Personal information is collected by Zesty Limited a company incorporated in England and Wales with company number 08294659 whose registered office is at 82 St John Street, London, England, EC1M 4JN.
To provide you with our products and services, we may need information about you.
If you use the website, you are in control of what information we collect about you, but if you choose not to share your information, you may not be able to access or use some areas of the website.
We have appointed a data privacy manager who is responsible for overseeing questions in relation to this privacy notice. If you have any questions about this privacy notice, including any requests to exercise your legal rights, please contact the data privacy manager using the details set out below.
Name or title of data privacy manager:
Data Privacy Manager
Email address: email@example.com
Postal address: Runway East, 20 St Thomas St, London, SE1 9RS
You have the right to make a complaint at any time to the Information Commissioner's Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.
It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.
If you are a user of the website, we will collect information about you when you:
If you are a health professional registered on the website, we will collect information about you when you:
The information we collect and hold about you may include:
We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy notice.
We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.
If you are a user of the website, we use the information provided for purposes which may include:
If you are a health professional registered on the website, we use the information provided for purposes which may include:
We may use your information for account administration (for example to email you your password, if you forget it) and for added security. We may use your email address or mobile number to send you a confirmation of any order you make, if you arrange services from or through us, to confirm any profile changes you make and to respond to you if you contact us for information about our services. We might also use your email address to bring you news such as changes to the way you can use our online services or new services and special offers we think you might be interested in.
Whenever you give us your personal information, legally we have to use it in accordance with the terms of various privacy laws, including the Data Protection Act 1998.
Zesty Limited is registered with the ICO as Data Controllers in accordance with the Data Protection Act 1998 with Data Protection Registration Number ZA045251.
Every now and again, we receive requests for information from government departments, such as trading standards, the police and other enforcement agencies. If this happens, and we think there is a proper legal basis for providing your personal information, we will provide it to the organisation asking for it.
We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal basis we rely on to do so. We have also identified what our legitimate interests are where appropriate.
Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.
|Purpose/Activity||Type of data||Lawful basis for processing including basis of legitimate interest|
|To register you as a new customer||
|Performance of a contract with you|
To manage our relationship with you which will include:
(b) Asking you to leave a review or take a survey
(d) Marketing and Communications
(a) Performance of a contract with you
(b) Necessary to comply with a legal obligation (c) Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services)
|To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)||
(a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise)
(b) Necessary to comply with a legal obligation
|To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you||
(e) Marketing and Communications
|Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy)|
|To use data analytics to improve our website, products/services, marketing, customer relationships and experiences||
|Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our|
|business and to inform our marketing strategy)|
|To make suggestions and recommendations to you about services that may be of interest to you||
|Necessary for our legitimate interests (to develop our products/services and grow our business)|
Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us
Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.
Comply with a legal or regulatory obligation means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.
We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.
If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
When we use your information, this may occasionally involve sending your information outside the European Economic Area (EEA). Where we do this, we make sure that appropriate steps are taken to protect your personal information and your rights. By providing us with your personal information, you agree that we may transfer, store and process your information outside the EEA.
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.
We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
Cookies are information files stored on your web browser or computer that help websites remember you. We collect information about your use of the website through cookies.
Your mobile phone can also store information files that help us remember you when you use our services. We collect information about your use of our services through on-device storage.
We will store cookies on your hard drive in order to save you time with data entries such as locations, username and passwords.
This information does not allow us to identify you. We collect it from lots of visitors to our websites and analyse it. This lets us build up a picture of how people use our websites. This helps us improve the services we offer.
We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.
To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.
Details of retention periods for different aspects of your personal data are available in our retention policy which you can request from us by contacting us.
We may record or monitor calls that you receive from us, or make to us or to a health professional using a telephone number provided on our website and which we operate. We do this for security and training purposes and to improve the service we provide to you.
We may provide copies of recordings of calls to a health professional where you have made a call to book an appointment with that health professional using a telephone number provided on our website.
If you give us feedback, we may use it to improve our products and services and we may publish it online or offline to promote our business, products and services.
If you wish to submit a comment or feedback on a blog or article featured on the website, we may (but are not obliged to) publish your comment online or offline to promote our business, products and services. We will collect your name which may be displayed next to your comment, and e-mail address and which we may use to contact you in relation to your comment. We may remove any comments at any time.
Under certain circumstances, you have rights under data protection laws in relation to your personal data. You have the right to:
Request access to your personal data (commonly known as a "data subject access request"). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data's accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine- readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent. If you wish to exercise any of the rights set out above, please contact us.
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
We may contact you:
We offer you the chance to receive news from us and information about our products and services, such as The Zesty Newsletter, about changes to the way you can use our online services or about new services and special offers you might be interested in.
Unless you tell us otherwise, we may contact you by phone, post, email, text message or any other way (electronic or otherwise). We will normally send you direct marketing by email if we have your email address.
If you would like us to stop sending direct marketing to you may email us at firstname.lastname@example.org
If you tell us that you do not want to receive direct marketing, we will still contact you in order to provide you with services you request and for administration purposes.
We will aggregate non-personally identifiable data in order to understand appointment demand, user habits, trends and user preferences.
We take the security of your personal information very seriously. We have put in place technology and security policies which are designed to protect the personal information that we hold about you. We also follow the strict security procedures that privacy laws require. These cover storing, using and releasing any information you have provided, and preventing unauthorised access or use.
We will not sell any personal information to any third parties. Additionally, except in providing the goods and/or services on our website, we will not release, give, lease, or transfer your personal data to third parties (other than if we sell or transfer our business or part of it).
Adopted on 29th March 2019.
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