Privacy policy

Introduction

This privacy notice provides you with details of how we collect and process your personal data through your use of our site www.organsymphonyhealth.com.

This website is not intended for children and we do not knowingly collect data relating to children. By providing us with your data, you warrant to us that you are over 13 years of age.

It is important that you read this privacy policy together with any other privacy policy or fair processing policy we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy policy supplements other notices and privacy policies and is not intended to override them.

Organ Symphony Health Ltd is the data controller and we are responsible for your personal data (referred to as “we”, “us” or “our” in this privacy notice). We have appointed a data privacy manager who is responsible for overseeing questions in relation to this privacy policy. If you have any questions about this privacy policy, including any requests to exercise your legal rights, please contact the data privacy manager using the details set out below.

Contact details

Our full details are:

Full name of legal entity: Organ Symphony Health Ltd

Email address: hello@organsymphonyhealth.com

Postal address: 41 Whitcomb Street, London, WC2H 7DT

You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK regulator 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.

Changes to the privacy policy and your duty to inform us of changes

We keep our privacy policy under regular review.

It is very important that the information we hold about you is accurate and up to date. Please let us know if at any time your personal information changes by emailing us at hello@organsymphonyhealth.com

Third-party links

This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy policy of every website you visit.

What data do we collect about you

Personal data means any information capable of identifying an individual. It does not include anonymised data. It does not include data where the identity has been removed (anonymous data).

We may process the following categories of personal data about you:

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

  • Contact Data includes billing address, delivery address, email address and telephone numbers.

  • Financial Data includes bank account and payment card details.

  • Transaction Data includes details about payments to and from you and other details of what you have purchased from us.

  • Usage Data that includes data about how you use our website and any online services together with any data that you post for publication on our website or through other online services.

  • Technical Data that includes data about your use of our website and online services such as your internet protocol (IP) address, your login data, details about your browser plug in types and versions, length of visit to pages on our website, page views and navigation paths, details about the number of times you use our website, time zone settings and other technology on the devices you use to access our website.

  • Profile Data includes your username and password, purchases or orders made by you, your interests, preferences, feedback and survey responses.

  • Marketing Data that includes data about your preferences in receiving marketing from us and our third parties and your communication preferences.

We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data could be derived from your personal data but is not considered personal data in law as this data will 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 policy.

Sensitive Data

We do not collect any Sensitive Data about you. Sensitive data refers to data that 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. We do not collect any information about criminal convictions and offences.

If you fail to provide personal data

Where we need to collect personal data by law, or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with goods or services). In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.

How we collect your personal data

We may collect data about you by directly interacting with you. You may give us your Identity, Contact and Financial Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:

  • apply for our products or services;

  • create an account on our website;

  • subscribe to our service or publications;

  • request marketing to be sent to you;

  • enter a competition, promotion or survey; or

  • give us feedback or contact us.

We may obtain information through automated technologies or interactions. As you interact with our website, we will automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies and other similar technologies. Please see our cookie policy for further details.

We may also collect data via third parties or publicly available sources. We will receive personal data about you from various third parties and public sources as set out below:

  • Technical Data from the following parties:

    • analytics providers such as Google based outside the UK;

    • advertising networks such as Facebook based outside the UK;

    • search information providers such as Google based outside the UK;

  • Identity and Contact Data from publicly available sources such as Companies House and the Electoral Register based inside the UK; and

  • Identity and Contact Data from networking events that you attend.

How we use your personal data

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

  • Where we need to perform the contract we are about to enter into or have entered into with you.

  • Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.

  • Where we need to comply with a legal obligation.

Generally, we do not rely on consent as a legal basis for processing your personal data although we will get your consent before sending third party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us.

Purposes for which we will use your personal data

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 bases 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 by category of individuals in the list below.

  • Purpose/Activity: To administer and protect our business and our website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)

    To deliver relevant website content to you and measure or understand the effectiveness of advertising

    To monitor use of our website and to use data analytics to improve our website, products/services, marketing, customer relationships and experiences

    What information is collected?: Website Data as referred to above including your IP address

    Lawful basis for processing: 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)

    Necessary for our legitimate interests (to study how clients use our products/services, to develop them, to grow our business and to inform our marketing strategy)

    Necessary for our legitimate interests (to define types of clients for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy)

  • Purpose/Activity: To respond to requests made via our website, social media channels, or by email, telephone or post and provide information about our services.

    What information is collected?: Name, email address, and any information provided in your message to us.

    Lawful basis for processing: Necessary for our legitimate interests (to respond to enquiries from potential clients and other interested parties)

    Necessary to perform our contract with you (where you are communicating with us in connection with our services)

  • Purpose/Activity: To send marketing materials to those individuals about our services or events that we feel may be of interest to you.

    What information is collected?: Name, email address, job title and role

    Lawful basis for processing: Necessary for our legitimate interests (to promote our services and events to interested parties who have not declined or opted out of receiving communications from us)

  • Purpose/Activity: To evaluate potential service providers, and to enter into and perform contracts with our service providers

    What information is collected?: Name, contact details and job title

    Lawful basis for processing: Necessary for our legitimate interests (where we have engaged a third-party service provider, we require to be in contact with representatives of that service provider in order to receive the full benefit of their services)

  • Purpose/Activity: To recruit members of staff to fulfil vacant positions and to undertake equal opportunities monitoring

    What information is collected?: Name, email address, contact details, details you provide in our application forms and in your CV, the details of necessary background checks, information from referees and right to work documentation

    Lawful basis for processing: Necessary for us to take required steps before potentially entering into an employment contract with you

    Necessary for our legitimate interests (to keep a record of applications in the event of a claim)

  • Purpose/Activity: As part of our delivery services

    What information is collected?: Publicaly available information

    Lawful basis for processing: Necessary for our legitimate interests (for running our business)

Change of purpose

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. For more information on this please email us at hello@organsymphonyhealth.com. In case we need to use your details for an unrelated new purpose we will let you know and explain the legal grounds for processing.

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.

Marketing communications

We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising. Our lawful ground of processing your personal data to send you marketing communications is either your consent or our legitimate interests (namely to grow our business). We have established the following personal data control mechanisms:

Promotional offers from us

We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you (we call this marketing).

You will receive marketing communications from us if you have requested information from us or made a purchase from us and you have not opted out of receiving that

Third-party marketing

Before we share your personal data with any third party for their own marketing purposes we will get your express consent.

Opting out

You can ask us or third parties to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you or by emailing us at hello@organsymphonyhealth.com at any time.

If you opt out of receiving marketing communications this opt-out does not apply to personal data provided as a result of other transactions, such as purchases, warranty registrations etc.

Cookies

You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly.

Disclosures of your personal data

We may have to share your personal data with the parties set out below:

  • Service providers who provide IT and system administration services.

  • Professional advisers including lawyers, bankers, auditors, accountants and insurers;

  • Government bodies that require us to report processing activities (such as HM Revenue & Customs, regulators and other authorities).

  • Third parties to whom we sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy policy.

We require all third parties to whom we transfer your data to respect the security of your personal data and to treat it in accordance with the law. We only allow such third parties to process your personal data for specified purposes and in accordance with our instructions.

International transfers

Whenever we transfer your personal data out of the UK, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

  • We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data.

  • Where we use certain service providers, we may use specific contracts approved for use in the UK which give personal data the same protection it has in the UK.

Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the UK.

Data security

We have put in place security measures to prevent your personal data from being accidentally lost, used, altered, disclosed, or accessed without authorisation. We also allow access to your personal data only to those employees, agents, contractors, partners and other third parties who have a business need to know such data. They will only process your personal data on our instructions and they must keep it confidential. We have procedures in place to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach if we are legally required to.

Data retention

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. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.

When deciding what the correct time is to keep the data for we look at its amount, nature and sensitivity, potential risk of harm from unauthorised use or disclosure, the processing purposes and if these can be achieved by other means and the applicable legal, regulatory, tax, accounting or other requirements.

For tax purposes the law requires us to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for six years after they stop being customers.

In some circumstances we may anonymise your personal data for research or statistical purposes in which case we may use this information indefinitely without further notice to you.

Your legal rights

Under data protection laws you have rights in relation to your personal data that include the right to request access, correction, erasure, restriction, transfer, to object to processing and (where the lawful ground of processing is consent) to withdraw consent.

You can see more about these rights at: https://ico.org.uk/for-organisations/guide-to-the-general-data-protection-regulation-gdpr/individual-rights/

If you wish to exercise any of the rights set out above, please email us at hello@organsymphonyhealth.com.

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 or 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.