1.1 Aqua-Rehab are committed to safeguarding the privacy of our website visitors and visitors to the Practice.

1.2 This Policy applies where we are acting as a data controller with respect to the personal data of our clients; in other words, where we determine the purposes and means of the processing of that personal data.

1.3 By using our website and agreeing to this Policy, you consent to our use of cookies in accordance with the terms of this policy.

1.4 In this Policy, “we”, “us” and “our” refer to Aqua-Rehab. For more information about us, see Section 13.

2. How we use your personal data

2.1 In this part we have set out:

(a) the general categories of personal data that we may process;
(b) in the case of personal data that we did not obtain directly from you, the source and specific categories of that data;
(c) the purposes for which we may process personal data; and
(d) the legal bases of the processing.

2.2 We may process “account data”. The account data may include your name, address and email address. The account data may be processed for the purposes of operating our website, providing our services, ensuring the security of our website and services, maintaining back-ups of our databases and communicating with you. The legal basis for this is our legitimate interests, namely the proper administration of our website and business.

2.3 We may process your personal data which is provided in the course of the use of our services (“service data”). The service data may include
• personal details, name, address, e-mail address, contact number, source of referral
• medical notes
• family details
• lifestyle and social circumstances
• case manager/insurance company details for purposes of reports and payment

We also process sensitive classes of information that may include:
• physical or mental health details
• sexual life
• racial or ethnic origin
• religious or other beliefs of a similar nature
• offences and alleged offences
• employment and education details

The data may be collected over the telephone, by e-mail, through the website, on initial assessment when you fill in forms for our records, at the point of referral from an external source e.g. through a case manager, an insurance company or other medical practitioner or through an informal or formal complaint where details are required in order to handle the complaint.

The service data may be processed for the purposes of operating our website, providing our services, ensuring the security of our website and services, maintaining back-ups of our databases and communicating with you. The legal basis for this processing is our legitimate interests, namely the proper administration of our website and business.

2.4 We may process information contained in any enquiry you submit to us regarding our services (“enquiry data”). The enquiry data may be processed for the purposes of offering, marketing and selling relevant services to you. The legal basis for this processing is our legitimate interests, namely the proper administration of our website and business.

2.5 We currently do not take any payments via our website or card reader, therefore we do not hold any “transaction data”. If you pay for our service via bank transfer then you should refer to your own banks privacy policy.

2.6 We may process information that you provide to us for the purpose of subscribing to our email notifications and/or newsletters (“notification data”). The notification data may be processed for the purposes of sending you the relevant notifications and/or newsletters. The legal basis for this processing is the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract.

2.7 We may process information contained in or relating to any communication that you send to us (“correspondence data”). The correspondence data may include the communication content and metadata associated with the communication. Our website will generate the metadata associated with communications made using the website contact forms. The correspondence data may be processed for the purposes of communicating with you and record-keeping. The legal basis for this processing is our legitimate interests, namely the proper administration of our website and business and communications with users.

2.8 We may process any of your personal data identified in this Policy where necessary for the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure. The legal basis for this processing is our legitimate interests, namely the protection and assertion of our legal rights, your legal rights and the legal rights of others.

2.9 In addition to the specific purposes for which we may process your personal data explained in Section 2, we may also process any of your personal data where such processing is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.

2.10 Please do not supply any other person’s personal data to us, unless we prompt you to do so.

3. Providing your personal data to others

3.1 We may disclose personal data to:-

• healthcare professionals
• Insurance Companies
• yourself
• social and welfare organisations.
• family, associates and representatives of yourself
• current, past and prospective work colleagues;

3.2 In addition to the specific disclosures of personal data set out in this Section 3, we may disclose your personal data where such disclosure is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person. We may also disclose your personal data where such disclosure is necessary for the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure.

4. International transfers of your personal data

4.1 It may sometimes be necessary to transfer personal information overseas. When this is needed information is only shared within the European Economic Area (EEA).

We process information relevant to the above reasons/purposes. This information may include:
• personal details
• medical notes
• family details
• lifestyle and social circumstances
• employment and education details

We also process sensitive classes of information that may include:
• physical or mental health details
• sexual life
• racial or ethnic origin
• religious or other beliefs of a similar nature
• offences and alleged offences

4.2 You acknowledge that personal data that you submit for publication through our website or services may be available, via the internet, around the world. We cannot prevent the use (or misuse) of such personal data by others.

5. Retaining and deleting personal data

5.1 This Section 5 sets out our data retention policies and procedures, which are designed to help ensure that we comply with our legal obligations in relation to the retention and deletion of personal data.

5.2 Personal data that we process for any purpose or purposes shall not be kept for longer than is necessary for that purpose or those purposes.

5.3 We will retain your personal data as follows:
(a) enquiry information that does not lead to any treatments will be held for 12 months.
(b) personal data and medical notes will be retained for a minimum period of 7 years for adults and 20 years for children following the patient’s last appointment.

5.4 Notwithstanding the other provisions of this Section 5, we may retain your personal data where such retention is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.

6. Amendments

6.1 We may update this policy from time to time by publishing a new version on our website.

7. Your Rights

7.1 In this Section 7, we have summarised the rights that you have under data protection law. Some of the rights are complex, and not all of the details have been included in our summaries. Accordingly, you should read the relevant laws and guidance from the regulatory authorities for a full explanation of these rights.

7.2 Your principal rights under data protection law are:

(a) the right to access;
(b) the right to rectification;
(c) the right to erasure;
(d) the right to restrict processing;
(e) the right to object to processing;
(f) the right to data portability;
(g) the right to complain to a supervisory authority; and
(h) the right to withdraw consent.

7.3 You have the right to confirmation as to whether or not we process your personal and medical data and, where we do, access to the personal and medical data, together with certain additional information. That additional information includes details of the purposes of the processing, the categories of personal and medical data concerned and the recipients of the personal and medical data. Providing the rights and freedoms of others are not affected, we will supply to you a copy of your personal and medical data. The first copy will be provided free of charge, but additional copies may be subject to a reasonable fee.

7.4 You have the right to have any inaccurate personal data about you rectified and, taking into account the purposes of the processing, to have any incomplete personal data about you completed.

7.5 In some circumstances you have the right to the erasure of your personal data without undue delay. Those circumstances include: the personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed; you withdraw consent to consent-based processing; you object to the processing under certain rules of applicable data protection law; the processing is for direct marketing purposes; and the personal data have been unlawfully processed. However, there are exclusions of the right to erasure. The general exclusions include where processing is necessary: for exercising the right of freedom of expression and information; for compliance with a legal obligation; or for the establishment, exercise or defence of legal claims.

7.6 In some circumstances you have the right to restrict the processing of your personal data. Those circumstances are: you contest the accuracy of the personal data; processing is unlawful but you oppose erasure; we no longer need the personal data for the purposes of our processing, but you require personal data for the establishment, exercise or defence of legal claims; and you have objected to processing, pending the verification of that objection. Where processing has been restricted on this basis, we may continue to store your personal data. However, we will only otherwise process it: with your consent; for the establishment, exercise or defence of legal claims; for the protection of the rights of another natural or legal person; or for reasons of important public interest.

7.7 You have the right to object to our processing of your personal data on grounds relating to your particular situation, but only to the extent that the legal basis for the processing is that the processing is necessary for: the performance of a task carried out in the public interest or in the exercise of any official authority vested in us; or the purposes of the legitimate interests pursued by us or by a third party. If you make such an objection, we will cease to process the personal information unless we can demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms, or the processing is for the establishment, exercise or defence of legal claims.

7.8 You have the right to object to our processing of your personal data for direct marketing purposes (including profiling for direct marketing purposes). If you make such an objection, we will cease to process your personal data for this purpose.

7.9 You have the right to object to our processing of your personal data for scientific or historical research purposes or statistical purposes on grounds relating to your particular situation, unless the processing is necessary for the performance of a task carried out for reasons of public interest.

7.10 To the extent that the legal basis for our processing of your personal data is:

(a) consent; or
(b) that the processing is necessary for the performance of a contract to which you are party or in order to take steps at your request prior to entering into a contract, and such processing is carried out by automated means, you have the right to receive your personal data from us in a structured, commonly used and machine-readable format. However, this right does not apply where it would adversely affect the rights and freedoms of others.

7.11 If you consider that our processing of your personal information infringes data protection laws, you have a legal right to lodge a complaint with a supervisory authority responsible for data protection. You may do so in the EU member state of your habitual residence, your place of work or the place of the alleged infringement.

7.12 To the extent that the legal basis for our processing of your personal information is consent, you have the right to withdraw that consent at any time. Withdrawal will not affect the lawfulness of processing before the withdrawal.

7.13 You may exercise any of your rights in relation to your personal data by written notice to us. Our contact details are at the end.

8. Cookies

A cookie is a file containing an identifier (a string of letters and numbers) that is sent by a web server to a web browser and is stored by the browser. The identifier is then sent back to the server each time the browser requests a page from the server.

8.2 Cookies may be either “persistent” cookies or “session” cookies: a persistent cookie will be stored by a web browser and will remain valid until its set expiry date, unless deleted by the user before the expiry date; a session cookie, on the other hand, will expire at the end of the user session, when the web browser is closed.

8.3 Cookies do not typically contain any information that personally identifies a user, but personal information that we store about you may be linked to the information stored in and obtained from cookies.

8.4 Aqua-Rehab use Cookies to help the Company identify and track visitors, their usage of the website, and their website access preferences. Where applicable this website uses a cookie control system allowing the user on their first visit to the website to allow or disallow the use of Cookies on their computer or device. This complies with UK legislation which requires that explicit consent is given before reading files are left, or applied, on a user’s computer or device. We do not use Cookies to collect any information that identifies you personally.
8.5 If you accept the use of Cookies on this website, you consent to the processing of data about you by us and any third parties as identified above in accordance with this policy and our Privacy Policy. You have the right to withdraw your consent at any time by emailing the Data Controller at [email protected]
8.6 Cookies may be placed on your computer or device by third parties, which are outside of the control of Aqua-Rehab. You should refer to the Privacy and Cookie Policies of any social media and/or channel used to link to our Website.
8.7 If you are uncomfortable with the use of Cookies, you can disable Cookies on your device by changing the settings in the preferences or options menu in your browser. You can set your browser to reject or block Cookies or to tell you when a website tries to put a cookie on your device. You can also delete any Cookies that are already stored on your device. However, please be aware that if you do delete and block all Cookies from our website, parts of the site my not fully function.

9. Our Details

9.1 www.aqua-rehab.co.uk website is owned and operated by Aqua-Rehab.

9.2 Our registered address is at 59 King Edward Avenue, Aylesbury, HP21 7JE.

9.3 You can contact us:

• by post, to the postal address given above;
• using our website contact form;
• by telephone, on the contact number published on our website; or
• by email, using the email address published on our website.

10. Data Protection Officer

10.1 Our data protection officer is Julie Dixon. She can be contacted at the Aqua-Rehab business address above.

11. Important Information

11.1 We reserve the right to amend this Statement at any time to meet the requirements of the GDPR and our role as a data processor. Any significant changes will be mutually agreed.

11.2 If you have a complaint about the use of data by us, you can email us at [email protected]. Alternatively, you can formally report an issue of concern to the Information Commissioner’s Office, the UK body that governs Data Protection. See https://ico.org.uk

11.3 No failure or delay by us in exercising any of our rights in accordance with this Privacy Policy or our Terms of Use shall be deemed to be a waiver of that right, and no waiver of a breach of any provision shall be deemed to be a waiver of any subsequent breach of the same or any other provision.

11.4 If one or more of the provisions of this Privacy Policy or our Terms of Use is found to be unlawful, invalid or otherwise unenforceable, those provision(s) shall be deemed severed, and the remainder of these shall remain enforceable.

11.5 The terms of this Privacy Policy shall not confer rights on any third parties and accordingly the Contracts (Rights of Third Parties) Act shall not apply.

11.6 The terms of this Privacy Policy and all disputes, whether contractual or otherwise, arising out of or in connection with the policy are governed by and shall be construed in accordance with the laws of England and Wales and each party submits to the exclusive jurisdiction of the English courts.