privacy

Introduction

1.1    We are committed to safeguarding the personal information of our service users and website visitors, and to making our platforms safe and enjoyable environments for our audiences.

1.2    This policy applies where we are acting as a data controller with respect to the personal data of our service users and website visitors; 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    Our website incorporates privacy controls which affect how we will process your personal data. When you share your data with us, you can specify whether you would like to receive digital marketing communications from us. If you want to edit your details at any point you can access the privacy controls for our digital communications via any emails from ‘Therapy Network Ltd’ by emailing us at hello@therapynetwork.org.uk to update your preferences.

1.5    In addition to our digital marketing communications, we sometimes send direct marketing by post, the legal basis for which is consent or legitimate interest. If you want to edit your details at any point you can email us at hello@therapynetwork.org.uk to update your preferences.

1.6    In this policy, “we”, “us” and “our” refer to Therapy Network Ltd. For more information about us, see Section 13.
Credit

2.1    This document was created using a template from SEQ Legal (https://seqlegal.com).

How we use your personal data
3.1    In this Section 3 we have set out:
(a)    the general categories of personal data that we may process;
(b)    the purposes for which we may process personal data; and
(c)    the legal bases of the processing.

3.2    We may process data about your use of our website and services (“usage data”). The usage data may include your IP address, geographical location, browser type and version, operating system, referral source, length of visit, page views and website navigation paths, as well as information about the timing, frequency and pattern of your service use. We use Google Analytics to collect this data. This usage data may be processed for the purposes of analysing the use of the website and services. This data is only for internal use and will never be shared with third parties. The legal basis for this processing is our legitimate interests, namely monitoring and improving our website and services.

3.3    We may process your personal data that are provided in the course of the use of our services (“service data”). The service data may include your name, email address, telephone number. The source of the service data is you. 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 and in some cases the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract.

3.4    We may process information contained in any enquiry you submit to us regarding goods and/or services (“enquiry data”). The enquiry data may be processed for the purposes of offering, marketing and selling relevant goods and/or services to you. The legal basis for this processing is consent, or legitimate interest, namely the proper administration of our website and business and in some cases the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract.

3.5    We may process information relating to transactions, including purchases of goods and services, that you enter into with us (“transaction data”). The transaction data may include your contact details and the transaction details. The transaction data may be processed for the purpose of supplying the purchased goods and services and keeping proper records of those transactions. The legal basis for this processing is the performance of a contract between you and us.

3.6    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 (including job alerts) and/or newsletters. The legal basis for this processing is consent or the performance of a contract between you and us.

3.7    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.

3.8    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.

3.9    We may process any of your personal data identified in this policy where necessary for the purposes of obtaining or maintaining insurance coverage, managing risks, or obtaining professional advice. The legal basis for this processing is our legitimate interests, namely the proper protection of our business against risks.

3.11  In addition to the specific purposes for which we may process your personal data set out in this Section 3, 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.

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

Providing your personal data to others
4.1    We may disclose your personal data to our insurers and/or professional advisers insofar as reasonably necessary for the purposes of obtaining or maintaining insurance coverage, managing risks, obtaining professional advice, or the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure.

4.4    In addition to the specific disclosures of personal data set out in this Section 4, 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.

International transfers of your personal data

5.1    In this Section 5, we provide information about the circumstances in which your personal data may be transferred to countries outside the European Economic Area (EEA).

5.2    The hosting facilities for our website are situated in the UK and will not be available around the world.

Retaining and deleting personal data
6.1    This Section 6 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.

6.2    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.

6.3    We will retain your personal data as follows:
(a)    All data relating to contracted speech therapy services services, including contact details, correspondence records and all transaction details will be retained for a minimum of 1 years where such processing is necessary for compliance with a legal obligation to which we are subject.

6.4    In some cases it is not possible for us to specify in advance the periods for which your personal data will be retained. In such cases, we will determine the period of retention based on the following criteria:
(a)    We will hold your personal information on our systems for as long as is necessary for the relevant activity, or as long as is set out in any relevant contract you hold with us.
(b)    If you have not received or requested correspondence from us in the last 1 years then your information may be classed as dormant and may be deleted (excluding any information relating to transactions, as specified in Section 6.3 (a)).
(c)    We will hold your personal information on our newsletter or email alert list until you manually unsubscribe or request for your details to be removed.

6.5    Notwithstanding the other provisions of this Section 6, 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. Retaining and deleting personal data

6.1    This Section 6 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.

6.2    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.

6.3    We will retain your personal data as follows:
(a)    All data relating to contract inquiries job opportunities, including contact details, correspondence records and all transaction details will be retained for a minimum of 1 years where such processing is necessary for compliance with a legal obligation to which we are subject.

6.4    In some cases it is not possible for us to specify in advance the periods for which your personal data will be retained. In such cases, we will determine the period of retention based on the following criteria:
(a)    We will hold your personal information on our systems for as long as is necessary for the relevant activity, or as long as is set out in any relevant contract you hold with us.
(b)    If you have not received or requested correspondence from us in the last 1 years then your information may be classed as dormant and may be deleted (excluding any information relating to transactions, as specified in Section 6.3 (a)).
(c)    We will hold your personal information on our newsletter or email alert list until you manually unsubscribe or request for your details to be removed.

6.5    Notwithstanding the other provisions of this Section 6, 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.

7. Amendments

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

7.2    You should check this page occasionally to ensure you are happy with any changes to this policy.

7.3    We may notify you of changes to this policy by email if you have consented to receive our newsletter or email alerts, or have undertaken a contract with us for the completion of services.

8. Your rights

8.1    You may instruct us to provide you with any personal information we hold about you; provision of such information will be subject to:
(a)    the payment of a fee (currently fixed at GBP 15.00); and

(b)    the supply of appropriate evidence of your identity (for this purpose, we will usually accept a photocopy of your passport certified by a solicitor or bank plus an original copy of a utility bill showing your current address).

8.2    We may withhold personal information that you request to the extent permitted by law.

8.3    You may instruct us at any time not to process your personal information for marketing purposes.

9.1 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.

9.2 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.

9.3 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.

10. Cookies that we use

10.1 We use cookies for the following purposes:

10.1  We use cookies for the following purposes:
(a)    authentication – we use cookies to identify you when you visit our website and as you navigate our website (cookies used for this purpose are: PHPSESSID: this is used to  identify the use and their session, but is not linked to the user’s personal details)

(b)    personalisation – we use cookies and local storage to hold information about your preferences and to personalise the website for you (cookies used for this purpose track: recently viewed properties, saved properties, and viewing request details for form submission). We also use cookies to determine whether you have seen the newsletter subscription drawer (cookies used for this purpose are: POPUP_SEEN)

(c)    security – we use cookies as an element of the security measures to protect our website and services generally (cookies used for this purpose are: wfvt_NUMBER to protect the website from malicious actions)

(d)    advertising – we use cookies to help us to display advertisements that will be relevant to you (cookies used for this purpose are: fr from Facebook)

(e)    analysis – we use cookies to help us to analyse the use and performance of our website and services (cookies used for this purpose are linked to Google Analytics: _ga, _gat_UA-4564936-3)

(f)     cookie consent – we use cookies to store your preferences in relation to the use of cookies more generally (cookies used for this purpose are: COOKIE_CONSENT)

Cookies used by our service providers

11.1  Our service providers use cookies and those cookies may be stored on your computer when you visit our website.

11.2  We use Google Analytics to analyse the use of our website. Google Analytics gathers information about website use by means of cookies. The information gathered relating to our website is used to create reports about the use of our website. Google’s privacy policy is available at: https://www.google.com/policies/privacy/.

11.3  We use Facebook Ads Manager to serve targeted adverts to relevant audiences. This service uses cookies to help us display advertisements that will be relevant to you, and to track the conversion rate of these advertisements.

11.3 We use Google AdWords, including the remarketing service, to serve targeted adverts to relevant audiences. This could be in the form of an advertisement on the Google search results page, or a site in the Google Display Network. This service uses cookies to display advertisements that will be relevant to you, and to track the conversion rate of these advertisements.

11. Cookies used by our service providers

11.1 Our service providers use cookies and those cookies may be stored on your computer when you visit our website.
11.2 We use Google Analytics to analyse the use of our website. Google Analytics gathers information about website use by means of cookies. The information gathered relating to our website is used to create reports about the use of our website. Google's privacy policy is available at: https://www.google.com/policies/privacy/.[ The relevant cookies are: [identify cookies].]

11.3 [We publish Google AdSense interest-based advertisements on our website. These are tailored by Google to reflect your interests. To determine your interests, Google will track your behaviour on our website and on other websites across the web using cookies.] OR [We publish Google AdSense advertisements on our website. To determine your interests, Google will track your behaviour on our website and on other websites across the web using cookies. This behaviour tracking allows Google to tailor the advertisements that you see on other websites to reflect your interests (but we do not publish interest-based advertisements on our website).] You can view, delete or add interest categories associated with your browser by visiting: https://adssettings.google.com. You can also opt out of the AdSense partner network cookie using those settings or using the Network Advertising Initiative's multi-cookie opt-out mechanism at: http://optout.networkadvertising.org. However, these opt-out mechanisms themselves use cookies, and if you clear the cookies from your browser your opt-out will not be maintained. To ensure that an opt-out is maintained in respect of a particular browser, you may wish to consider using the Google browser plug-ins available at: https://support.google.com/ads/answer/7395996.

12. Managing cookies

12.1 Most browsers allow you to refuse to accept cookies and to delete cookies. The methods for doing so vary from browser to browser, and from version to version. You can however obtain up-to-date information about blocking and deleting cookies via these links:
(a) https://support.google.com/chrome/answer/95647?hl=en (Chrome);
(b) https://support.mozilla.org/en-US/kb/enable-and-disable-cookies-website-preferences (Firefox);
(c) http://www.opera.com/help/tutorials/security/cookies/ (Opera);
(d) https://support.microsoft.com/en-gb/help/17442/windows-internet-explorer-delete-manage-cookies (Internet Explorer);
(e) https://support.apple.com/kb/PH21411 (Safari); and
(f) https://privacy.microsoft.com/en-us/windows-10-microsoft-edge-and-privacy (Edge).

12.2 Blocking all cookies will have a negative impact upon the usability of many websites.

12.3 If you block cookies, you will not be able to use all the features on our website.

13. Our details
13.1 This website is owned and operated by Therapy Network Ltd.

13.2 We are registered in [England and Wales] under registration number [07837512], and our registered office is at 152 City Road London, EC1V 2NX.

13.3 Our principal place of business is at 152 City Road, London, EC1V 2NX.
13.4 You can contact us:
(a) by post, to the postal address given above;
(b) using our website contact form: https:// speechandlanguagetherapy.org.uk/contact/;
(c) by telephone, 0203 488 1027
(d) by email: helloo@therapynetwork.org.uk

14. Data protection officer
14.1 Our data protection officer's contact details are: Mr Matthew Lawrence, Clinical Director.


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