these companies and inter-company co-ordination of events, functions and the development of programs to promote health and wellness for the individual and the community.

Using our Services

You must follow any policies made available to you regarding the Services.

About your THG KeyCard

THG membership permits and controls your THG KeyCard which gives you access to a) the building at authorised times, b) your patient portal via the screens in the clinic if you are an IH Practice Member, and c) the THG loyalty points programme when it is launched. Your information will be used to process your requests for THG KeyCard assistance, loyalty points and membership renewal.

Using your THG card as a door key

Your KeyCard contains a unique identification number which enables you to access to the building but your personal and/or medical details are not stored on the card.

Using your THG KeyCard to access your health record

Your THG KeyCard also gives you access to your health records via the IH Practice Members’ portal in the clinic. Your password will give you cloud-based access at any time to upload, submit, store, send or retrieve content from your personal health record.  You retain ownership and responsibility for the content and any information transferred through the portal.

Keeping your details secure

You will given a temporary IH password, we recommend you change your temporary password to another of your choice.  If you forget your password, we can reset it for you by supplying another temporary password.  To protect your health record, please keep your password confidential.  You are responsible for keeping your password safe and secure; we recommend that you do not use your password for other third party applications.

To maintain your privacy, you need to tell us if your THG KeyCard is lost. If you learn of or suspect any unauthorised use of your card, password, or lose your THG KeyCard, you must notify us immediately to cancel your KeyCard and/or reset your password. Do not share your card with an unregistered party, or interfere with our Services, or try to access them using a method other than the interface and the instructions that we provide.  We may suspend or stop providing our Services to you if you do not comply with our terms or policies or if we suspect misconduct or fraud.

Using your THG KeyCard as a loyalty card

Your THG KeyCard will enable you to collect loyalty points on purchases of products and services from THG companies which can be redeemed on products and services from the same THG companies when this service launched.  The full terms and conditions for the loyalty programme will be available at the launch date.

Modifying and/or Terminating our Services

We are constantly changing and improving our THG Services.  We may add or remove functionalities or features and we may suspend or stop a THG Service altogether.  You can stop using our THG Services at any time, although we would be sorry to see you go.  THG may also stop providing Services to you or add or create new limits to our Services at any time. If we discontinue a Service, where reasonably possible, we will give you reasonable advance notice and a chance to remove information from that Service.

Our Warranties and Disclaimers

We provide our Services using a commercially reasonable level of skill and care and we hope that you will enjoy using them.  However, there are certain things that we do not promise about our Services. Other than as expressly set out in these terms or additional terms, neither THG or its suppliers or distributors makes any specific promises about the services For examples, we do not make any commitments about the content within the services, the specific functions of the services or their reliability, availability or ability to meet your needs. We provide the services “as is”.

Changes to these Terms & Conditions

We may modify these terms or any additional terms that apply to the THG Card service to, for example, reflect changes to the law or changes to our THG Card Services. You should look at the terms regularly. We will post notice of modifications to these terms on this page.  We will post notice of modified additional terms in the applicable Service.  Changes will not apply retrospectively and will become effective no earlier than fourteen days after they are posted. However, changes addressing new functions for a Service or changes made for legal reasons will be effective immediately.  If you do not agree to the modified terms for a Service, you should discontinue your use of that Service.  If there is any inconsistency between these terms and the additional terms, the additional terms will prevail to the extent of the inconsistency.

About these Terms

These terms govern the relationship between THG and you. They do not create any third party beneficiary rights.  If you do not comply with these terms and we do not take action immediately, this doesn’t mean that we are giving up any rights that we may have (such as taking action in the future).  If it turns out that a particular term is not enforceable, this will not affect any other terms.

The laws of England will apply to any disputes arising out of or relating to these terms or the THG Services.  For further information, please contact us at info@trihealthgroup.co.uk