Privacy Policy

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This privacy policy aims to give you information on how we collect and process your personal data so that you can be confident when you use our website or our Services that you know what your personal data is being used for and that it is being kept safe.

We provide support services (collectively, the Services) to healthcare organisations. 

Please note, this policy explains our use of personal data as a controller only. If we have to access personal data as part of our Services, we process your personal data as a processor only and in this case the data controller organisation’s privacy policy will explain how your data is being used and stored.

1. IMPORTANT INFORMATION AND WHO WE ARE

Fractional Consulting is a trading name of Richard Moss, operating as a sole trader (referred to as "we", "us" or "our" in this privacy policy). Our Data Protection Officer can be contacted by email at dpo@fractional-consulting.com. 

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.

2. THE DATA WE COLLECT ABOUT YOU

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

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, title, and gender

· Contact Data includes work address, job role, email address and telephone numbers.

· Technical Data includes internet protocol (IP) address, device type, cookie ID, API keys, [web becons (also known as “pixel tags” or “clear GIFs”)], browser-type, broad geographic location (e.g. country or city-level location), date/time stamps, session tokens and other technical information. We may also collect information about how your device has interacted with our wesbite, including the pages accessed and links clicked. 

· Usage Data includes information about how you use our website and Services.

· Marketing and Communications Data includes your preferences in receiving marketing from us your communication preferences.

3. HOW IS YOUR PERSONAL DATA COLLECTED?

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

· Direct interactions. You may give us your Identity or Contact details by filling out our form asking for information about our Services, or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:

· access our website;

· request marketing to be sent to you; or

· give us feedback or contact us.

· Automated technologies or interactions. As you interact with our website and our Services 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. 

HOW WE USE YOUR PERSONAL DATA

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

· Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.

· Where we need to comply with a legal obligation.

Generally, we do not rely on consent as a legal basis for processing your personal data although we will get your consent before sending direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us.

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 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.

Purpose/Activity

Type of data

Lawful basis for   processing including basis of legitimate interest

To manage our relationship with you which will include,   for example, responding to your queries or communications. 

· Identity

· Contact

· Profile

· Marketing and Communications

· Performance of a contract with you

· Necessary for our legitimate interests (to   keep our records updated and to study how customers use our website and   Services)

To administer and protect our business and this website   (including troubleshooting, data analysis, testing, system maintenance,   support, reporting and hosting of data)

· Identity

· Contact

· Technical

· Necessary for our legitimate interests (for   running our business, provision of administration and IT services, network   security, to prevent fraud and in the context of a business reorganisation or   group restructuring exercise)

· Necessary to comply with a legal obligation

Website management. Including: 

To deliver relevant website content and advertisements   to you and measure or understand the effectiveness of the advertising we   serve to you

· Identity

· Contact

· Profile

· Usage

· Marketing and Communications

· Technical

Necessary for our legitimate interests (to study how   customers use our website, to grow our business and to inform our marketing   strategy)

To use data analytics to improve our website,   products/services, marketing, customer relationships and experiences

· Technical

· Usage

Necessary for our legitimate interests (to define types   of customers for our products and services, to keep our website updated and   relevant, to develop our business and to inform our marketing strategy)

For data analytics purposes (e.g. usage statistics and   performance management) in relation to usage of and access to our Services. 

Note, such analytics would only involve aggregated data.   

· Technical

· Usage

Necessary for our legitimate interests (to develop and   improve our Services)

MARKETING

We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising. You will only receive marketing communications from us if you have requested information from us and you have not opted out of receiving that marketing.

You can ask us to stop sending you marketing messages at any time by contacting us at any time.

COOKIES

You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly

DISCLOSURES OF YOUR PERSONAL DATA

We may share your personal data with the parties set out below for the purposes set out in the table above.

· Service providers including those who provide: 

· Webhosting, IT, and system administration services

·  Metrics and analytics

· Professional advisers including lawyers, bankers, auditors, and insurers who provide consultancy, banking, legal, insurance, and accounting services.

· Authorities including regulators and other authorities who require reporting of processing activities in certain circumstances

· Third parties to whom we may 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.

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.

4. INTERNATIONAL TRANSFERS

Some of our external third parties are based outside the UK so their processing of your personal data will involve a transfer of data outside the UK. Where we use certain service providers, we may use specific contracts approved for use in the UK which give personal data the same protection it has in the UK. 

Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the UK.

5. 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.

6. YOUR LEGAL RIGHTS

Under certain circumstances, you have rights under data protection laws in relation to your personal data. Please click on the links below to find out more about these rights:

· Request access to your personal data

· Request correction of your personal data

· Request erasure of your personal data

· Object to processing of your personal data

· Request restriction of processing your personal data

· Request transfer of your personal data

· Right to withdraw consent

If you wish to exercise any of the rights set out above, please contact us at [dpo@infinity.health].

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.

7. DATA WE PROCESS FOR CLIENT ORGANISATIONS 

As described above, we also act as a data processor of personal data on behalf of our clients. If you are an individual using our Service, we process your personal data as a processor only and in this case the health care organisation’s privacy policy will explain how your data is being used and stored. If your data has been submitted to us in our role as a processor by or on behalf of a healthcare organisation and you wish to exercise any rights you may have under applicable data protection laws, please inquire with them directly. Because we may only access a a health organisation's data upon their instructions, if you wish to make your request directly to us, please provide us the name of the relevant healthcare organisation and we will refer your request to them. 

8. CONTACT DETAILS

If you have any questions about this privacy policy or our privacy practices, please contact [dpo@fractional-consulting.com].

You have the right to make a complaint at any time to the Information Commissioner's Office (ICO), the UK regulator for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.