Privacy Policy

Privacy Policy for Chiropractic Corporation Limited

Thank you for visiting our website (“website” includes any mobile or other applications giving you access to websites).

This Privacy Policy relates to our privacy practices and policies for our website and digital and social media. It sets out what Personal Data we collect and process about you in connection with the services and functions of Optimal Chiropractic. We will inform you of the following:

• where we obtain the data from,
• what we do with that data,
• how we comply with the data protection rules,
• who we transfer data to and
• how we deal with individuals’ rights in relation to their Personal Data.

Any Personal Data is collected and processed in accordance with Irish and EU data protection laws.

All our employees and contractors are required to comply with this Privacy Policy when they process Personal Data on our behalf.

Please note that we may disclose individuals’ information to trusted third parties for the purposes set out and explained in this document. We require all third parties to have appropriate technical and operational security measures in place to protect your Personal Data, in line with Irish and EU laws on data protection.

We will not disclose personal information to any third party without your consent or on one of the grounds listed herein, except in incidences where an individual is potentially at risk or where the law requires it.

We are not responsible for the content or the privacy policies for any websites that we provide external links to.

These practices may be changed, but any changes will be posted, and changes will only apply to activities and information on a going forward, not retroactive basis. You are encouraged to review the Privacy Policy periodically to make sure that you understand how any personal information you provide will be used.

We need to demonstrate accountability for our data protection obligations. This means that we must be able to show how we comply with the data protection rules, and that we have in fact complied with the rules. We do this, among other ways, by our written policies and procedures, by building data protection compliance into our systems and business rules, by internally monitoring our data protection compliance and keeping it under review, and by taking action if our employees or contractors fail to follow the rules. We also have certain obligations in relation to keeping records about our data processing.

Identity of the Data Controller and Contact Details

Chiropractic Corporation Limited trades as Optimal Chiropractic.
Our Data Protection Co-Ordinator can be contacted as follows:-
Telephone: 021 487 8465
Email:
Post: Optimal Chiropractic, Station Road, Ballincollig, Cork P31 T925

Data protection provides rights to individuals with regard to the use of their Personal Data by organisations, including Optimal Chiropractic. Irish and EU laws on data protection govern all activities we engage in with regard to our collection, storage, handling, disclosure and other uses of Personal Data.

Compliance with the data protection rules is a legal obligation. In addition, our compliance with the data protection rules helps individuals to have confidence in dealing with us and helps us to maintain a positive reputation in relation to how we handle personal information.

The data protection rules that apply to us are currently contained in the Data Protection Acts 1988 and 2003, in the ePrivacy Regulations 2011 and in related legislation (together the “DPAs”). As and from 25 May 2018, the applicable rules will be contained in the EU General Data Protection Regulation (EU Regulation 679/2016) (the “GDPR”) and in related Irish data protection legislation which gives effect to the GDPR.

“Data controllers” are the people who or organisations which determine the purposes for which, and the manner in which, any Personal Data is processed, who/which make independent decisions in relation to the Personal Data and/or who/which otherwise control that Personal Data.

For the purposes of the GDPR, Optimal Chiropractic is the data controller with regard to the Personal Data described in this Privacy Policy.

What are the data protection rules?

This Policy aims to ensure compliance with the relevant data protection laws. We aim to comply with the following:

Lawfulness, fairness and transparency – Personal data must be processed lawfully, fairly and in a transparent manner.
Purpose Limitation. Personal data must be collected for specified, explicit and legitimate purposes and not further processed in a manner that is incompatible with those purposes.
Data minimisation – Personal Data must be adequate, relevant and limited to what is necessary in relation to purposes for which they are processed.
Accuracy – Personal data must be accurate and, where necessary, kept up to date. Inaccurate Personal Data should be corrected or deleted.
Retention – Personal data should be kept in an identifiable format for no longer than is necessary.
Integrity and confidentiality – Personal data should be kept secure.
Accountability – An important change for Data Controllers. Under the GDPR, we must not only comply with the above six general principles but we must be able to demonstrate that we comply by documenting and keeping records of all decisions.

Special Category Data

We will not collect special category data from you.

Criminal Conviction Data

We will not collect criminal conviction data from you.

Type of Information Collected
We collect two types of information: “Personal data” means any information relating to and identified or identifiable natural person. We will collect this from you when you:

ask about our activities
register for our newsletter
buy a voucher
book to attend an event
visit our website
or otherwise give us personal information via any of our digital platforms.

We hold some data about you:

your personal details including your name, email address or telephone number (when you provide us with same)
your IP address which is not ever attached to a name or email address and kept only for 8 days in server logs

Technical Information We Collect on Our Website
“Non-Personal Data”. Like most websites, we gather statistical and other analytical information collected on an aggregate basis of all visitors to our website. This non-Personal Data comprises information that cannot be used to identify or contact you. We will collect this from you when you visit our website and accept cookies. This information includes standard information from you (such as browser type and browser language), your Internet Protocol (“IP”) address, and the actions you take on our website (such as the web pages viewed and links clicked). Our use of cookies to process information is explained within this policy.

This site uses cookies to enable us to improve our service to you and to provide certain features that you may find useful.

Cookies are small text files that are transferred to your computer’s hard drive through your web browser to enable us to recognise your browser and help us to track visitors to our site. A cookie contains your contact information and information to allow us to identify your computer when you travel around our site for the purpose of helping you accomplish your voucher purchase, event booking or other function. Most web browsers automatically accept cookies, but, if you wish, you can set your browser to prevent it from accepting cookies. The “help” portion of the toolbar on most browsers will tell you how to prevent your browser from accepting new cookies, how to have the browser notify you when you receive a new cookie, or how to disable cookies altogether. The cookies we use do not detect any information stored on your computers.

We use cookies to monitor customer traffic patterns and site usage to help us develop the design and layout of the websites. This software does not enable us to capture any personal information.

Certain information in relation to web usage is revealed via our internet service provider who records some of the following data. The information we receive depends upon what you do when visiting our site:

The logical address of the server you are using.
The date and time you access our site.
The pages you have accessed and the documents downloaded.
What browser you use to access the website.
The previous Internet address from which you linked directly to our site.
Some of the search criteria you are using

How we may use this technical information
Aggregate cookie and tracking information may be shared with third parties.

The technical information is used to allow us improve the information we are supplying to our users, to find out how many people are visiting our sites and for statistical purposes.

Some of the above information is used to create summary statistics which allow us to assess the number of visitors to the different sections of our site, discover what information is most and least used, inform us on future design and layout specifications, and help us make our site more user friendly.

We will make no attempt to identify individual visitors, or to associate the technical details listed above with any individual. We will only use the technical information for statistical and other administrative purposes. You should note that technical details, which we cannot associate with any identifiable individual, are not “Personal Data” within the meaning of the GDPR.

Use of Information Collected
We collect and use your information for the following purposes:

To perform the services requested, for example, if you fill out the “How can we help you?” Web form, we will use the information provided to contact you about your request. This data processing is necessary to provide or fulfill a service requested by or for you.
To perform marketing purposes, for example, we may use information you provide to contact you to further discuss your interest in the service and to send you information regarding the organisation such as our products, services, or events. This data processing for marketing purposes is a legitimate business interest.
To operate and improve our Website, for example, we may analyze and process information for the purpose of improving the customer experience. Information collected may include your browser type and language, or the city or region or country from which you accessed the Website, as well as the ways you interact with the Website, such as pages visited, time spent on pages, the number of clicks and the domain names. We may use third-party analytic providers and technologies, including cookies and similar tools, to assist. We process this information given our legitimate business interest to improve the Optimal Chiropractic Website and our customer’s experience with it.
For payment purposes, for example, to collect payment from you where applicable. This data processing is necessary to provide or fulfil a service requested by or for you.

Marketing
We strive to provide you with choices regarding certain Personal Data uses, particularly around marketing and advertising. At the point at which you provide us with your Personal Data you will be asked whether you wish to receive any marketing communications from us.

We may use your Personal Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you (we call this marketing).

We will not share your Personal Data with any third party for marketing purposes.

You may object to direct marketing by using the contact details herein to opt-out.

Third Party Data Processors
We may use trusted third parties as data processors. We require all third parties to have appropriate technical and operational security measures in place to protect your Personal Data, in line with Irish and EU laws on data protection. Any such organisation or individual will have access to personal information needed to perform these functions but may not use it for any other purpose.

Specifically, we need to have written agreements in place with all of our data processors and, before we sign each agreement, we need to have vetted and be satisfied with the processor’s data security. The agreements also need to contain specific clauses that deal with data protection.

In some situations, we may be considered to be co or joint data controllers with the listed third parties. One of these examples would be where we have our business page hosted on Facebook and utilise the advertising capabilities Facebook offers. We would encourage you to be aware of Facebook’s privacy and data notices which can be read at: https://www.facebook.com/privacy/explanationYou may also learn more about your ad preferences on Facebook here: https://www.facebook.com/help/247395082112892

These processors may be updated from time to time and for an updated list of categories of data processors you should check this Privacy Policy periodically.

We use the following third party data processors in the course of our business:

For online marketing;

Convert Kit
Zapier
Google Analytics
Eventbrite
Groupon
LivingSocial
Facebook

For online Banking;

PayPal
Bank of Ireland
Stripe
SumUp

For website building, hosting and security;

Automattic
Blacknight
WordFence

We may pass on your details if we are under a duty to disclose or share a Data Subject’s Personal Data in order to comply with any legal obligation, or in order to enforce or apply any contract with the Data Subject or other agreements; or to protect our rights, property, or safety of our employees, customers, or others. This includes reporting information about incidents (as appropriate) to the law enforcement authorities and responding to any requirements from law enforcement authorities to provide information and/or Personal Data to them for the purposes of them detecting, investigating and/or prosecuting offences or in connection with crime sentencing.

Other than the above, we will not disclose personal information to any third party without your consent except in incidences where an individual is potentially at risk or where the law requires it.

International Transfers
When we transfer your Personal Data out of the EEA, we ensure an adequate degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

We will only transfer your Personal Data to countries that have been deemed to provide an adequate level of protection for Personal Data by the European Commission.
Where we use certain service providers, we may use specific contracts approved by the European Commission which give Personal Data the same protection it has in Europe.
Where we use providers based in the US, we may transfer data to them if they are part of the Privacy Shield which requires them to provide similar protection to Personal Data shared between the Europe and the US.

Please contact us if you want further information on the specific mechanism used by us when transferring your Personal Data out of the EEA.

Data Retention
We have a documented data retention schedule. We will only retain your Personal Data for as long as necessary to fulfil the purposes we collected it for and for up to seven (7) years afterwards or otherwise permitted by applicable laws. We may also retain your information during the period of time needed to complete our legitimate business operations, including for the purposes of satisfying any legal, accounting, or reporting requirements.

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 requirements.

Your Data Protection Rights
Under certain circumstances, by law you have the right to:

Request information about whether we hold personal information about you, and, if so, what that information is and why we are holding/using it.
Request access to your personal information (commonly known as a “Data Subject access request”). This enables you to receive a copy of the personal information we hold about you and to check that we are lawfully processing it.
Request correction of the personal information that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected.
Request erasure of your personal information. This enables you to ask us to delete or remove personal information 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 information where you have exercised your right to object to processing (see below).
Object to processing of your personal information where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground. You also have the right to object where we are processing your personal information for direct marketing purposes.
Object to automated decision-making including profiling, that is not to be subject of any automated decision-making by us using your personal information or profiling of you.
Request the restriction of processing of your personal information. This enables you to ask us to suspend the processing of personal information about you, for example if you want us to establish its accuracy or the reason for processing it.
Request transfer of your personal information in an electronic and structured form to you or to another party (commonly known as a right to “data portability”). This enables you to take your data from us in an electronically useable format and to be able to transfer your data to another party in an electronically useable format.

How You Exercise Your Rights
We have appointed a Data Protection Co-Ordinator to monitor compliance with our data protection obligations and with this policy and our related policies. If you have any questions about this policy or about our data protection compliance, please contact the Data Protection Co-Ordinator.

Data subjects must make a formal request for Personal Data we hold about them or otherwise to exercise their data protections rights whether to make an access request or otherwise by contacting our Data Protection Co-Ordinator who will respond to the request within 30 days.

We are obliged to comply with exceptions to your requests where laid out in law. Such exceptions relate to health data, disclosures that would be likely to cause serious harm to your physical or mental health or emotional condition and opinions given in confidence.

Our Data Protection Co-Ordinator can be contacted as follows:-

Telephone: 021 487 8465
Email:
Post: Optimal Chiropractic, Station Road, Ballincollig, Cork P31 T925

Your Right to Lodge a Complaint
You as the Data Subject have the right to complain at any time to a data protection supervisory authority in relation to any issues related to our processing of your Personal Data. As our organisation is located in Ireland and we conduct our data processing here, we are regulated for data protection purposes by the Irish Data Protection Commissioner.

You can contact the Data Protection Commissioner as follows:

Use their website www.dataprotection.ie
Phone: +353 57 8684800 or +353 (0)761 104 800
Email:

Address: Data Protection Office – Canal House, Station Road, Portarlington, Co. Laois, R32 AP23. Or 21 Fitzwilliam Square Dublin 2. D02 RD28 Ireland.

Consent
By consenting, where this is the appropriate grounds, to our processing your Personal Data in line with this Privacy Policy you are giving us permission to process your Personal Data specifically for the purposes identified.

You may withdraw consent at any time by providing an unambiguous indication of your wishes by which you, by a statement or by a clear affirmative action, signify withdrawal of consent to the processing of Personal Data relating to you. If you have any queries relating to withdrawing your consent, please contact our Data Protection Co-Ordinator using the contact details set out below.

Withdrawal of consent shall be without effect to the lawfulness of processing based on consent before its withdrawal.

Security of your Personal Data
We take appropriate security measures against unlawful or unauthorised processing of Personal Data, and against the accidental loss of, or damage to, Personal Data.

We have put in place procedures and technologies to maintain the security of all Personal Data from the point of collection to the point of destruction. Personal data will only be transferred to a data processor if they agree to comply with those procedures and policies, or if they put in place adequate measures himself. In addition, we have appropriate written agreements in place with all of our data processors.

We maintain data security by protecting the confidentiality, integrity and availability of the Personal Data, defined as follows:

Confidentiality means that only people who are authorised to use the data can access it.
Integrity means that Personal Data should be accurate and suitable for the purpose for which it is processed.
Availability means that authorised users should be able to access the data if they need it for authorised purposes.

We follow strict security procedures in the storage and disclosure of your Personal Data, and to protect it against accidental loss, destruction or damage. We use third party vendors and hosting partners to provide the necessary hardware, software networking, storage, and related technology required to run. The data you provide to us is protected using modern encryption, intrusion prevention, and account access techniques.

Sale of Business
Situations may arise where it is necessary to transfer information (including your Personal Data) to a third party in the event of a sale, merger, liquidation, receivership or transfer of all or substantially all of the assets of our organisation provided that the third party agrees to adhere to the terms of the Privacy Policy and provided that the third party only uses your Personal Data for the purposes that you provided it to us. The Personal Data transferred will be limited to that which is absolutely necessary. You will be notified in the event of any such transfer and you will be afforded an opportunity to opt-out.

Existence of Automated Decision-Making
Automated Decision Making refers to a decision which is taken solely on the basis of automated processing of your personal data. This means processing using, for example, software code or an algorithm, which does not require human intervention.

As Profiling uses automated processing, it is sometimes connected with automated decision making. Not all profiling results in automated decision making, but it can do.

This website contains an automated decision-making mechanism, which is used to determine user location. You have the right to object to the use of your Personal Data. Please submit your request through the contact details on this website in writing.

We regularly check the automated tools used to ensure that the profiling is done fairly. Specific measures such as data minimisation are implemented when creating profiles. You are invited to express your point of view through the right of access described above. You can also contest the result of the automated decision by sending an email to the contact details provided in this Policy.

Children’s Personal Data
If you would like to make use of our services and you are not yet 18 years old, we require that an adult is present when you register. Where consent is required to process your Personal Data as a child, we will obtain that consent from the adult who is authorised to give the consent on your behalf.

You must be at least 18 years old to create an account and engage in activities and transactions on our digital and social media. By creating an account or engaging in activities or transactions on our digital and social media, you affirm that you are at least 18 years old and are fully able to enter into and comply with our regular Terms of Use and this Privacy. If we are notified or learn that a child has submitted Personal Data to us through our digital or social media, we will delete such Personal Data.

Changes to the Privacy Policy
Any changes to this Privacy Policy will be posted on this website so you are always aware of what information we collect, how we use it, and under what circumstances, if any, we disclose it. If at any time we decide to use Personal Data in a manner significantly different from that stated in this Privacy Policy, or otherwise disclosed to you at the time it was collected, we will notify you by email, and you will have a choice as to whether or not we use your information in the new manner.

Policy Approval
This Policy has been approved and authorised by:

NAME: Benjamin Martin

POSITION: Owner and Director

DATE: 15 May 2018

POLICY IMPLEMENTATION DATE: 15 May 2018