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Canterbury Sleep Clinic
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Policy

Privacy Policy

How Canterbury Sleep Clinic collects, uses and protects your personal information.

Last updated

1. Introduction

We are committed to protecting your privacy. This policy explains what personal data we collect about you, how we use it, and the rights you have over it.

Please read it carefully. This policy explains how we use your data. Where we rely on your consent, we ask for it separately, and you can withdraw it at any time.

2. The Company

canterburysleepclinic.co.uk is a website and service operated by Resolve Health Group Ltd (“we”/“us”), a company registered in England and Wales under company number 16988460. Our registered office is at 4th Floor, Silverstream House, 45 Fitzroy Street, Fitzrovia, London, W1T 6EB.

For the purposes of UK data protection law (including the UK GDPR and the Data Protection Act 2018), we are the controller of your personal data. Our nominated representative is available on request.

3. Data we may collect from you

In this policy, your “data” means information relating to you, or from which you could be identified directly or indirectly. We may collect, use, store and transfer the following kinds of data:

  • Contact Data – email address, telephone number, correspondence address.

  • Identity Data – first and last name, username or similar identifier.

  • Health Data – your answers to our online questionnaires and triage tool, and any other information you give us about your physical or mental health, including current medicines and, if you choose to share them, your GP’s details.

  • Technical Data – IP address, login data, browser type and version, cookies, time zone and location, browser plug-ins, operating system and platform, and other technology on the devices you use to access our website and communications.

  • Usage Data – how you use our website, including the pages you visit, searches you make, response times, download errors, visit length, page interactions (scrolling, clicks, mouse-overs), and how you navigate away.

  • Marketing Data – your preferences for receiving marketing from us.

We do not knowingly collect data from children. Please do not provide us with data unless you are at least 18.

Data you voluntarily provide. You may give us data when you: complete our triage tool or an online questionnaire; register for communications; contact us by email or phone (we may keep a record of the correspondence or call); complete optional research surveys; purchase services or products; provide services to us or our users; give us feedback; or otherwise contact us with questions, comments or complaints.

Certain data is mandatory so that we can fulfil your request, and we will make this clear at the point of collection. Everything you provide must be true, complete and accurate. If you give us inaccurate or false data and we identify or suspect fraud, we will record it and may report it to the appropriate authorities.

Data we collect automatically. When you use our website we may automatically collect Technical Data and Usage Data for research and analysis. Some of this uses cookies and similar technologies – see section 12.

Data we receive from others. We may receive data about you from service providers such as our payment and analytics providers, and from the clinical partners we work with, including our partner pharmacy and prescribing service.

We only use your data where we have a lawful basis to do so:

  • Consent, where you choose to give it.

  • Performance of our contract with you.

  • Compliance with legal requirements.

  • Legitimate interests – our legitimate business interests in the normal running of our business, where these do not materially impact your rights, freedoms or interests.

Health Data is special category data. We process it only with your explicit consent (UK GDPR Article 9(2)(a)), given when you submit your assessment. You can withdraw consent at any time by emailing contact@canterburysleepclinic.co.uk; we will then delete your answers unless we’re required to keep them.

If you use our services, we use Contact Data, Identity Data and Health Data to provide you with access to the website and to supply the services and products you request, in line with our terms and conditions. We cannot provide clinical services or products unless you provide, and permit us to process, your Health Data.

We may use Contact Data and Identity Data to comply with legal obligations – for example anti-money-laundering checks, or to protect a third party’s rights, property or safety.

We may also use your data (except Health Data) for our legitimate interests, including: improving our website and services; in connection with any merger, sale of assets, restructuring, financing or acquisition of all or part of our business; answering your questions or comments; audit; and telling you about changes to this policy or our terms.

5. Who do we share your data with?

For our legitimate interests, we may share your data with service providers, sub-contractors, consultants and agents who perform functions on our behalf and under our instructions – including IT providers, group companies, accountants, auditors and lawyers. They receive only the data they need to provide their service, and if we stop using them we ask them to delete or anonymise your data.

Our services depend on clinical partners – in particular our partner pharmacy and prescribing service, The Independent Pharmacy. Where you choose to proceed to treatment with them, we may share your Contact Data and Health Data with them so they can assess, prescribe, dispense and deliver your treatment.

Where identity verification is required, we share relevant Contact Data and Identity Data with our verification partners.

To deliver orders, we share your Contact Data with third-party delivery companies such as Royal Mail.

To evaluate business performance we may occasionally share data with validated third parties for analysis.

We keep any disclosure to the minimum required for the safe and effective delivery of services, and will never knowingly share data with third parties who do not comply with UK data protection law.

Where we must comply with legal obligations or requests, we may share your data with authorities, regulators and agencies.

If we merge, sell assets, restructure, or sell all or part of our business, the new owners may use your data as set out in this policy.

6. Third-party service providers

We currently work with the following third-party providers:

7. Where we store your data

Data we collect may be transferred to and stored at a destination outside the UK and/or the European Economic Area, and may be processed by staff outside those areas working for us or our suppliers – for example in fulfilling orders, processing payments or providing support.

Where data is transferred outside the UK/EEA, it will only go to countries recognised as providing adequate protection, or to recipients where approved transfer mechanisms (such as the International Data Transfer Agreement or standard contractual clauses) are in place.

8. Information security

We take appropriate measures to protect data against unauthorised access, alteration, disclosure or destruction, including internal reviews of our collection, storage and processing practices, encryption, and physical security controls.

Information you provide is stored on secure servers, and any payment transactions we process are encrypted.

Where you have a password for any part of our services, you are responsible for keeping it confidential and should not share it.

Transmission of information over the internet is never completely secure. We do our best to protect your data, but any transmission is at your own risk. Once received, we apply strict procedures and security features to prevent unauthorised access.

9. Marketing

You may consent to receive marketing emails from us – for example by ticking the relevant box when you sign up. You can stop receiving them at any time by contacting contact@canterburysleepclinic.co.uk or clicking “Unsubscribe” in any marketing email. If you ask to be removed, we keep a record of your name and email address so that we do not market to you again.

10. Your rights

You have a number of rights under data protection law. You can exercise them at any time by contacting contact@canterburysleepclinic.co.uk:

  • Access – obtain a copy of the data we hold about you.

  • Rectification – require us to correct inaccurate, incomplete or outdated data.

  • Portability – request transfer of your data to another provider where processing was based on consent or contract.

  • Restriction and objection – in certain circumstances, require us to restrict processing where you believe it impacts your rights and freedoms, though we may demonstrate legitimate grounds to continue.

  • Erasure – require deletion of data we no longer need to hold, subject to legal retention requirements, which we will explain when we respond.

  • Marketing opt-out – ask us to stop sending marketing, though we will still contact you about matters relating to any account you hold.

We may charge a reasonable fee, or decline to act, where a request is manifestly unfounded or excessive, and may ask for identification before responding.

If you have a complaint about this policy or how we process your data, please tell us and we will investigate and respond within a reasonable time. You also have the right to complain to the Information Commissioner’s Office (ico.org.uk).

11. Retention of data

We retain data in line with applicable law. We may need to keep data longer to meet legal, audit or statutory requirements (including HMRC requirements for financial records) or to deal with disputes. We keep assessment answers for 36 months from your last activity, then delete or anonymise them. Contact form messages are kept for 36 months.

Where we have no legal basis to continue processing, we will delete or anonymise your data – or, if that is not possible (for example because it sits in backup archives), securely store it and isolate it from further processing until deletion is possible.

12. Cookies

What are cookies?

Cookies are small pieces of data stored on your computer, phone or other device. We also use pixels (small blocks of code that allow measurement of page viewing), web beacons and local storage – small files with unique identifiers that let us recognise when someone has visited our site or opened an email.

How we use cookies

Cookies help us operate the website and provide services: recognising you when you return, customising the site to your interests, speeding up searches, supporting research and analytics, and delivering relevant advertising. Third-party cookies enable features such as advertising, interactive content and analytics; those third parties are responsible for the cookies they set, and we have no control over them.

Cookies we use

  • Strictly necessary – required for the site to work, such as login and billing cookies.

  • Performance – track how the site is used, visit counts and behaviour, so we can improve it.

  • Functionality – recognise you and personalise your experience.

  • Analytics – record your visit, pages viewed and links clicked, to shape services and content; this may be shared with third-party providers.

Technical information we collect about your device

Device type, network information, operating system, IP address, browser and version, and time zone.

Usage data we collect

The full URL clickstream to, through and from the site (with date and time), services and products viewed or searched for, page response times, download errors, visit lengths, page interactions, and any phone number used to call us.

Controlling cookies

You can refuse cookies through your browser settings, though parts of the site may not work if you do. Most advertising networks also let you opt out of targeted advertising – see http://www.aboutads.info/choices/. Instructions for common browsers:

13. General

Our website may link to third-party websites, plug-ins and applications. We are not responsible for their content or privacy practices – check the relevant third party’s own policy before providing them with information.

If any provision of this policy is held invalid or unenforceable, it will be construed as nearly as possible to reflect the parties’ intentions and the remainder will continue in full force.

This policy is governed by English law and you agree to the exclusive jurisdiction of the English courts.

Changes to this policy will be posted on this page; if they substantially affect your rights or obligations, we will notify you if we hold your email address.

Questions, comments and requests about this policy are welcome at Resolve Health Group Ltd, 4th Floor, Silverstream House, 45 Fitzroy Street, Fitzrovia, London, W1T 6EB, or contact@canterburysleepclinic.co.uk.