General
Your privacy is important to Medical Massage Lady. I respect your privacy and I am committed to protecting your personal data. This privacy policy will inform you as to how I look after your personal data when you visit my website (regardless of where you visit it from) and tell you about your privacy rights and how the law protects you. This policy is intended to give you confidence in the privacy and security of the personal information I obtain from you whether you upload information from my Website, download it or are simply visiting my Website. I cannot, however, be responsible for any use of the personal information you provide to third party Websites which may be accessed through our Website.
1. Important information
Purpose of this privacy policy
This privacy policy aims to give you information on how The Medical Massage Lady collects and processes your personal data through your use of this Website, including any data you may provide through this Website when you agree to receive further information from me, purchase one or more of our product or services or take part in any competition or survey circulated by me.
[I do not knowingly collect data relating to minors (i.e. those under 18 years). While I am happy to supply information relating to my courses to minors I do not accept orders for courses and or course materials and similar / ancillary items / products from minors without parent/guardian consent.’
It is important that you read this privacy policy together with any other privacy policy or fair processing policy I may provide on specific occasions when I am collecting or processing personal data about you so that you are fully aware of how and why I am using your data. This privacy policy supplements any other notices issued by me which relate to specific circumstances and / or information and is not intended to override such specific notices.
Controller
The Medical Massage Lady is the data controller in relation to all data collected, is responsible for your personal data and is referred to as , “I", "me" or “my” in this privacy policy.
The UK Regulator for data protection issues is the Information Commissioner. You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), whose website address is www.ico.org.ukp. I 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 me of changes
I keep my privacy policy under regular review.
It is important that the personal data I hold about you is accurate and current. Please keep me informed if your personal data changes during your relationship with me.
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. I do not control these third-party websites and am not responsible for their privacy statements. When you leave my website, I encourage you to read the privacy policy of every website you visit.
2. The data I collect about you
Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).
I may collect, use, store and transfer different kinds of personal data about you which I have grouped together as follows:-
Identity Data includes first name, last name, username or similar identifier, , title, date of birth.
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 products and services you have purchased from me.
Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access this website.
Profile Data includes your purchases made and/ or orders placed by you and/or on your behalf, your interests, preferences, feedback and survey responses.
Usage Data includes information about how you use my website, products and services.
Marketing and Communications Data includes your preferences in receiving marketing from me and my third parties and your communication preferences.
I 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, I may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if I combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, I treat the combined data as personal data which will be used in accordance with this privacy policy.
I 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 I collect any information about criminal convictions and offences.
If you fail to provide personal data
Where I need to collect personal data by law, or under the terms of a contract I have with you, and you fail to provide that data when requested, I 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, I may have to cancel a product or service you have with me but I will notify you if this is the case at the time.
3. How is your personal data collected?
I use different methods to collect data from and about you including through:-
Direct interactions. You may give me 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:-
Make a purchase and / or place an order with me;
request information or marketing to be sent to you;
enter a competition, promotion or survey; or
give me feedback or contact me.
Automated technologies or interactions. As you interact with my website, I will automatically collect Technical Data about your browsing actions and patterns. I collect this personal data by using cookies, server logs and other similar technologies. I may also receive Technical Data about you if you visit other websites employing my cookies. Please see my cookie policy included within this document for further details.
Third parties or publicly available sources. I will receive personal data about you from various third parties and public sources as set out below as and when appropriate.
Technical Data from the following parties:
(a) analytics providers such as Google based outside the UK;
(b) advertising networks such as Criteo and whether based inside or outside the UK; and
(c) search information providers such as Algolia and whether based inside or outside the UK.
Contact, Financial and Transaction Data from providers of technical, payment and delivery services such as First Data, Etika and SagePage and whether based inside or outside the UK.
Identity and Contact Data from data brokers or aggregators such as Business Data Prospects and whether based inside or outside the UK.
Identity and Contact Data from publicly available sources such as Companies House and the Electoral Register based inside the UK.
4. How I use your personal data
I will only use your personal data when the law allows me to. Most commonly, I will use your personal data in the following circumstances:-
Where I need to perform the contract I am about to enter into or have entered into with you.
Where it is necessary for my legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
Where I need to comply with a legal obligation.
Please see the table below as to the types of lawful basis that I will rely on to process your personal data.
Generally, I do not rely on consent as a legal basis for processing your personal data although I 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 me.
Purposes for which we will use your personal data
I have set out below, in a table format, a description of all the ways I plan to use your personal data, and which of the legal bases I rely on to do so. I have also identified what my legitimate interests are where appropriate.
Note that I may process your personal data for more than one lawful ground depending on the specific purpose for which I am using your data. Please contact me if you need details about the specific legal ground I am relying on to process your personal data where more than one ground has been set out below.
Purpose/activity: To register you as a new customer
Type of data: (a) Identity (b) Contact
Lawful basis for processing including basis of legitimate interest: Performance of a contract with you
Purpose/activity: To process and deliver your order including:(a) Manage payments, fees and charges (b) Collect and recover money owed to me
Type of data: (a) Identity (b) Contact (c) Financial (d) Transaction (e) Marketing and Communications
Lawful basis for processing including basis of legitimate interest: a) Performance of a contract with you (b) Necessary for my legitimate interests (to recover debts due to me)
Purpose/activity: To manage my relationship with you which will include: (a) Notifying you about changes to my terms or privacy policy (b) Asking you to leave a review or take a survey (c) Providing updates relating to any material changes to course information including (but not limited to)changes to syllabus, examinations and assessments and tutor details
Type of data: (a) Identity (b) Contact (c) Profile (d) Marketing and Communications
Lawful basis for processing including basis of legitimate interest: (a) Performance of a contract with you (b) Necessary to comply with a legal obligation (c) Necessary for my legitimate interests (to keep my records updated and to study how customers use my products/services)
Purpose/activity: To enable you to partake in a prize draw, competition or complete a survey
Type of data: (a) Identity (b) Contact (c) Profile (d) Usage (e) Marketing and Communications
Lawful basis for processing including basis of legitimate interest: (a) Performance of a contract with you (b) Necessary for my legitimate interests (to study how customers use my products/services, to develop them and grow my business)
Purpose/activity: To administer and protect my business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)
Type of data: (a) Identity (b) Contact (c) Technical
Lawful basis for processing including basis of legitimate interest: (a) Necessary for my legitimate interests (for running my 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
Purpose/activity: To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising I serve to you including
Type of data: (a) Identity (b) Contact (c) Profile (d) Usage (e) Marketing and Communications (f) Technical
Lawful basis for processing including basis of legitimate interest: Necessary for my legitimate interests (to study how customers use our products/services, to develop them, to grow my business and to inform my marketing strategy)
Purpose/activity: To use data analytics to improve my website, products/services, marketing, customer relationships and experience
Type of data: (a) Technical (b) Usage
Lawful basis for processing including basis of legitimate interest: Necessary for my legitimate interests (to define types of customers for my products and services, to keep my website updated and relevant, to develop my business and to inform my marketing strategy)
Purpose/activity: To make suggestions and recommendations to you about goods or services that may be of interest to you including marketing and sales information / promotions and / or offers.
Type of data: (a) Identity (b) Contact (c) Technical (d) Usage (e) Profile (f) Marketing and Communications
Lawful basis for processing including basis of legitimate interest: Necessary for my legitimate interests (to develop my products/services and grow my business)
Marketing
I strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising as follows;
Promotional offers from me
I may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what I think you may want or need, or what may be of interest to you. This is how I decide which products, services and offers may be relevant for you .
You will receive marketing communications from me if you have requested information from me or purchased goods or services from me and you have not opted out of receiving that marketing.
Third-party marketing
I never share your data with any third party. If that ever changes, I will get your express opt-in consent before I share your personal data with any third party for marketing purposes.
Opting out
You can ask me 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 contacting me at any time.
Where you opt out of receiving these marketing messages, this will not apply to personal data provided to me as a result of a purchase made or an order placed with me by you, warranty registration, or service experience.
Cookies and our Cookie Policy
A Cookie is a small text file stored on your computer and used by your web browser. They can be used for many different purposes, and on this Website some of them are essential to deliver the functionality needed to run this Website and to enrol on a course.
My Cookie Policy applies to websites operated directly by me.
By accessing this Website, you agree that my Cookie Policy will apply whenever you access this Website on any device. My Cookie Policy forms part of and is incorporated in to my Website Terms and Conditions.
Any alterations and / or amendments to my Cookie Policy will be posted on my Website. I reserve the right to vary my Cookie Policy from time to time. Such changes shall become effectively immediately they are posted. Your continued use of the Website constitutes your agreement to all such alterations and/or amendments.
Our use of Cookies
I may collect information automatically when you visit the Website. Such information is stored in a Cookie.
I have placed my use of Cookies into three categories as follows:-
Required Cookies;
Analytical Cookies;
Advertising Cookies.
Required Cookies
When you browse my Website some cookies are required for the site to work correctly. Data is collected via these Cookies for audit purposes. This functionality may include remembering which course product you have added to the shopping basket, or which payment plan you have selected as your preferred option.
Analytical Cookies
These Cookies monitor how visitors navigate around the Website and how they found it in the first place. I use these Cookies to enable me to monitor total (not individual) figures as to which type of content is most popular with users and also to identify problems with the Website which may need to be rectified or improved upon. This enables me to provide my users with a better experience of using my site.
Advertising Cookies
My courses are advertised on third party websites as well as on social networks. I work with third party media partners to achieve this.
Advertising Cookies store information about the user’s computer. They do not store personal information about the individual. They are likely, however to store information about which products have been browsed by your computer.
The following are the third party services I use with details of how to opt out / control the use of the relevant Cookies:Google (DoubleClick)
Microsoft Ads/Bing
Changing Cookie Settings
You have the option not to use Cookies at all. However, if you choose this option I cannot guarantee that you experience with my Website will be as good as it would have been had you allowed the use of Cookies.
As a final note, information collected by Cookies does not collect information which identifies you personally. It includes general information about your computer settings, your internet connection, IP address, browsing patterns (including timings) and location
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.
Change of purpose
I will only use your personal data for the purposes for which I collected it, unless I reasonably consider that I need to use it for another reason and that reason is compatible with the original purpose.
If I need to use your personal data for an unrelated purpose, I will notify you and I will explain the legal basis which allows me to do so.
Please note that I may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
5. Disclosures of your personal data
I may share your personal data with the parties set out below for the purposes set out in the table Purposes for which I will Use Your Personal Data above:
Internal Third Parties as set out above.
External Third Parties as set out above.
Third parties to whom I may choose to sell, transfer or merge parts of my business or our assets. And/or with who I have commercial co-operation and / or joint venture arrangements (or similar) from time to time. Alternatively, I may seek to acquire other businesses or merge with them. If a change happens to my business, then the new owners may use your personal data in the same way as set out in this privacy policy.
I require all third parties to respect the security of your personal data and to treat it in accordance with the law. I do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with my instructions.
6. International transfers
At times I may share your personal data with entities outside UK. This will involve transferring your data outside the UK.
We have reviewed all our systems and the below are those that process data outside of the UK and their locations:
Facebook (Ads) | USA | Advertising
Google Ads | Europe | Advertising
Google Data Studio | Europe | Reporting and insights
7. Data security
I 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, I 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.
All account information is password protected. Where appropriate I use industry standard Secure Socket Layer (SSL) encryption to protect data transmission.
I use SSL technology extensively on our all back-office systems which store and / or process customer account information.
I endeavour to make purchasing my products and services as safe as I reasonably can. Your browser will automatically default to secure mode before you enter any personal or payment details. This means that all of your details are encrypted to keep them secure.
I only accept payments which are placed using SSL. I do not store debit or credit card details on my servers once initial payment has been made and processed. All such details are stored securely through Symantec which uses internationally recognised encryption systems. Encryption keys are then held on state-of-the-art tamper-proof systems. I 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 I are legally required to do so.
8. Data retention
How long will you use my personal data for?
I will only retain your personal data for as long as reasonably necessary to fulfil the purposes I collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. I may retain your personal data for a longer period in the event of a complaint or if I reasonably believe there is a prospect of litigation in respect to my relationship with you.
To determine the appropriate retention period for personal data,I 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 I process your personal data and whether I can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.
As a general guide, I retain enquiry information for a period of up to two years from the date of the last enquiry. After that time the information is securely archived. All archived information is kept for a minimum period of six years from the date of receipt.
By law I have to keep basic information about my customers (including Contact, Identity, Financial and Transaction Data) for a minimum of six years after they cease being customers (this is usually once the individual has completed their course) for tax purposes.
In some circumstances you can ask me to delete your data: -
In some circumstances I will anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case I may use this information indefinitely without further notice to you.
9. Your legal rights
Under certain circumstances, you have rights under data protection laws in relation to your personal data.
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, I may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, I could refuse to comply with your request in these circumstances.
I may need to request specific information from you to help me 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. I may also contact you to ask you for further information in relation to your request to speed up my response.
I try to respond to all legitimate requests within one month. Occasionally it could take me longer than a month if your request is particularly complex or you have made a number of requests. In this case, I will notify you and keep you updated.