Privacy policy

Introduction

This privacy policy sets out how Reframe uses and protects your personal data.

Reframe gathers and processes your personal data in accordance with this privacy notice and in compliance with relevant data protection regulations and laws. This notice provides you with the necessary information regarding your rights and obligations, and explains how, why and when we collect and process your personal data.

1. Important information and who we are

Reframe is a trading style of Harley Street Concierge Ltd, a limited company registered in England and Wales under company number 08331310. Registered office is The Square, Basing View, Basingstoke, Hampshire, RG21 4EB. We act as a data controller and a data processor and Reframe is registered on the Information Commissioner’s Office Register of Data Controllers under registration number ZA033036.

Privacy policy

This privacy policy gives you information about how Reframe collects and uses your personal data through your use of this website, including any data you may provide when you register with us or purchase a product or service.

This website is not intended for children, and we do not knowingly collect data relating to children through it. Reframe will only process the personal data of children if necessary for the provision of a product or service in compliance with applicable data protection laws.

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.

Controller

Harley Street Concierge Limited is the controller and responsible for your personal data (collectively referred to as “Reframe”, "we", "us" or "our" in this privacy policy).

We have appointed a data protection officer (DPO) 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 DPO using the details set out below.

You may also contact the Information Commissioner’s Office by writing to Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF, calling 0303 123 1113 or visiting the ICO website (www.ico.org.uk). We would, however, appreciate the opportunity to try to address your concerns before you approach the ICO so please contact us in the first instance.

2. The types of personal data we collect about you

Personal data means any information about an individual from which that person can be identified.

We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:

• Identity Data includes first name, last name, any previous names, username or similar identifier, NHS Number, marital status, title, date of birth and gender.
• Contact Data includes email address and telephone numbers.
• Employment Data includes your employers name, employee ID, relationship to main policy holder and relationship to the nominated representative.
• Medical Data includes medical health records whether provided by the NHS or another third party.
• 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 us.
• 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, device ID and other technology on the devices you use to access this website.
• Profile Data includes your username and password, purchases or orders made by you, your interests, preferences, feedback and survey responses.
• Usage Data includes information about how you interact with and use our website, products and services.
• Marketing and Communications Data includes 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 which is not personal data as it does not directly (or indirectly) reveal your identity. For example, we may aggregate individuals' Usage Data to calculate the percentage of users accessing a specific website feature in order to analyse general trends in how users are interacting with our website to help improve the website and our service offering.

Owing to the products and services we offer, Reframe sometimes needs to request sensitive personal data from you such as your health data and medical history. Where we collect sensitive personal data, we will only request the data required for the specified purpose and always ask for your explicit consent through a signature. You can modify or remove consent at any time, which we will act on immediately, unless there is a legitimate interest or legal reason for not doing so.

3. How is your personal data collected?

We use different methods to collect data from and about you including through:

• Your interactions with us. You may give us your personal data by filling in online 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; or
• give us feedback or contact us.
• 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, server logs and other similar technologies. We may also receive Technical Data about you if you visit other websites employing our cookies. Please see further details below about our use of cookies in section 4 (how we use your personal data).
• Third parties or publicly available sources. We will receive personal data about you from various third parties as set out below:
  • National Health Service
  • Your employer
  • Your insurance provider
  • Your private health care provider
• Technical Data is collected from the following parties:
• analytics providers;
• advertising networks; and
• search information providers.

4. How we use your personal data

Legal basis

The law requires us to have a legal basis for collecting and using your personal data. We rely on one or more of the following legal bases:

• Performance of a contract with you: Where we need to perform the contract we are about to enter into or have entered into with you.
• Legitimate interests: We may use your personal data where it is necessary to conduct our business and pursue our legitimate interests, for example to prevent fraud and enable us to give you the best and most secure customer experience. We make sure we consider and balance any potential impact on you and your rights (both positive and negative) before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law).
• Legal obligation: We may use your personal data where it is necessary for compliance with a legal obligation that we are subject to. We will identify the relevant legal obligation when we rely on this legal basis.
• Consent: We rely on consent only where we have obtained your active agreement to use your personal data for a specified purpose, for example where you complete a consent form releasing your medical data.

Purposes for which we will use your personal data

Reframe takes your privacy very seriously and will never disclose, share or sell your personal data without your consent, unless required to do so by law. We only retain your data for as long as is necessary and for the purposes specified in this notice.

We collect, process and store personal data in the performance of a contract or to provide a service requested by you, and as part of our legal obligation for business accounting and tax purposes.

Reframe does not provide clinical diagnosis or treatment to individuals, so does not obtain consent for treatment. Such consent is obtained by healthcare professionals at the time of providing treatment.

We have set out below, in a table format, a description of all the ways we plan to use the various categories of 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.

Direct marketing

During the registration process on our website when your personal data is collected, you will be asked to indicate your preferences for receiving direct marketing communications from Reframe.

We may also analyse your Identity, Contact, Technical, Usage and Profile Data to form a view which products, services and offers may be of interest to you so that we can then send you relevant marketing communications.

Third-party

We will share your name, contact details and relevant medical records with relevant Clinicians and Medical Service Providers to enable the performance of the contract you enter with us for a specific service. This data will only be shared when you have given us your consent. We will send you relevant documentation prior to us commencing our services that will allow you to provide your consent.

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We 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 our instructions.

Opting out of marketing

You can ask to stop sending you marketing communications at any time by following the opt-out links within any marketing communication sent to you.

If you opt out of receiving marketing communications, you will still receive service-related communications that are essential for administrative or customer service purposes.

Cookies and similar technologies and how we use them

Cookies

A cookie is a small file placed on your computer’s hard drive. It enables our website to identify your computer as you view different pages on our website. Cookies allow websites and applications to store your preferences in order to present content, options or functions that are specific to you. They also enable us to track website usage and pages visit.

A cookie is a small file placed on your computer’s hard drive. It enables our website to identify your computer as you view different pages on our website. Cookies allow websites and applications to store your preferences to present content, options or functions that are specific to you. They also enable us to track website usage and pages visit.

We may use cookies to:

*analyse our web traffic using Google’s analytics package so that we can use aggregated usage data to help improve the website structure, design, content and functions

*identify whether you are signed into our website

*test content on our website, for example, half our users might see one piece of content and the other half see a different piece of content

*store information about your preferences so the website can then present you with information you will find more relevant and interesting

*recognise when you return to our website so we may show you relevant content or provide functionality you used previously

Cookies do not provide us with access to your computer or any information about you, other than that which you choose to share with us.

You can use your web browser’s cookie settings to determine how our website uses cookies. If you do not want our website to store cookies on your computer or device, you should set your web browser to refuse cookies. Please note that doing this may affect how our website functions and some pages and services may become unavailable to you. Unless you have changed your browser to refuse cookies, our website will issue cookies when you visit it.

We use Hotjar to understand how you use our website through their services that include heatmaps, page usage recordings and feedback polls and surveys. The Hotjar privacy policy explains more about how they collect data and keep it safe.

Similar Technologies

Reframe may use tracking pixels and link tracking on email communications. Tracking pixels and link tracking are small pieces of code used to track behaviour when a user clicks within an email.

We use tracking pixels and link tracking in order to understand engagement with our services and to improve and customise the services we provide to you.

5. International transfers

We do not transfer your personal data outside the UK.

6. Data security

We 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, we 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.

We 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 we are legally required to do so.

Reframe takes your privacy seriously and we take every reasonable measure and precaution to protect and secure your personal data. We work hard to protect you and your information from unauthorised access, alteration, disclosure or destruction. Our security measures include:

*data encryption, anonymisation and pseudonymisation

*data access restrictions

*system access controls and multifactor authentication

*data security and protection risk assessment

*internal and external audits

*privacy by design for platform development

*staff training on data protection

Payment services

Where relevant, we use both HubSpot Forms and Stripe to take payment for a service that you purchase directly from Reframe These parties act in the capacity of processors on our behalf. Reframe do not provide any personal data to these processors, however they will ask you to provide specific personal data including contact and payment details and provide specific consent required to process a payment.

Where required by these processors, whenever we transfer your personal data out of the UK, we ensure sufficient safeguards are implemented to protect such data.

7. Data retention

How long will you use my personal data for?

We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, 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.

To determine the appropriate retention period for personal data, we 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 we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.

By law we have to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for seven years after they cease being customers for tax purposes.

In some circumstances you can ask us to delete your data.

In some circumstances we will anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.

8. Your legal rights

You have a number of rights under data protection laws in relation to your personal data.

You have the right to:

• Request access to your personal data (commonly known as a "subject access request"). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
• Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
• Request erasure of your personal data in certain circumstances. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
• Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) as the legal basis for that particular use of your data (including carrying out profiling based on our legitimate interests). In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your right to object.
• You also have the absolute right to object any time to the processing of your personal data for direct marketing purposes.
• Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
• Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.
• Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in one of the following scenarios:
• If you want us to establish the data's accuracy;
• Where our use of the data is unlawful but you do not want us to erase it;
• Where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or
• You have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.

If you wish to exercise any of the rights set out above, please contact.

What we may need from you

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.

9. Contact details

If you have any questions about this privacy policy or about the use of your personal data or you want to exercise your privacy rights, please contact our DPO in the following ways:

• Email address: support@reframe.co.uk
• Postal address: Data Protection Officer, Reframe, the Square, Basing View, Basingstoke, Hampshire, RG21 4EB
• Telephone: 0207 965 0309