Privacy

BACKGROUND:
Hillside Physiotherapy understands that your privacy is important to you and that you care
about how your personal data is used and shared online. We respect and value the privacy
of everyone who visits this website, wirralhomephysio.co.uk (“Our Site”) and will only collect
and use personal data in ways that are described here, and in a manner that is consistent
with Our obligations and your rights under the law.
Please read this Privacy Policy carefully and ensure that you understand it. [Your
acceptance of Our Privacy Policy is deemed to occur upon your first use of Our Site]
AND/OR [You will be required to read and accept this Privacy Policy when signing up for an
Account]. If you do not accept and agree with this Privacy Policy, you must stop using Our
Site immediately.
1. Definitions and Interpretation
In this Policy the following terms shall have the following meanings:
“Account” means an account required to access and/or use certain

areas and features of Our Site;

“Cookie” means a small text file placed on your computer or device
by Our Site when you visit certain parts of Our Site and/or
when you use certain features of Our Site. Details of the
Cookies used by Our Site are set out in section 13, below;
[“Cookie Law” means the relevant parts of the Privacy and Electronic
Communications (EC Directive) Regulations 2003;]
“personal data” means any and all data that relates to an identifiable
person who can be directly or indirectly identified from that
data. In this case, it means personal data that you give to
Us via Our Site. This definition shall, where applicable,
incorporate the definitions provided in the [Data Protection
Act 1998] OR [EU Regulation 2016/679 – the General
Data Protection Regulation (“GDPR”)]; and

2. Information About Us
1. Our Site is [owned and] operated by Kooi Westgeet-Teoh
2. [Our VAT number is (currently not VAT registered).]
3. [Our Data Protection Officer is Kooi Westgeet-Teoh, and can be contacted by
email at info@hillsidephysio.co.uk

3. What Does This Policy Cover?
This Privacy Policy applies only to your use of Our Site. Our Site may contain links to
other websites. Please note that We have no control over how your data is collected,
stored, or used by other websites and We advise you to check the privacy policies of

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any such websites before providing any data to them.

4. [Your Rights
1. As a data subject, you have the following rights under the GDPR, which this
Policy and Our use of personal data have been designed to uphold:
1. The right to be informed about Our collection and use of personal data;
2. The right of access to the personal data We hold about you (see
section 12);
3. The right to rectification if any personal data We hold about you is
inaccurate or incomplete (please contact Us using the details in section
14);
4. The right to be forgotten – i.e. the right to ask Us to delete any
personal data We hold about you (We only hold your personal data for
a limited time, as explained in section 6 but if you would like Us to
delete it sooner, please contact Us using the details in section 14);
5. The right to restrict (i.e. prevent) the processing of your personal data;
6. The right to data portability (obtaining a copy of your personal data to
re-use with another service or organisation);
7. The right to object to Us using your personal data for particular
purposes; and
8. Rights with respect to automated decision making and profiling.
2. If you have any cause for complaint about Our use of your personal data,
please contact Us using the details provided in section 14 and We will do Our
best to solve the problem for you. If We are unable to help, you also have the
right to lodge a complaint with the UK’s supervisory authority, the Information
Commissioner’s Office.
3. For further information about your rights, please contact the Information
Commissioner’s Office or your local Citizens Advice Bureau.]

5. What Data Do We Collect?
Depending upon your use of Our Site, We may collect some or all of the following
personal [and non-personal] data (please also see section 13 on Our use of Cookies
and similar technologies [and Our Cookie Policy]):
1. [name;]
2. [date of birth;]
3. [gender;]
4. [business/company name]
5. [job title;]
6. [profession;]
7. [contact information such as email addresses and telephone numbers;]
8. [demographic information such as post code, preferences and interests;]

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9. [financial information such as credit / debit card numbers;]
10. [IP address;]
11. [web browser type and version;]
12. [operating system;]
13. [a list of URLs starting with a referring site, your activity on Our Site, and the
site you exit to;]

6. How Do We Use Your Data?
1. All personal data is processed and stored securely, for no longer than is
necessary in light of the reason(s) for which it was first collected. We will
comply with Our obligations and safeguard your rights under the [Data
Protection Act 1998] OR [GDPR] at all times. For more details on security see
section 7, below.
2. Our use of your personal data will always have a lawful basis, either because
it is necessary for Our performance of a contract with you, because you have
consented to Our use of your personal data (e.g. by subscribing to emails), or
because it is in Our legitimate interests. Specifically, We may use your data for
the following purposes:
1. [Providing and managing your Account;]
2. [Providing and managing your access to Our Site;]
3. [Personalising and tailoring your experience on Our Site;]
4. [Supplying Our [products] AND/OR [services] to you (please note that
We require your personal data in order to enter into a contract with
you);]
5. [Personalising and tailoring Our [products] AND/OR [services] for
you;]
6. [Replying to emails from you;]
7. [Supplying you with emails that you have opted into (you may
unsubscribe or opt-out at any time by sending us an email
info@hillsidephysio.co.uk and state opt-out]
8. [Market research;]
9. [Analysing your use of Our Site [and gathering feedback] to enable Us
to continually improve Our Site and your user experience;]

3. [With your permission and/or where permitted by law, We may also use your
data for marketing purposes which may include contacting you by [email]
AND/OR [telephone] AND/OR [text message] AND/OR [post] with
information, news and offers on Our [products] AND/OR [services]. We will
not, however, send you any unsolicited marketing or spam and will take all
reasonable steps to ensure that We fully protect your rights and comply with
Our obligations under the [Data Protection Act 1998] OR [GDPR] and the
Privacy and Electronic Communications (EC Directive) Regulations 2003.]

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4. You have the right to withdraw your consent to Us using your personal data at
any time, and to request that We delete it.
5. We do not keep your personal data for any longer than is necessary in light of
the reason(s) for which it was first collected. Data will therefore be retained for
the following periods (or its retention will be determined on the following
bases):
1. 6 years from the date of date of receipt

7. How and Where Do We Store Your Data?
1. We only keep your personal data for as long as We need to in order to use it
as described above in section 6, and/or for as long as We have your
permission to keep it.
2. Your data will only be stored in the UK.
Data security is very important to Us, and to protect your data We have taken
suitable measures to safeguard and secure data collected through Our Site.
3. Steps We take to secure and protect your data include:
1. SSL website and use of cloud flare.

8. Do We Share Your Data?
1. [Subject to section 8.2, We will not share any of your data with any third
parties for any purposes.
2. In certain circumstances, We may be legally required to share certain data
held by Us, which may include your personal data, for example, where We are
involved in legal proceedings, where We are complying with legal obligations,
a court order, or a governmental authority.]

9. What Happens If Our Business Changes Hands?
1. We may, from time to time, expand or reduce Our business and this may
involve the sale and/or the transfer of control of all or part of Our business.
Any personal data that you have provided will, where it is relevant to any part
of Our business that is being transferred, be transferred along with that part
and the new owner or newly controlling party will, under the terms of this
Privacy Policy, be permitted to use that data only for the same purposes for
which it was originally collected by Us.
2. In the event that any of your data is to be transferred in such a manner, you
will [not] be contacted in advance and informed of the changes. [When
contacted you will [not, however,] be given the choice to have your data
deleted or withheld from the new owner or controller.]

10. How Can You Control Your Data?
1. [In addition to your rights under the GDPR, set out in section 4, when] OR
[When] you submit personal data via Our Site, you may be given options to
restrict Our use of your data. In particular, We aim to give you strong controls

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on Our use of your data for direct marketing purposes (including the ability to
opt-out of receiving emails from Us which you may do by unsubscribing using
the links provided in Our emails and at the point of providing your details [and
by managing your Account]).
2. You may also wish to sign up to one or more of the preference services
operating in the UK: The Telephone Preference Service (“the TPS”), the
Corporate Telephone Preference Service (“the CTPS”), and the Mailing
Preference Service (“the MPS”). These may help to prevent you receiving
unsolicited marketing. Please note, however, that these services will not
prevent you from receiving marketing communications that you have
consented to receiving.
11. Your Right to Withhold Information
1. You may access [certain areas of] Our Site without providing any data at all.
[However, to use all features and functions available on Our Site you may be
required to submit or allow for the collection of certain data.]
2. You may restrict Our use of Cookies. For more information, see section 13
[and Our Cookie Policy.
12. How Can You Access Your Data?
You have the right to ask for a copy of any of your personal data held by Us (where
such data is held). Under the GDPR, no fee is payable and We will provide any and
all information in response to your request free of charge.] Please contact Us for
more details at hello@whoopa.co.uk, or using the contact details below in section 14.

13. [Our Use of Cookies
1. [Our Site may place and access certain first party Cookies on your computer
or device. First party Cookies are those placed directly by Us and are used
only by Us. We use Cookies to facilitate and improve your experience of Our
Site and to provide and improve Our [products] AND/OR [services]. We have
carefully chosen these Cookies and have taken steps to ensure that your
privacy and personal data is protected and respected at all times.
2. All Cookies used by and on Our Site are used in accordance with current
Cookie Law.
3. Before Cookies are placed on your computer or device, you will be shown
prompt, requesting your consent to set those Cookies. By giving your consent
to the placing of Cookies you are enabling Us to provide the best possible
experience and service to you. You may, if you wish, deny consent to the
placing of Cookies; however certain features of Our Site may not function fully
or as intended. [You will be given the opportunity to allow only first party
Cookies and block third party Cookies.]
4. [Certain features of Our Site depend on Cookies to function. Cookie Law
deems these Cookies to be “strictly necessary”. These Cookies are shown
below in section 13.5. Your consent will not be sought to place these Cookies,
but it is still important that you are aware of them. You may still block these
Cookies by changing your internet browser’s settings as detailed below in
section 13.9, but please be aware that Our Site may not work properly if you
do so. We have taken great care to ensure that your privacy is not at risk by

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allowing them.]
5. Cookies are constantly changing so it is not possible to show the exact
cookies and list them here.
6. Our Site uses analytics services provided by google. Website analytics refers
to a set of tools used to collect and analyse anonymous usage information,
enabling Us to better understand how Our Site is used. This, in turn, enables
Us to improve Our Site and the [products] AND/OR [services] offered through
it. You do not have to allow Us to use these Cookies, however whilst Our use
of them does not pose any risk to your privacy or your safe use of Our Site, it
does enable Us to continually improve Our Site, making it a better and more
useful experience for you.
7. The analytics service(s) used by Our Site use(s) Cookies to gather the
required information.
8. The analytics service(s) used by Our Site use(s) Cookies that can change and
therefore it is not possible to list them here.
9. In addition to the controls that We provide, you can choose to enable or
disable Cookies in your internet browser. Most internet browsers also enable
you to choose whether you wish to disable all cookies or only third party
cookies. By default, most internet browsers accept Cookies but this can be
changed. For further details, please consult the help menu in your internet
browser or the documentation that came with your device.
10. You can choose to delete Cookies on your computer or device at any time,
however you may lose any information that enables you to access Our Site
more quickly and efficiently including, but not limited to, login and
personalisation settings.
11. It is recommended that you keep your internet browser and operating system
up-to-date and that you consult the help and guidance provided by the
developer of your internet browser and manufacturer of your computer or
device if you are unsure about adjusting your privacy settings.]
OR
[Our Site may place and access certain first party Cookies on your computer or
device. First party Cookies are those placed directly by Us and are used only by Us.
We use Cookies to facilitate and improve your experience of Our Site and to provide
and improve Our [products] AND/OR [services]. In addition, Our Site uses analytics
services provided by <<insert name of analytics service provider(s)>>, which also use
Cookies. Website analytics refers to a set of tools used to collect and analyse usage
statistics, enabling Us to better understand how people use Our Site. For more
details, please refer to Our Cookie Policy.
14. Contacting Us
If you have any questions about Our Site or this Privacy Policy, please contact Us by
email at info@hillsidephysio.co.uk. Please ensure that your query is clear, particularly
if it is a request for information about the data We hold about you (as under section
12, above).

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15. Changes to Our Privacy Policy
We may change this Privacy Policy from time to time (for example, if the law
changes). Any changes will be immediately posted on Our Site and you will be
deemed to have accepted the terms of the Privacy Policy on your first use of Our Site
following the alterations. We recommend that you check this page regularly to keep
up-to-date.