2. The Data Protection Bill 2017
3. Purpose of data how we use this data
UltiVita Health Ltd acts as data controller of the data we collect from clients and is the data required to provide professional services to clients, communicate with clients and validate and verify the legitimacy of clients. UltiVita Health Ltd acts as data controller and processor regarding your data from third parties such as testing companies and other healthcare providers. UltiVita Health Ltd acts as data controller and processor regarding processing of credit cards and online payments.
We may use your personal data where there is an overriding public interest in using the information e.g., in order to safeguard an individual, or to prevent a serious crime. This may also be the case where there is a legal requirement such as a formal court order. In the case of the use of your data for marketing purposes, such as newsletters, your explicit consent would be required.
4. Disclosures - Sharing of data
We may disclose your personal information (including to trusted third parties) for the purposes for which is primarily held or for a related secondary purpose and in some cases, we may disclose information without your consent. Your personal and sensitive information may be disclosed to UltiVita Health Ltd employees, UltiVita Health Ltd representatives and service providers we use to deliver aspects of our service such as database or email software facilities.
Data is shared via member numbers with insurance providers for the purposes of verifying the legitimacy of insurance applicants.
Data is shared with our regulator the General Naturopathic Council for the purposes of registering practitioners on a public register, and confirming their status as a fully qualified, voluntarily regulated practitioner.
Data is shared internally with administrators for the purpose of verifying payments and refunds.
5. Legacy data
All data collected from clients and third parties regarding clients will remain in the possession of UltiVita Health for the duration specified by the guidance of our professional body Association of Naturopathic Practitioners.
6. Device specific data
The following information may be collected through your device and browser:
Your devices IP address (collected and stored in an anonymised format)
Your email address including first name and surname
Device screen size
Device type (unique identifiers) and browser information
Geographic location (country only)
Preferred language used to display the webpage
7. Digital Log data
Our servers automatically record information which is created using our software. Data includes:
Geographic location (country only)
Preferred language used to display information
Date and time when pages were accessed or created
We only use information that may identify you in accordance with GDPR. This requires us to process personal data only if there is a legitimate basis for doing so and that any processing must be fair and lawful.
Within the health sector, we also have to follow the common law duty of confidence, which means that where identifiable information about you has been given in confidence, it should be treated as confidential and only shared for the purpose of providing direct healthcare. We will protect your information, inform you of how your information will be used, and allow you to decide if and how your information can be shared.
We also ensure the information we hold is kept in secure locations, restrict access to information to authorised personnel only, protect personal and confidential information held on equipment such as laptops with passwords. We ensure external data processors that support us are legally and contractually bound to operate and prove security arrangements are in place where data that could or does identify a person are processed.
UltiVita Health Ltd is registered with the Information Commissioner’s Office (ICO) as a data controller and collects data for a variety of purposes. A copy of the registration is available through the ICO website (search by business name).
9. Your rights and opting out
Opt out mechanisms are in place on all UltiVita Health Ltd mailings and communications. Users can choose to opt out at any time by clicking the opt-out button at the bottom of mailings or emailing.
11. Verifying, updating and amending your personal information
If, at any time, a user wants to verify, update or amend their personal data they may write to:
UltiVita Health Ltd
Verification, updating or amendment of personal data takes place within 10 working days.
A “cookie” is a small text file that is placed on a user’s computer hard drive by a website. There are several types of cookie and the most common are often referred to as ‘session’ cookies. These are used to keep track of information needed by a user as they travel from page to page within a website. These cookies have a short lifetime and expire within a few minutes of the user leaving the site.
Other types of cookies can be used to track internet activity after the user has left a website. These are usually sponsored by organisations external to the website being visited and are generally known as ‘third party’ cookies. These usually have a long lifetime with several months being quite common. They are ‘harvested’ and ‘refreshed’ whenever the user visits a page where the same or a similar cookie is being used.
UltiVita Health Ltd uses benign, short lived ‘session’ cookies to tell whether a website user has logged in, where to find details that can be used to pre-fill parts of on-line forms and to personalise the user’s visit to the website.
UltiVita Health Ltd.’s cookies do not analyse visits to other website, or any searches undertaken whilst on the UltiVita Health Ltd website.
Internet browsers normally accept cookies by default; however, it is possible to set a browser to reject cookies. If this is done it is important not to exclude the benign and useful session cookies. Choose an option that rejects all third party and long-lived cookies.
To find out more about cookies, including how to see what cookies have been set and how to manage and delete them, visit www.allaboutcookies.org
To opt out of being tracked by Google Analytics across all websites visit http://tools.google.com/dlpage/gaoptout
13. Links to Third Party Websites
UltiVita Health Ltd is not responsible for the privacy policies of third-party websites. UltiVita Health Ltd advises users to read the privacy policies of other websites before registering any personal data.
UltiVita Health Ltd holds your personal data in accordance with the security provisions of the UK data protection legislation.
If you have any questions about security, please contact UltiVita Health Ltd via email (www.ultivitahealth.co.uk)
15. Request of personal information
Clients have the right to ask the UltiVita Health Ltd in writing, for a copy of all the personal data held about them and shall receive a response within 20 working days from point of receipt of request.
If you have a complaint about the use of your data, then please contact us via email email@example.com. If your complaint is not resolved to your satisfaction and you wish to make a formal complaint to the Information Commissioner’s Office (ICO), you can contact them on 01625 545 745, 0303 123 1113.