Privacy notice

This privacy notice describes how we will collect, use, share and otherwise process your personal data in connection with your use of this website and our services, including any data you may provide when you purchase services from us. Please read the following carefully to understand our practices regarding your personal data and how we will treat it.

While our services are for the benefit of children, tis not intended or designed for use by children.

• Important information and who we are

Kidswell Health Limited is the controller and is responsible for your personal data (Kidswell, we, us or our in this notice). If you have any questions about this privacy notice, please contact us using the information set out in the contact details section.

• The types of personal data we collect about you

Personal data means any information that can be used to identify directly or indirectly a specific individual.

We may collect, use, store and transfer different kinds of personal data about you. What information we collect will depend on which of our services you use. The information we may typically collect is as follows:

• – Identity Data includes first name, last name, any previous names, username or similar identifier, marital status, title, date of birth and gender.
• – Contact Data includes billing address, home address, email address and telephone numbers.
• – Financial Data includes bank account and payment card details, insurance policy details where applicable.
• – Transaction Data includes details about payments to and from you and other details of products and services you have purchased from us.
• – Profile Data includes your username and password for any account you have set up with us via our electronic health record system (to manage your appointments, access test results etc.) , purchases or orders made by you, your interests, preferences including marketing and communication preferences, feedback and survey responses.
• – Health Data includes any information you provide to us about your or your child’s physical and mental health and associated conditions, challenges or difficulties, including the information provided by you in the New Patient Form or any other Patient Questionnaires and including details about you and your child’s background and medical history, symptoms, height, weight, vaccination information, allergies, test results, details of any medication taken, your GP details, patient feedback and treatment outcome information you provide

For website users (including customers that use our website):

• – 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, including cookies.
• – Usage Data includes information about how you interact with and use our website and services.
• – Marketing and Communications Data includes your preferences in receiving marketing from us and any third parties and your communication preferences.

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.

• How is your personal data collected?

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

• – 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:
  • – purchase our services, including our membership options, or register your interest for our services;
  • – complete our New Patient Form in order to receive our services, prior to your first appointment with us;
  • – complete any of our Patient Questionnaires in order to provide relevant information to your clinician or healthcare professional;
  • – take one of our online consultations or register to receive communications;
  • – attend any of our in-person or remote events;
  • – If you do, we may keep a record of that correspondence;
  • – subscribe to our service or publications, including our blog or email updates;
  • – request marketing to be sent to you;
  • – enter a competition, promotion or survey; 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 and other similar technologies. We may also receive Technical Data about you if you visit other websites employing our cookies. Please see our cookie policy https://kidswellhealth.com/cookies-policy

• – We will receive personal data about you from various third parties and public sources as set out below:

• – Technical Data is collected from the following types of company:

–  analytics providers;

–  advertising networks; and

–  search information providers.

• Contact, Financial and Transaction Data is collected from providers of technical, payment and delivery services.

• Healthcare professionals and other individuals contracted to deliver services on behalf of Kidswell.

• We may receive personal data about you, including Health Data, from these third parties which we need to provide the services to you.

• Organisations you have requested that we receive personal data from, such as your local authority or your child’s school.

• Insurance providers where you have commenced a claim and your child requires treatment with us. This will normally be in the form of a referral and may consist of basic personal and contact details as well as the type of treatment required.

• 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 if you are not an existing customer and subscribe to an email newsletter.

There are special rules about how we can use Health Data. For Health Data, in addition to the lawful bases outlined above, we must also comply with an Article 9 UK GDPR condition. In the table below we have set out the conditions that we rely upon when processing Health Data.

Purposes for which we will use your personal data

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, the categories of personal data we may typically use for each processing activity, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

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 Kidswell via email, SMS, WhatsApp, telephone or post.

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

Third-party marketing

We will get your express consent before we share your personal data with any third party for their own direct marketing purposes.

Opting out of marketing

If you opt out of receiving marketing communications, you will still receive service-related communications that are essential for administrative or customer service purposes for example relating to order confirmations, updates to our Terms and Conditions, or checking that your contact details are correct.

Cookies

For more information about the cookies we use and how to change your cookie preferences, please see https://kidswellhealth.com/cookies-policy.

• Disclosures of your personal data

We may share your personal data where necessary with the parties set out below for the purposes set out in the table Purposes for which we will use your personal data above.

• – including our service providers:
  • – that provide us with marketing, customer service, IT, healthcare diagnostics, e-prescription services, telehealth services, our electronic health record system and other administrative or technical services including for communications and video calling;
  • – that provide us with payment processing services including Semble Pay;
  • – that are involved in providing the services to you, including suppliers of diagnostic services such as blood testing companies and third party provider(s) used for certain scans and procedures.
  • – that assist with the management and fulfilment of deliveries, including couriers.

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

• – Healthcare professionals and other individuals contracted to deliver services on behalf of Kidswell.
• – Hospitals, GP practices and registered health care professionals (such as doctors, paediatricians, psychiatrists, psychologists or therapists who are not delivering services on behalf of Kidswell) which act as separate controllers of the personal data, for example your NHS GP. We will share Health Data where the appropriate consent has been given.
• – Organisations you have requested that we share personal data with, such as your local authority or your child’s school.
• – your medical insurer, to provide information about your child’s treatment and its cost, only if they are paying for all or part of your child’s treatment with us
• – our professional advisors.
• – courts, tribunals, law enforcement authorities and regulators to comply with our legal obligations or to support them in carrying out their duties.

• – third parties with which we may negotiate or choose to sell, transfer or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy policy.

International Transfers

We do not transfer your personal data outside of the UK.

• Data security

We have put in place 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.

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.

• Data retention

We retain Health Data according to NHS guidance on retention periods.

We will only retain your other 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 typically retain data for a maximum of 7 years.  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.

In some circumstances you can ask us to delete your data: see Your legal rights below for further information.

• 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 (see Opting out of marketing in paragraph 4 for details of how to object to receiving direct marketing communications).
• – 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 (see the table in paragraph 4 for details of when we rely on your consent as the legal basis for using your 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 us – see Contact details in paragraph 10. For more information on any of the rights set out above, please refer to the ICO guidance (available here).

No fee usually required

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances.

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.

Time limit to respond

We try to respond to all valid requests within . Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

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 us in the following ways:

• – Email address: compliance@kidswellhealth.com
• – Postal address: 771 Finchley Road, London, NW11 8DN
• – Telephone number: 020-3011-1843
• –  Complaints

You have the right to make a complaint to the Information Commissioner’s Office (ICO), the UK regulator for data protection issues www.ico.org.uk at Wycliffe House, Water Lane, Wilmslow, Cheshire SK9 5AF.

We would appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.

• Changes to the privacy policy and your duty to inform us of changes

We keep our privacy policy under regular review and may update this privacy notice to reflect changes to our information practices. In that case, the “last updated” at the top of this page will also change. We encourage you to periodically review this page for the latest information on our privacy practices.

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us, for example a new address or email address.

• Third-party links

This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy policy of every website you visit.