Privacy Policy

Privacy and Cookie Policy

Last updated July 2020

We recognise the importance of protecting your privacy and your rights with regards to data protection. The Internet is a very powerful medium when it comes to transmitting personal information; for that reason, we undertake the serious task of respecting the current laws regarding the protection of personal data and the security of the same, with the aim of guaranteeing secure, controlled and confidential navigation for its users and customers who visit and/or use the Website and/or use our medical forms (you as a "User") or then give us their consent for a specific purpose (you as a "Customer").

This Privacy Policy describes how we collect, use, process, and disclose your personal data in conjunction with your access to and use of our Website and services and, specifically:

  1. Who is the controller of your data?
  2. What categories of your data do we collect and use?
  3. Why and how do we collect your data?
  4. Who sees, receives and uses your data and where?
  5. How long do we retain your data?
  6. What are your data protection rights and how can you exercise them?
  7. Contact details of the data controller
  8. Contact details of our data protection officer
  9. Information about cookies

It also informs you of how you can exercise Your Rights (including the right to object to some of the data handling we carry out). More information about your rights and how you can exercise them is set out in the section below.

If you see an undefined term in this Privacy Policy (such as “Service”, “Website” or “Websites”), it has the same definition as in our Company contractual service conditions. The “Website” refers to the online COVID Age Risk and Mental Health forms at this URL: https://covid.polbridge.org.uk which in its demo form does not collect or save personal data, but simply demonstrates the full version that can collect and store personal data depending on your agreement selection.

1. Who is the controller of your personal data?

When this Privacy Policy mentions “Company”, “we,” “us,” “our” or “Data Controller”, it refers to:

Polbridge Health Ltd. 104 Frank Lester Way, Luton, LU29NQ. Registered office address: 1 Treetops, Welwyn, England, AL6 0HU. Company number 10717265.

info@polbridge.org.uk

which is responsible for the processing of Users’ and/or Customers’ personal data under this Privacy Policy (hereinafter, referred to as the “Company”, “we”, “us”, “our”, “Data Controller”).

We, being an entity located in England, are subject to English and European law regarding the protection of personal data. For that reason, we undertake to comply with the obligations imposed by the General Data Protection Regulation (EU) 2016/679 (“GDPR”).

In accordance with General Data Protection Regulation (EU) 2016/679 (“GDPR”) we inform our Users and/or Customers that their personal data is securely processed and kept by the Company in the manner and for the means as follows.

2. What categories of your data do we collect and use?

When you visit the Website and use our online forms (you as a "User") we collect the categories of personal data as follows:

2.1. Personal data provided by you

More specifically:

When you use our online “Websites” e.g. COVID Age Risk or Mental Health forms, you may provide us with information such as:

Contact details (i.e. Name, email address, phone number), date of birth etc.

Special categories of personal data, for example, relevant medical data and any special dietary or disability conditions, so information concerning your health. We will use the special categories of personal data only as strictly necessary to fulfil your request. Where we need to process this data, we will only do it if we have your explicit consent, in accordance with Art.6.1.a) and Art. 9.2 GDPR or if permitted by regulations.

When you contact us or we contact you through email, post and/or phone or through social media we may collect: personal data you provide when you connect with us, including your name, phone number, email.

The provision of the above personal data, where requested, is necessary for the adequate performance of the contract between you and us and to allow us to comply with our legal obligations except when we rely on consent as legitimate basis for processing and or our legitimate interest. Without it, we may not be able to provide you with all the requested services.

It is important that all the personal data you give us is correct and accurate. This includes, by way of example only, ensuring that we have your correct contact (including email) details at all times.

2.2. Personal data collected automatically from our Website, on the phone, from communication we send, and/or from third parties

We collect information about your visits to and use of the Website, such as information about the device and browser you are using, your IP address or domain names of the computers connected to the Websites, uniform resource identifiers for requests made, the time of request, the method used to submit the request to the server, the size of the archive obtained as a response, the numerical code indicating the status of the response given by the server (correct, error, etc.) and other parameters relative to the operating system and the computer environment used, the date and time that you visited, the duration of your visit, the referral source and website navigation paths of your visit and your interactions on the Website including the Services and offers you are interested in. Please note that we may associate this information with your account.

See the cookies section of this Privacy Policy (9. Information about cookies) for further information on the purposes for which we collect and use this information.

3. Why do we collect your data?

In general terms, we use your personal data to provide you with the services you request, notify you about important changes to our Website. More specifically:

A. To create and maintain the contractual relation established for the provision of the product and/or service requested by you in all its phases and by way of any possible integration and modification or to take steps at your request in relation to the contract prior to entering into contract (e.g. responding to your questions and concerns). Information concerning our provision of the Service and/or to provide you with any clarification or assistance may be sent to you via email, phone, SMS, recorded calls or other similar technologies.

On which legal basis?

To fulfil a contract, or take steps linked to a contract (i.e. To provide the products and/or the services you request and/or to provide you with any clarification or assistance to you)

B. To carry out aggregative statistical analyses on anonymised groups or to analyse identifiable individuals behaviour so that we can see how our Website, products and services are being used and how our business is performing.

On which legal basis?

To pursue our legitimate interest (i.e. improving our Website, its features and our products and services)

C. To understand the behaviour on your use of our Website, products and services and other sites collected through cookies (please see the Cookies section of this Privacy Policy for further information).

On which legal basis?

Where you give your consent (i.e. through the cookie banner or by your browser's settings)

4. Who sees, receives and uses your data and where?

4.1. Categories of recipients of your data

We share your personal data, for the purposes described in this Privacy Policy, to the following categories of recipients:

Our authorised employees and/or collaborators that assist and advise us on administration, legal affairs and information systems;

Our third-party service providers which process your personal data on our behalf and under our instructions for the purposes described hereinabove acting as data processors, such as those providing us with IT and hosting services call centre and customer support, analytics and administration services etc.

5. How long do we retain your data?

We retain your personal data for as long as is required to achieve the purposes and fulfil the activities as set out in this Privacy Policy, otherwise communicated to you or for as long as is permitted by applicable law. Further information about the retention period is available here:

HEALTH CONDITION RECORDS

The “Websites” e.g. COVID Age Risk and Mental Health forms record your personal details (e.g. name, contact information, date of birth, weight and height, gender at birth and ethnicity. Further to these, medical related questions such as ‘Chronic kidney disease’ are also recorded to calculate or process information that provides our services. We will use the special categories of personal data only as strictly necessary to fulfil your request.

Retention period

5 years after termination of contract.

Starting date

From the date of the usage of our forms.

DATA COLLECTED VIA GOOGLE ANALYTICS

Technical cookies

Retention period

Max 3 years

Starting date

From the date of browsing on our websites

Non-Technical cookies

Retention period

Max 1 year

Starting date

From the date of consent

6. What are your data protection rights and how can you exercise them?

You can exercise the rights provided by the Regulation EU 2016/679 (Articles 15-22), including the right to:

Name of the right: Right of access

Content: to receive confirmation of the existence of your personal data, access its content and obtain a copy.

Name of the right: Right of rectification

Content: to update, rectify and/or correct your personal data.

Name of the right: Right to erasure/right to be forgotten and right to restriction

Content: to request the erasure of your data or restriction of your data which has been processed in violation of the law, including whose storage is not necessary in relation to the purposes for which the data was collected or otherwise processed; where we have made your personal data public, you have also the right to request the erasure of your personal data and to take reasonable steps, including technical measures, to inform other data controllers which are processing the personal data that you have requested the erasure by such controllers of any links to, or copy or replication of, those personal data.

Name of the right: Right to data portability

Content: to receive a copy of your personal data you provided to us for a contract or with your consent in a structured, commonly used and machine-readable format (e.g. data relating to your purchases) and to ask us to transfer that personal data to another data controller.

Name of the right: Right to withdraw your consent

Content: wherever we rely on your consent (see p. 3 - F and J), you will always be able to withdraw that consent, although we may have other legal grounds for processing your data for other purposes.

Name of the right: Right to object, at any time

Content: you have the right to object at any time to the processing of your personal data in some circumstances (in particular, where we don’t have to process the data to meet a contractual or other legal requirement, or where we are using your data for direct marketing.

Name of the right: Right not to be subject to a decision based solely on automated processing, including profiling

Content: you can always request a manual decision- making process instead, express your opinion or contest decision based solely on automated processing, if such a decision would produce legal effects or otherwise similarly significantly affect you.

You can exercise the above rights at any time by:

Contacting us via email at info@polbridge.org.uk.

Your rights in relation to your personal data might be limited in some situations. For example, if fulfilling your request would reveal personal data about another person or if we have a legal requirement or a compelling legitimate ground we may continue to process your personal data which you have asked us to delete.

You also may have the right to make a complaint if you feel your personal information has been mishandled. We encourage you to come to us in the first instance but, to the extent that this right applies to you, you are entitled to complain directly to the relevant Information Commissioners Office (ICO).

7. Contact details of the data controller

The contact details of the Data Controller of the data processing described hereinabove are:

Polbridge Health Ltd. 104 Frank Lester Way, Luton, LU29NQ. Registered office address: 1 Treetops, Welwyn, England, AL6 0HU. Company number 10717265.

info@polbridge.org.uk

8. Contact details of our data protection officer (DPO)

Our Data Protection Officer (or "DPO") is available at:

robhood@polbridge.org.uk

9. Information about cookies

Cookies are small files which are stored on your computer, they hold a modest amount of data specific to you and allows a server to deliver a page tailored to you on your computer, hard drive, smartphone or tablet (hereinafter referred to as, “Device”). Later on, if you return to our Website, it can read and recognise the cookies. Primarily, they are used to operate or improve the way our Website works as well as to provide business and marketing information to the website owner.

In accordance with the notice of cookie usage appearing on our Website’s homepage and our Cookie Policy you opt for and consent to the use of non-essential cookies, when you accept the cookie notice on the landing page.

What follows is a description of the type of cookies used in the website:

9.1 Types of cookies according to the managing entity

Depending on what entity manages the computer or domain from which the cookies are sent and processed, there exist the following types of cookies:

First party cookies: these are sent to your Device from a computer or domain managed by us and from which the service you requested is provided.

Third party cookies: these are sent to your Device from a computer or domain that is not managed by us, but by a separate entity that processes data obtained through cookies e.g. Google Analytics

9.2. Types of cookies according to the length of time you stay connected:

Depending on the amount of time you remain active on your Device, these are the following types of cookies:

Session cookies: these are designed to receive and store data while you access the Website. These cookies do not remain stored on your Device when you exit the session or browser.

Persistent cookies: these types of cookies remain stored on your Device and can be accessed and processed after you exit the Website as well as when you navigate on it for a pre-determined period of time. The cookie remains on the hard drive until it reaches its expiration date. The maximum time we use persistent cookies on our Website is 2 years. At this point the browser would purge the cookie from the hard drive.

9.3. Types of cookies according to their purpose

Cookies can be grouped as follows:

a) Technical cookies: these cookies are strictly necessary for the operation of our Website and are essential for browsing and allow the use of various features. Without them, you cannot use the search function, compare tool or book other available services on our Website.

b) Personalisation cookies: these are cookies used to make navigating our Website easier, as well as to remember your selections and offer more personalised services. When you select the use of this we may allow advertisers or other third parties to place cookies on our Website to provide personalised content and services. If cookies are blocked, we cannot guarantee the functioning of such services.

c) Analytical cookies for statistical purposes and measuring traffic: these cookies gather information about your use of our Website, the pages you visit and any errors that may occur during navigation. We also use these cookies to recognise the place of origin for visits to our Website. These cookies do not gather information that may personally identify you. All information is collected in an anonymous manner and is used to improve the functioning of our Website through statistical information. Therefore, these cookies do not contain personal data. In some cases, some of these cookies are managed on our behalf by third parties, but may not be used by them for purposes other than those mentioned above.

List of cookies used on this Website:

Google Analytics: https://developers.google.com/analytics/devguides/collection/analyticsjs/cookie-usage

These companies have their own privacy policies in which they set forth both their own declarations as well as applicable disabling systems.

Polbridge Health Ltd is not responsible for the contents and accuracy of third party cookie policies contained in our Cookie Policy.

You must keep in mind that if your Device does not have cookies enabled, your experience on the Website may be limited, thereby impeding the navigation and use of our services.

There are a number of ways to manage cookies. By modifying your browser settings, you can opt to disable cookies or receive a notification before accepting them. You can also erase all cookies installed in your browser’s cookie folder. Keep in mind that each browser has a different procedure for managing and configuring cookies. Here’s how you manage cookies in the various major browsers:

MICROSOFT WINDOWS EXPLORER
GOOGLE CHROME
MOZILLA FIREFOX
APPLE SAFARI

See the following article on how to remove cookies from your device: https://us.norton.com/internetsecurity-privacy-how-to-clear-cookies.html


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