LAST UPDATED: 24 May 2018 

 

Privacy Policy

 

RE:COGNITION HEALTH LTD

 

INTRODUCTION

For the purpose of this Privacy Policy “you” or “your” means any end user accessing our services or our website (as defined below), “we” or “us“, “our” means Re:Cognition Health Ltd, registered in England and Wales under company number 06892124 with registered office at 77 Wimpole Street, London, England, W1G 9RU.

This Privacy Policy, together with our terms and conditions available at https://recognitionhealth.com/terms-conditions/(the “Terms“) and any other documents referred to in it, sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us.  This Privacy Policy also sets out how you can instruct us if you prefer to limit the use of that personal data and the procedures that we have in place to safeguard your privacy.

For the purpose of this Privacy Policy, Data Protection Legislation means: (i) the General Data Protection Regulation 2016/679 (the “GDPR”) applicable in the European Union, including the UK until any UK data protection legislation replaces or adopts the GDPR in the UK and; (ii) then such UK data protection legislation replacing the GDPR once in force and applicable. For the purpose of the Data Protection Legislation, the data controllers are Ticket Arena and Event Genius.

Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it.

For the purpose of applicable Data Protection Legislation, we are the data controller. We will treat your personal data in accordance with our obligations under data protection law and implement adequate security measures.  Our aim is to be clear and transparent about the way we use your personal data and not do anything you would not reasonably expect.

By using or accessing our website http://www.recognitionhealth.com (the “Website“) or using our services you signify your consent to our collection, use and disclosure of your personal data in accordance with this Privacy Policy.  If you do not agree with this Privacy Policy, you must not use our services, access the Website or submit information to us through or in connection with our services, the Website or otherwise.

    1. Information We May Collect From You
      1. Information you give us (submitted information):
        1. This includes information that you provide to us:
          1. when you call us;
          2. by filling in forms and submitting them to us;
          3. by e-mail;
          4. when you register to use our services, subscribe to any one of our services, through surveys, or by requesting further services; or
          5. when you enter any promotion sponsored by us.
        2. The information you give us may include:
          1. your name, address, e-mail address, age, personal description and photograph, username, password and other registration information, financial information or your phone number;
          2. background or medical information your submit to us (for example if you wish to take part in one of our clinical trials or you request medical advice); or
          3. information you submit in order to sign up for one of our events, give a testimonial or tell us your story.
        3. Sometimes when you request a service through us, your information will be collected by a health professional or a health organisation working with us (e.g. someone from our medical team or a health clinic) and in this case you may also be subject to their terms and conditions and privacy policy.
        4. If you contact us, whether through our services, the Website or otherwise we may keep a record of that correspondence.  For example, if you submit a query, a complaint, report a problem with our service, Website, or otherwise liaise with our customer service, technical support or any other department in our company we may keep a record.
        5. We may also ask you to complete surveys that we use for research purposes, although you do not have to respond to them.
    2. Information We Collect About You
      1. Each time you visit our Website or use our services we may collect the following information:
        1. details of your use and your visits to our Website including, but not limited to traffic data, weblogs and other communication data, whether this is required for our own billing purposes or otherwise (“Log Information“);
        2. your contact details such us your e-mail address, forename and surname (“Contact Details Information“);
        3. information we receive from other sources (“Third Party Information“). We are working closely with third parties (including, business partners, sub-contractors in technical, payment and delivery services, advertising networks, analytics providers, search information providers and credit reference agencies);
        4. you might give us permission to access some information about you when using some social media sites such as Twitter, WhatsApp or Facebook, depending on the privacy settings you have and the privacy policies of such companies (“Social Media Information”); and
        5. we may combine the information we have about you with other information available from other external sources such as information available in the UK electoral roll, or published articles or news, etc.
      2. We may check some of the information that you provide against third party databases to confirm that it is accurate.
      3. We may use third party payment agents to manage card payments.  In doing so, you will be asked by the payment agent for your card details and billing address.  This information is held by the third party payment agent, and you will be asked to agree to their terms and conditions, including their privacy policy, in completing the payment steps.
      4. We may have access to your billing address and payment history in order to assist with customer service enquiries.  Under no circumstances are these details disclosed to any third parties other than those who need to know this information for the performance of the services requested by you.
    3. How We May Use The Information Collected From You
      1. We will only use your personal data in line with the purposes for which you provided it to us (or for compatible purposes), in line with your stated preferences and with your reasonable expectations.
      2. We may process this information for the purpose of:
        1. administering registration records (including reminders, e.g. to update your payment details). Lawful Basis: to comply with our legal obligations, performance of our contract with you or necessary for our legitimate interests;
        2. providing and personalising our products or services. Lawful Basis: consent, performance of our contract with you or necessary for our legitimate interests;
        3. remembering your preferences about how you would like us to use your personal data and interact with you. Lawful Basis: consent, performance of our contract with you, necessary for our legitimate interests;
        4. providing you access to all parts or features of our services, or the Website. Lawful Basis:  performance of our contract with you and necessary for our legitimate interests;
        5. dealing with your enquiries and requests, including contacting you where necessary and providing you with information you ask from us. Lawful Basis:  performance of our contract with you, necessary for our legitimate interests, or compliance with laws and regulations;
        6. carrying out our obligations arising from any contracts entered into between you and us, such as providing you with medical advice and other medical services or considering your participation in our clinical trials. We process this information separately from any other data collected from you. Lawful Basis:  performance of our contract with you, necessary for our legitimate interests, or compliance with laws and regulations;
        7. contacting you for your views on our services and notifying you occasionally about important changes or developments to our services, or to the Website. Lawful Basis:  performance of our contract with you or necessary for our legitimate interests;
        8. carrying out market research campaigns. Lawful Basis: consent or necessary for our legitimate interests;
        9. improving and developing our services, or the Website. Lawful Basis:  performance of our contract with you or necessary for our legitimate interests;
        10. ensuring that content from our Website is presented in the most effective manner for you and for your computer or mobile device. Lawful Basis:  performance of our contract with you or necessary for our legitimate interests; and
        11. debt recovery or debt tracing, crime, fraud and money laundering compliance. Lawful Basis: compliance with laws and regulations or necessary for our legitimate interests.
      3. We may also use your personal data or permit selected third parties to use your data to provide you with information about goods and services, which may be of interest to you, and we or they may contact you about these by e-mail or text.
      4. If you are an existing customer, and you have not opted out of this, we will only contact you by electronic means (e-mail, SMS or inmail) with information about goods and services similar to those which were the subject of a previous sale to you.  You will be entitled to opt out from this by contacting us or by clicking “unsubscribe” in the electronic communication you receive.
      5. If you are a new customer, and where we permit selected third parties to use your information, we (or they) will contact you by electronic means only if you have consented to this.
      6. If you do not want us to use your information in this way, or to pass your details on to third parties for marketing or advertising purposes, please specify your preferences by ticking or not ticking the relevant box (or boxes) situated on the form on which we collect your data (e.g. the registration form) or email compliance@re-cognitionhealth.com to withdraw your consent.
      7. We may contact you by phone when you submit a form to us or when you send us a written enquiry about our services (e.g. by email).
      8. We may contact you by phone in connection with services and activities we promote (i.e. this would typically consist of a very small number of calls to you per year and follow up calls only if the first call yields positive interest).
      9. We may also gather information and statistics for the purposes of monitoring the usage of the Website and our services and may provide such anonymised information to third parties.  These statistics will not include information that can be used to identify you.
      10. We may use screening and profiling methods to enable us to determine your behaviour, interests and habits and to analyse demographic, geographic, and other information relating to you, to allow us to send you information relevant to you and to improve your experience. When doing so, we may gather information about you from other suitable and lawful third party sources, such as publicly available data or data from social networks as specified in paragraph 2.1(d) above.
      11. You may ask us to provide you with information about our services or services offered jointly with or on behalf of other organisations by sending us an e-mail to clinician@re-cognitionhealth.com.
      12. If you choose to post messages on any online forum or other message platforms that we may make available for this purpose on the Website, we may collect that information you provide to us, on or via those forums and platforms.  We may retain this information as necessary to resolve disputes, provide customer support and troubleshoot problems, as permitted by law.
      13. If you stop using our services, or our Website or your permission to use the Website or our services is terminated, we may continue to use and disclose your personal data in accordance with this Privacy Policy (as amended from time to time) and as permitted by law.  However, if you wish us to stop e-mailing you with information in connection with the Website or our services, please send your request in accordance with paragraph 12 below.
      14. We may contract out part of our services plus other ancillary services such as hosting, credit checking, billing, and verification of sales.  We may disclose your personal data to other organisations so that they can provide you with the services that we have contracted out.
      15. We may ask you to share your medical experiences. We will only use this information on our Website, materials or to promote our services if we have explicit consent from you.
    4. Information Security
      1. The Internet is not a secure medium.  However, we have put in place various security procedures with regards to the Website and your electronic communications with us, as set out in this Privacy Policy.
      2. Where relevant, with respect to online payments, all your payment details will be passed from your browser for processing using encryption.  All information you provide to us is stored on our secured servers. Any payment transactions carried out by us or our chosen third party provider of payment processing services will be encrypted using Secured Sockets Layer technology or other suitable encryption technology.
      3. Where you have been allocated a user admin area (an “Account“), this area is protected by your user name and password, which you should never divulge to anyone else. You are responsible for keeping this password confidential. We ask you not to share a password with anyone.
      4. Please be aware that communications over the Internet, such as e-mails/webmails are not secure unless they have been encrypted.  Your communications may route through a number of countries before being delivered – this is the nature of the World Wide Web/Internet.
      5. We cannot accept responsibility for any unauthorised access or loss of personal data that is beyond our control.
      6. We believe that we have appropriate policies, rules and technical measures to protect the personal data that we have under our control (having regard to the type and amount of that data) from unauthorised access, improper use or disclosure, unauthorised modification, unlawful destruction or accidental loss.
      7. All of our employees and data processors that have access to, and are associated with, the processing of your personal data, are obliged to respect the confidentiality of our users’ information.
      8. We ensure that your information will not be disclosed to government institutions or authorities, unless required by law or when lawfully requested to by courts of law, regulatory bodies or law enforcement organisations.
      9. Certain of our services include social networking, chat room or forum features. When using these features, please ensure that you do not submit any personal data (including any medical data) that you do not want to be seen, collected or used by other users.
      10. If we use external suppliers to collect or process personal data on our behalf, we will check such companies first and ensure that we place contractual obligations on them so they manage your personal data in line with our instructions and expectations and with data protections laws.
    5. To Whom Will Your Information Be Disclosed?
      1. We do not sell your personal data to any third parties. However, we may share some of your data with our trusted service providers and suppliers who may provide you with information on their services if:
        1. such service providers or suppliers are acting on our behalf. They cannot use your data for any purpose other than that which has been prescribed by us. We only use those service providers and suppliers who undertake to protect your details with the same degree of care as we do; or
        2. such service providers or suppliers are acting on their own account. You will be subject to their own terms and conditions and privacy policy.
      2. Your information, for the purposes set out in this Privacy Policy, may be disclosed for processing to:
        1. our employees;
        2. our affiliates;
        3. any member of our group companies and their employees, which means our subsidiaries, our ultimate holding company and its subsidiaries, as defined in section 1159 of the Companies Act 2006;
        4. successors in title to our business;
        5. a prospective seller or buyer in the event that we sell or buy any business or assets, in which case we will disclose your personal data to such business or assets;
        6. a buyer, if Re:Cognition Health or substantially all of its assets are acquired by a third party, in which case personal data held by it about its customers will be one of the transferred assets;
        7. as required by our event organisers in respect to any event you are taking part in or have applied for;
        8. third party consultants, contractors or other service providers who may access your personal data when providing services (including but not limited to IT support services) to us;
        9. government bodies and law enforcement agencies and in response to other legal and regulatory requests, if we are under a duty to disclose or share your personal data in order to comply with any legal or regulatory obligation or request;
        10. auditors or contractors or other advisers auditing, assisting with or advising on any of our business purposes or processes;
        11. to any third party where such disclosure is required in order to enforce or apply our Terms, and/or other agreements; or to protect the rights, property, or safety of our company, our customers, or others;
        12. protect the rights, property or safety of Re:Cognition Health, our customers, or others. This includes exchanging information with other companies and organisations for the purposes of fraud prevention and credit risk reduction; and
        13. subject to the limitations in paragraphs 3.3 to 3.6 above, to carefully selected third parties that may contact you about products and services which may be of interest to you.
    6. Your Rights In Relation To Your Information
      1. Please note that these rights do not apply in all circumstances. You are entitled to:
        1. request access to your personal data (commonly known as a “data subject access request”);
        2. request correction of the personal data that we hold about you;
        3. request erasure of your personal data. 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;
        4. object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation that makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms;
        5. request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios:
          1. if you want us to establish the data’s accuracy;
          2. where our use of the data is unlawful but you do not want us to erase it;
          3. 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
          4. you have objected to our use of your personal data but we need to verify whether we have overriding legitimate grounds to use it;
        1. 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 (i.e. not to hard copies) that you initially provided consent for us to use or where we used the information to perform a contract with you; and
        2. withdraw consent at any time where we are relying on consent to process your personal data. 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. Please write to: compliance@re-cognitionhealth.com.
      1. Please quote your name and address. We should be grateful if you would also provide brief details of the data that you would like a copy of or which you would like to be corrected (this helps us to more readily locate your data).
      2. We will require proof of your identity before providing you with details of any personal data we may hold about you.
      3. If you wish to do this, please write to: compliance@re-cognitionhealth.com. Please quote your name and address in any such correspondence. If possible, please also provide brief details of the information that you would like a copy of or would like to be corrected (this helps us to more readily locate your personal data).
      4. We try to respond to all legitimate requests within 1 (one) month. Occasionally, it may take us longer than 1 (one) month if your request is particularly complex or you have made a number of requests. In this case, we will notify you within 1 (one) month of the receipt of your request and keep you updated in relation to this request.
      5. We will require proof of your identity before providing you with details of any personal data we may hold about you. We may charge a reasonable fee when a request is manifestly unfounded or excessive or repetitive or we receive a request to provide further copies of the same information.
    1. Cookies

We use cookies to distinguish you from other users of the Website. This helps us to provide you with a good experience when you browse our Website and also allows us to improve our Website. For detailed information on these cookies, the way we use them and the purposes for which we use them, please see our cookie policy https://recognitionhealth.com/cookies-policy/.

    1. Where We Store And Process Your Information
      1. The data that we collect from you may be transferred to, and stored at, a destination outside the European Economic Area (“EEA“).  It may also be processed by staff operating outside the EEA who work for us or for one of our suppliers or affiliates.  Such staff maybe engaged in, among other things, the processing of your payment details and the provision of support services. By submitting your personal data, you agree to this transfer, storing or processing. We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this Privacy Policy. We will implement the following safeguards for personal data transfers outside the EEA:
        1. personal data will only be transferred to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission;
        2. we will use specific contract clauses approved by the European Commission, which give personal data the same protection it has in Europe; or
        3. when we use providers based in the US, we will 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.
    1. Your Consent And Changes To This Privacy Policy
      1. By submitting any personal data (including, without limitation, your payment details) to us you consent to the use of information as set out in this Privacy Policy.  We reserve the right to amend or modify this Privacy Policy, and if we do, we will post the changes on our Website. If we make any significant changes in the way we treat your personal data, we will make this clear on our Website or by contacting you directly. It is your responsibility to check the Privacy Policy every time you submit information to us. Your use of the Website will signify that you agree to any such changes.
      2. In the event that the purposes for which we process personal data changes, whereby a new, additional purpose for processing is not compatible or similar to the originally specified purposes, we will contact you as soon as practicable to seek your consent.
    2. Use Of Your Personal Data Submitted To Other Apps
      1. We are not responsible for the privacy policies and practices of other apps or websites, even if you accessed the third party app using links from our Website or by means of our services.
      2. We recommend that you check the policy of each app you visit and contact the owner or operator of such app if you have concerns or questions.
    3. Data Retention
      1. We will only retain your personal data for as long as you have consented to it, or when it is necessary for us to provide you with our services or fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, reporting or regulatory requirements. For instance, by law, we must keep basic information about our customers (including contact, identity, financial and transaction data) typically for 6 (six) years after they cease being customers for tax purposes.
      2. 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.
      3. In some circumstances you can ask us to delete your personal data.
      4. In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.
    4. Further Information
      1. For complaints or for requesting further information from us on data protection and privacy or any requests concerning your personal data e-mail us at compliance@re-cognitionhealth.com.
      2. You can also contact the Information Commissioner’s Office if you have a complaint regarding your personal data that we cannot resolve. Their website address is: https://www.gov.uk/government/organisations/information-commissioner-s-office