Last updated: 22/05/2018
WHO IS COLLECTING MY DATA?
This Privacy Statement explains how Spectrum Wellness will process your professional and personal information in accordance with the General Data Protection Regulation 2016 (GDPR) effective from May 25th 2018, replacing the existing data protection framework under the EU Data Protection Directive. Spectrum Wellness, through Spectrum Health, are registered with the Data Protection Commissioner (DPC) Registration Number 13807/A as data controllers.
As data controllers, Spectrum Wellness employs appropriate technical and organisational measures to meet the requirements of GDPR and ensures that all processors do the same.
PRIVATE PRACTICES AND DIRECT MARKETING
We will never use your data for direct marketing purposes without your consent. At any time you may opt out (i.e. refuse the use of your personal data), including at the time the data is collected, or on every subsequent marketing message. Unsubscribing will always be free of charge and fully respected.
It should be noted that other methods of communication (confirmation of appointments or reminders, etc.) do not fall under “direct marketing”, however consent will still be collected for this.
WHAT TYPE OF DATA IS COLLECTED?
Spectrum Wellness complies with the EU Data Protection Directive 95/46/EC as set forth by the European Union regarding the collection, use, and retention of personal data from European Union member countries. Spectrum Wellness has certified that it adheres to the requirements of notice, choice, onward transfer, security, data integrity, access and enforcement.
We collect two types of data: personal data, and sensitive personal data.
- Personal data can be used to identify or contact you, and may include: your name, address, date of birth, telephone number, and email address. This will only be collected if you voluntarily submit it to us.
- Sensitive personal data is relating to your health, and is collected for the purposes of our digital wellness products HealthScore and MindScore, as well as any other virtual or digital product operated by Spectrum Wellness and health and wellness practitioners.
WHAT IS MY DATA BEING USED FOR?
- When you contact Spectrum Wellness to avail of or enquire about any of our services via a form on our website or by phone, we will ask you to provide your name, email address, the company you work with, your work phone number, your job title and the number of employees working at your company.
This information provided will be used by Spectrum Wellness to:
- verify your identity
- provide you with the service or information you have requested
- respond to your enquiries or provide customer support effectively
- create a customer file which will contain your future bookings on behalf of the company you work with
- send updates regarding your appointments and programmes
- contact you in the case of a data breach
- provide you with advice, dependant on the information you have given
- seek feedback for ongoing service improvements
- communicate with you regarding other Spectrum Wellness products and services
When we communicate with you regarding our products and services for the first time we will give you the option to “opt-in,” and on every subsequent communication there will be an option to “unsubscribe.” If you subscribe to our email newsletter, we use email tracking to record and save your email address to your subscriber record to monitor and store your preferences.
If you are using one of our digital wellness products or screens or one of our health and wellness practitioners, your personal data is being collected during screening in order to provide you with a personalised and comprehensive report or programme. We will not share any of your personal or sensitive data with your employer. Your employer will receive a company overview report containing only anonymised and aggregated data about the health and wellness of their employees as a whole.
Spectrum Wellness will never share your personal or sensitive information with any other third party, including your employer, without your consent unless required to do so by law.
WHAT HAPPENS TO MY DATA?
All of your personal and health data is stored securely, offsite and in electronic format on a Customer Management System. All electronic communications are hosted within platforms which are SSL-secure, password protected and encrypted. Spectrum Wellness has adequate measures in place to ensure that your information is held securely, within the EU. Any personally identifiable information you elect to make available publicly on our sites – e.g. posting comments on any of our blog posts – will be available to others.
WHO HAS ACCESS TO MY DATA?
Access is restricted to essential personnel of Spectrum Wellness who are bound by their professional ethics and/or confidentiality agreements.
We may provide non-personal data to third parties, where such information is combined with similar information of other users of our website. For example, we might inform third parties regarding the number of unique users who visit our website, the demographic breakdown of our community users of our website, or the activities that visitors to our website engage in while on our website.
The third parties to whom we may provide this information may include, commercial partners, sponsors, licensees, researchers, sister companies and other similar parties. We will never disclose your Personal Data to third parties unless you have consented to this disclosure or unless the third party is required to fulfil your order (in such circumstances, the third party is bound by similar data protection requirements).
We will disclose your Personal Data if we believe in good faith that we are required to disclose it in order to comply with any applicable law, a summons, a search warrant, a court or regulatory order, or other statutory requirement.
HOW LONG IS MY DATA HELD FOR?
Your data will be held by Spectrum Wellness as long as is legally required.
WHAT ARE MY RIGHTS?
You can contact us at any time to:
- Request personal or sensitive personal data about yourself
- Correct any information if it is incomplete or misleading
- Withdraw your consent regarding the processing of your data at any time
- Review our Data Protection Policy
- Ask any questions about your data
Any request should be put in writing and will be responded to, by us within 30 days. Please contact us either by email at email@example.com or by post at 95 Merrion Square West, Dublin 2. All correspondence should be marked for the attention of our GDPR team.
For your protection, we may need to verify your identity to process your request.
USE OF SPECTRUM WELLNESS WEBSITES
Like most websites, we gather statistical and other analytical information collected on an aggregate basis of all visitors to our website.
This Non-Personal Data comprises of information that cannot be used to identify or contact you; such as demographic information regarding, for example, user IP addresses where they have been clipped or anonymised, browser types and other anonymous statistical data involving the use of our websites.
Any external links to other websites are clearly identifiable as such, and we are not responsible for the content or the privacy policies of these other websites.
You are always free to decline our cookies, if your browser permits, or to ask your browser to indicate when a cookie is being sent. You can also delete cookie files from your computer at your discretion. Note that if you decline our cookies or ask for notification each time a cookie is being sent, this may affect your ease of use of this website.
FACEBOOK CONVERSION TRACKING PIXEL
Spectrum Wellness may, from time to time, use Facebook Advertising, Facebook Pixel Re-Marketing, and communications. This tool allows us to understand and deliver ads, making them more relevant to you. The collected data remains anonymous, and we cannot see the personal data of any individual user.
However, the collected data is saved and processed by Facebook. Facebook may be able to connect the data with your Facebook account and use the data for their own advertising purposes (in accordance with Facebook’s Data Use Policy found under: https://www.facebook.com/about/privacy/).
Spectrum Wellness may, from time to time, utilise Google’s remarketing technology. This allows us to display relevant ads based on the pages on the Spectrum website you have viewed. The advertisements will be displayed using cookies. This cookie will not record any personal information or identify you personally.
Google has its own data protection policy which can be accessed here: https://www.google.com/intl/en/policies/privacy/.
We take our security responsibilities seriously, taking all reasonable steps, including appropriate technical and organisational measures to protect your data. We review our security measures regularly.
If you have reason to believe that your interaction with us is no longer secure, please contact us immediately via email firstname.lastname@example.org or phone +353-1-6111-740.
SALE OF BUSINESS
We reserve the right to transfer information (including your personal data) to a third party in the event of a sale, merger, liquidation, receivership or transfer of all or substantially all of the assets of our company in the following cases:
- provided that the third party will only use your Personal Data for the purposes that you provided it to us.
You will be notified in the event of any such transfer and you will be afforded an opportunity to opt-in.
UPDATES TO THIS PRIVACY STATEMENT
We may change this privacy statement, however the “last updated” date will always be listed at the top of this page. Any changes will be effective immediately.