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GDPR & Privacy Policy

BACKGROUND:

REJENÉ CLINIC understands that your privacy is important to you and that you care about how your personal data is used. We respect and value the privacy of all of our clients and will only collect and use personal data in ways that are consistent with our obligations and your rights under the law. This Privacy Notice outlines Rejené Clinic’s (“we”, “our” or “the company”) practices with respect to information collected from users who access our website at www.rejeneclinic.com (“site”), or otherwise share personal information with us (collectively: “users”).

 

1. Information About Us

REJENÉ MEDICAL AESTHETICS LTD Is registered in England and Wales under company number 12149006

Data Protection Officer: Mohamed Hani

Email address: drhani@rejeneclinic.com

We are  regulated by the General Medical Council in the UK, and the Information Commissioners Office  (ICO).

 

2. What Does This Notice Cover?

It explains how we use your personal data: how it is collected, how it is held, stored and how it is processed. It also explains your rights under the law relating to your personal data.

 

3. What Is Personal Data?

Personal data is defined by the General Data Protection Regulation (EU Regulation 2016/679) (the “GDPR”) and the Data Protection Act 2018 (collectively, “the Data Protection Legislation”) as ‘any information relating to an identifiable person who can be directly or indirectly identified in particular by reference to an identifier’.

Personal data is, in simpler terms, any information about you that enables you to be identified. Personal data covers obvious information such as your name and contact details, but it also covers less obvious information such as identification numbers, electronic location data, and other online identifiers.

The personal data that we use is set out in Part 5, below.

 

4. What Are My Rights?

Under the Data Protection Legislation, you have the following rights, which we will always work to uphold:

a) The right to be informed about our collection and use of your personal data. This Privacy Notice should tell you everything you need to know, but you can always contact us to find out more or to ask any questions using the details in Part 11.

b) The right to access the personal data we hold about you. Part 10 will tell you how to do this.

c) The right to have your personal data rectified if any of your personal data held by us is inaccurate or incomplete. Please contact us using the details in Part 11 to find out more.

d) The right to be forgotten, i.e. the right to ask us to delete or otherwise dispose of any of your personal data that we hold. Please contact us using the details in Part 11 to find out more. The right to restrict (i.e. prevent) the processing of your personal data..

e) The right to object to us using your personal data for a particular purpose or purposes.

f) The right to data portability. This means that, if you have provided personal data to us directly, we are using it with your consent or for the performance of a contract, and that data is processed using automated means, you can ask us for a copy of that personal data to re-use with another service or business in many cases.

g) Rights relating to automated decision-making and profiling. We do not use your personal data in this way

For more information about our use of your personal data or exercising your rights as outlined above, please contact us using the details provided in Part 11.

It is important that your personal data is kept accurate and up-to-date. If any of the personal data we hold about you changes, please keep us informed as long as we have that data.

Further information about your rights can also be obtained from the Information Commissioner’s Office or your local Citizens Advice Bureau.

If you have any cause for complaint about our use of your personal data, you have the right to lodge a complaint with the Information Commissioner’s Office. We would welcome the opportunity to resolve your concerns ourselves, however, so please contact us first, using the details in Part 11.

 

5. What Personal Data Do You Collect and How?

Depending upon your use of our Site, we may collect and hold some or all of the personal and non-personal data set out in the table below, using the methods also set out in the table. 

 

Data Collected

How We Collect the Data

Identity Information including name, title, date of birth, gender

by asking you directly and/ or collected through our website contact system

Contact information including address, email address, telephone number(s)

By asking you directly and/or collected through our website contact system

Payment information, please note that we accept credit cards payments only

Collected at point of payment by credit card. We never store any credit card details at all

Profile information including preferences, interests, purchase history, medical information including photography (before and after treatment photos), history, treatment(s) done and results of treatment(s).

Collected by asking you directly and from your consent and treatment record forms.

 

Cookies 

Please carefully read the following information on cookies, your continued use of our website means that you agree with our use of cookies.

By visiting Rejene Clinic website with your browser set to accept cookies, we reasonably assume that you want to use our website and the functionality offered through our website; and that you consent to our use of cookies, as described in the information below which explains how we use cookies and also provides you with the information required to modify your browser settings to control your browsers use of cookies.

What are cookies?

Cookies are very small text files that are created by a website through a browser on your device. They are used to help you navigate a website, identify preferences and perform specific functions. Cookies are used to enhance the usability of the site and to make navigating a website easier and more intuitive, so disabling cookies may prevent you from using certain websites, or from using certain functions within a website.
When you use a browser to load a website that uses cookies, if the browser settings enable the use of cookies, it will allow the website to send a small text file (a cookie), to your computer’s hard drive. When you visit subsequent pages on the website it may use the information inside the cookie to provide certain functionality. When you re-visit the website, it may again request that cookie to further assist functionality within that website e.g. automatically remember the product you last looked at.

How we use Cookies?

We use cookies on this website for the following purposes:

- Anonymously tracking page visits, hits, search terms, visitor locations etc. for statistical purposes, which help us to improve our services. We use Google Analytics to provide us with information about use of the website, examples of this statistical information would be how many visitors from UK we have had, how many visitors used Internet Explorer as a browser, how many pages were visited today, what words visitors search for to find our website etc.

- Improving security on the website to prevent fraudulent activity and protect your personal information.

How to manage cookies on your browser?

If you want to control the use of cookies via your browser then we recommend that you use the help menu within the browser of your choice. Obviously, there are many browsers available on a variety of devices, so it is difficult to provide you with precise instructions, but if you seek out the help menu and search for ‘cookie’ you should find the appropriate guidance.

 

6.  How Do You Use My Personal Data?

Under the Data Protection Legislation, we must always have a lawful basis for using personal data. The following table describes how we may use your personal data, and our lawful bases for doing so:

What We Do

What Data We Use

Our Lawful Basis

Administering our business.

Contact and payment details 

Contract and Consent 

Supplying our products and services to you.

Personal information provided by you to us

Contract for provision of services and consent 

Managing payments for our products and services

Credit card details at the time of your payment only

Contract for provision of services and consent 

Personalising and tailoring our products and services for you.

Contact details provided by you to us

Consent

Communicating with you.

Contact details provided by you to us

Contract for provision of services and Consent

Supplying you with information by email and post that you have opted-in-to (you may opt-out at any time by contacting us)

Contact details provided by you to us

Contract for provision of services and Consent

The retention of medical data, records and information 

This includes photography, notes, sketches, medical and  personal information you provided to us

You have consented to this we also have a Legitimate interest - as the retention of medical and personal data is necessary for health and insurance purposes

With your permission and/or where permitted by law, we may also use your personal data for marketing purposes, which may include contacting you by email and telephone and text message and post with information, news, and offers on our products services. You will not be sent any unlawful marketing or spam. We will always work to fully protect your rights and comply with our obligations under the Data Protection Legislation and the Privacy and Electronic Communications (EC Directive) Regulations 2003, and you will always have the opportunity to opt-out. We will always obtain your express opt-in consent before sharing your personal data with third parties for marketing purposes and you will be able to opt-out at any time.

We will only use your personal data for the purpose(s) for which it was originally collected unless we reasonably believe that another purpose is compatible with that or those original purpose(s) and need to use your personal data for that purpose. If we do use your personal data in this way and you wish us to explain how the new purpose is compatible with the original, please contact us using the details in Part 11.

If we need to use your personal data for a purpose that is unrelated to, or incompatible with, the purpose(s) for which it was originally collected, we will inform you and explain the legal basis which allows us to do so.

In some circumstances, where permitted or required by law, we may process your personal data without your knowledge or consent. This will only be done within the bounds of the Data Protection Legislation and your legal rights.

 

7. How Long Will You Keep My Personal Data?

We will not keep your personal data for any longer than is necessary in light of the reason(s) for which it was first collected. Our indemnity insurance provider requests us to keep patient’s medical records files (including medical questionnaire forms, consent forms, treatment records, your related photos and follow up notes for ten years period). Your personal data will therefore be kept for the following periods (or, where there is no fixed period, the following factors will be used to determine how long it is kept):

Type of Data

How Long We Keep It

Identity Information including name, title, date of birth, gender.

10 years after the date of your last contact with us.

Contact information including. address, email address, telephone number(s)

10 years after the date of your last contact with us

Profile information including, photographs, medical information, preferences and interests, purchase history

10 years from the date of your treatment.

Consent forms, treatments records and photos related to your treatment.

10 years from the date of your treatment.

 

8. How and Where Do You Store or Transfer My Personal Data?

We will only store or transfer your personal data or store or transfer some of your personal data within the UK. This means that it will be fully protected under the Data Protection Legislation.

We will normally only store or transfer your personal data or store or transfer some of your personal data within the European Economic Area (the “EEA”). The EEA consists of all EU member states, plus Norway, Iceland, and Liechtenstein. This means that your personal data will be fully protected under the Data Protection Legislation, GDPR, and/or to equivalent standards by law.

We may store or transfer some or all of your personal data in countries that are not part of the European Economic Area (the “EEA” consists of all EU member states, plus Norway, Iceland, and Liechtenstein). These are known as “third countries” and may not have data protection laws that are as strong as those in the UK and/or the EEA. This means that we will take additional steps in order to ensure that your personal data is treated just as safely and securely as it would be within the UK and under the Data Protection Legislation as follows:

Where we transfer your data to a third party based in the US, the data may be protected if they are part of the EU-US Privacy Shield. This requires that third party to provide data protection to standards similar levels of data protection to those in Europe. More information is available from the European Commission.

The security of your personal data is essential to us and to protect your data, we take a number of important measures, including the following:

  • limiting access to your personal data to those employees, agents, contractors, and other third parties with a legitimate need to know and ensuring that they are subject to duties of confidentiality;
  • procedures for dealing with data breaches (the accidental or unlawful destruction, loss, alteration, unauthorised disclosure of, or access to, your personal data) including notifying you and/or the Information Commissioner’s Office where we are legally required to do so.

Your records (encryption and/or coding are used when and where applicable) are stored: 

  • on paper, in locked filing cabinets, and the offices/clinics are always locked and alarmed out of working hours. 
  • electronically using storage devices, these devices are pin-coded, password-protected and backed up regularly, and the offices/clinics are always locked and alarmed out of working hours. 
  • on our office computers and devices. These are password-protected, backed up regularly, and the offices are always locked and alarmed out of working hours. 

9. Do You Share My Personal Data?

We will not share any of your personal data with any third parties for any purposes, subject to the following exception:

  • ·If we sell, transfer, or merge parts of our business or assets, your personal data may be transferred to a third party. Any new owner of our business may continue to use your personal data in the same way(s) that we have used it, as specified in this Privacy Policy.
  • In some limited circumstances, we may be legally required to share certain personal data, which might include yours, if we are involved in legal proceedings or complying with legal obligations, a court order, or the instructions of a government authority.
  • If any of your personal data is shared with a third party, as described above, we will take steps to ensure that your personal data is handled safely, securely, and in accordance with your rights, our obligations, and the third party’s obligations under the law, as described above in Part 8.
  • If any personal data is transferred outside of the EEA, we will take suitable steps in order to ensure that your personal data is treated just as safely and securely as it would be within the UK and under the Data Protection Legislation, as explained above in Part 8.

 

10. How Can I Access My Personal Data?

If you want to know what personal data we have about you, you can ask us for details of that personal data and for a copy of it (where any such personal data is held). This is known as a “subject access request”.

All subject access requests should be made in writing and sent to the email shown in Part 11. 

There is not normally any charge for a subject access request. If your request is ‘manifestly unfounded or excessive’ (for example, if you make repetitive requests) a fee may be charged to cover our administrative costs in responding.

We will respond to your subject access request within less than 3 weeks and, in any case, not more than one month of receiving it. Normally, we aim to provide a complete response, including a copy of your personal data within that time. In some cases, however, particularly if your request is more complex, more time may be required up to a maximum of three months from the date we receive your request. You will be kept fully informed of our progress.

 

11. How Do I Contact You?

To contact us about anything to do with your personal data and data protection, including to make a subject access request, please use the following details for the attention of:                    

Dr Mohamed Hani:

Email address: drhani@rejeneclinic.com

 

12. Changes to this Privacy Notice

We may change this Privacy Notice from time to time. This may be necessary, for example, if the law changes, or if we change our business in a way that affects personal data protection. Any changes will be made available on our website. This Privacy Notice was last updated on 30/01/2020.

For further information about data protection issues:

Information Commissioner’s Office (ICO)
The Information Commissioner’s Office
Wycliffe House
Cheshire
SK9 5AF

Helpline: 08456 30 60 60
Website: www.ico.gov.uk

 

Related Information:

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