Transform respects your privacy and is committed to protecting your personal data. This privacy notice will inform you how we look after your personal data when you visit our website: transforminglives.co.uk (regardless of where you visit it from) and tell you about your privacy rights and how the law protects you.
This privacy notice is provided in a layered format so you can click through to the specific areas set out below. We have also provided a Glossary to assist with the understanding of the meaning of some of the terms used in this privacy notice.
1. [IMPORTANT INFORMATION AND WHO WE ARE]
2. [THE DATA WE COLLECT ABOUT YOU]
3. [HOW IS YOUR PERSONAL DATA COLLECTED]
4. [HOW WE USE YOUR PERSONAL DATA]
5. [DISCLOSURES OF YOUR PERSONAL DATA]
6. [INTERNATIONAL TRANSFERS]
7. [DATA SECURITY]
8. [DATA RETENTION]
9. [YOUR LEGAL RIGHTS]
1. IMPORTANT INFORMATION AND WHO WE ARE
Transform is committed to safeguarding the privacy of our website visitors and this policy sets out how we will treat your personal information. Our policy complies with UK law accordingly implemented including that required by the EU General Data Protection Regulation (GDPR).
TFHC Ltd entered administration on the 3rd July 2019. Transform Hospital Group Ltd (Transform) purchased the right to use the trading name “Transform” amongst other things. Transform assumed control over the database including but not limited to the usual personal data e.g. names, addresses, email addresses etc. Importantly it also includes the associated health-related data relevant to the surgery/treatment that the customer is undergoing or has undergone. Transform will be arranging cosmetic surgery and other treatments and procedures in the same way that TFHC ltd did it will be using the personal data within the database for the purposes for which it was originally collected and within the reasonable expectations of the customers.
The Transform privacy notice sets out the legal basis for processing special category health data gathered from TFHC ltd. Article 9 (2) exemption for processing the health data applies in this instance, as the processing falls within the Data Protection Act 2018 Schedule 1, Part 1, s 2 (1) and (2) (c), (d) and (f) processing for ‘Health and social care purposes’. Transform will ensure the processing of any data must be ‘necessary’ to fall within this exemption and will be targeted and proportionate.
TFHC Ltd’s Administrator’s transferring the data relied on the legal basis of legitimate interests for this data sharing i.e., it is necessary to share this information with Transform in order to preserve the business operations and services and it is in the best interests of the customers that the continuation of service is provided by Transform.
In relation to the special category personal data (i.e., the health data) for customers who are part-way through cosmetic or other treatment programmes, or who are within the scope of follow up aftercare following their initial consultation and treatment, the personal data will be shared with Transform on the legal bases of (i) performing a contract and (ii) legitimate interests and (iii) the ‘Health and social care purposes’ exemption mentioned above.
Where the personal data relates to customers who have completed their consultation/treatment and follow-up care and where there has been a reasonable lapse of time since they have been dealt with by TFHC ltd i.e., historic customer data, Transform will only access this data where it is; “necessary” to assist the patient with ongoing care, for other health-related reasons, requested for legal purposes or requested by the patient themselves.
PURPOSE OF THIS PRIVACY NOTICE
This privacy notice aims to give you information on how Transform collects and processes your personal data through your use of this website, including any data you may provide through this website when you sign up to our newsletter, purchase a product or service or take part in a competition.
This website is not intended for children and we do not knowingly collect data relating to children. The minimum age limit for viewing this website is at least 18 years of age.
It is important that you read this privacy notice together with any other privacy notice or fair processing notice we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy notice supplements the other notices and is not intended to override them.
The Transform cosmetic surgery group (TFHC Limited) is made up of different legal entities and who are owned by Aurelius. This privacy notice is issued on behalf of the Transform cosmetic surgery group so when we mention Transform, “we”, “us” or “our” in this privacy notice, we are referring to the relevant company in the Transform cosmetic surgery group responsible for processing your data. We will let you know which entity will be the controller for your data when you purchase a product or service with us.
TFHC Limited is the controller and responsible for this website.
We have appointed a Data Protection Officer (DPO), who is responsible for overseeing questions in relation to this privacy notice. If you have any questions about this privacy notice, including any requests to exercise your legal rights, please contact the DPO using the details set out below.
Our full details are:
Full name of legal entity: Transform Hospital Group Limited, which is a company registered in England and Wales under the company number 11932035 and whose registered address is Pines Hospital, 192 Altringham Road, Manchester, M22 4RZ.
DPO: Jeremy Rouch, Company Secretary.
Contact email address: [email protected]
Postal address: Transform, Pines Hospital, 192 Altrincham Road, Manchester, M22 4RZ.
Telephone number: 0330 053 9115
Opening Hours: The office opening hours are between 8.30am to 9 pm Monday to Sunday except for Christmas Day and we are therefore only able to respond to email and telephone enquiries during these times.
You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority 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.
CHANGES TO THE PRIVACY NOTICE AND YOUR DUTY TO INFORM US OF CHANGES CONCERNING YOUR PERSONAL DATA
This version was last updated on May 2018 and historic versions can be obtained by contacting us.
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.
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 and their website terms and conditions. When you leave our website, we encourage you to read the privacy notice of every website you visit.
CHANGES TO THIS PRIVACY STATEMENT
We reserve the right to update this privacy statement at any time and we will provide you with a new privacy statement when we make any substantial updates. We may also notify you in other ways from time to time about the processing of your personal information.
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, maiden name, surname, username or similar
identifier, marital status, title, date of birth and gender.
• Contact Data includes a billing address, delivery address, email address and telephone numbers.
• Financial Data includes bank account and payment card details.
• Transaction Data includes details about payments to and from you and other details of products and services you have purchased from us.
• 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 and other technology on the devices you use to access this website.
• Profile Data includes your username and password, purchases or orders made by you, your interests, preferences, feedback and survey responses.
• Usage Data includes information about how you use our website, products and services.
• Marketing and Communications Data includes your preferences in receiving marketing from us, our third parties and your communication preferences.
We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy notice.
We do collect Special Categories of Personal Data about you which includes information about your health, genetic and biometric data but only as required in order to offer you our products and services.
We do collect any information about criminal convictions and offences.
IF YOU FAIL TO PROVIDE PERSONAL DATA
Where we need to collect personal data by law or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are proposing to enter into a contract with you (for example, to provide you with goods or services). In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.
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, Contact and Financial Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
• make an enquiry about our products or services;
• create an account on our website;
• subscribe to our service or publications;
• request marketing to be sent to you;
• enter a competition, promotion or survey; or
• give us some feedback.
• Automated technologies or interactions.
• We use 3rd party providers registered with the ICO including, but not exclusive to, Edit Agency Limited (03624881) who will process some personal data, which has been collected on behalf of Transform. This is done where it is necessary to do so, when they manage the external 3rd party suppliers, where personal data was collected, with the intent to be delivered to Transform for us to contact the individual via personal data that was supplied. All 3rd party external suppliers are responsible to ensure that the data provided is valid, accurate and up to date as possible, and to avoid contact duplication. So that when Transform contact individuals, we are using the most up to date and accurate information possible, having already been partly verified by the 3rd party supplier. We insist when using a 3rd party supplier that they are appropriately registered with the ICO and capture the IP address of those supplying the data.
• Web beacons: We also include web beacons (also known as clear gifs) in our emails to track the success of our marketing campaigns. This means that if you open an email from us we can see which pages of the websites you visit. Our web beacons do not store additional information on your computer but by communicating with our cookies on your computer they can tell us when you have opened our email. If you object to web beacons, we recommend you follow the instructions for deleting existing cookies and disabling future cookies above. We will still know how many of our emails are opened and we will automatically receive your IP address, a unique identifier of your computer or other access device, but we will not identify you as an individual.
• Third parties or publicly available sources. We may receive personal data about you from various third parties:
• Technical Data from the following parties:
(a) analytics providers such as Google based outside the EU; they may provide us with special categories of personal data.
(b) advertising networks UK Bride & The Hospital Group based inside they may provide us with personal data and special categories of data.
4. HOW WE USE YOUR PERSONAL DATA
We will only use your personal data when we are lawfully permitted to do so. Most commonly, we will use your personal data in the following circumstances:
• Where we need to perform the contract, we are about to commence or have agreed with you.
• 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 or regulatory obligation.
Generally, we do not rely on consent as a legal basis for processing your personal data other than in relation to sending third-party 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.
Note that we may process your personal data for more than one lawful purpose depending on the specific purpose for which we are using your data. Please Contact us if you need details about the specific legal basis we are relying on to process your personal data where more than one ground has been set out in the table below.
LAWFUL BASIS FOR PROCESSING INCLUDING BASIS OF LEGITIMATE INTEREST
To respond to your enquiry or request for a consultation:
(a) Necessary steps to enter into a contract with you
(b) Necessary for our legitimate interests (to contact individuals who have made an enquiry or requested a consultation
To provide you with our products or services:
(a) Performance of a contract with you
(b) Necessary for our legitimate interests
To manage our relationship with you which will include:
(b) Asking you to leave a review or take a survey
(a) Performance of a contract with you
(b) Necessary to comply with a legal obligation
(c) Necessary for our legitimate interests (to keep our records updated and to study how individuals use our products/services)
To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data):
(a) 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)
(b) Necessary to comply with a legal obligation
To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you:
Necessary for our legitimate interests (to study how customers use our products/services, to develop them, 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:
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)
To make suggestions and recommendations to you about goods or services that may be of interest to you:
Necessary for our legitimate interests (to develop our products/services and grow our business)
The lawful basis for processing data in accordance with GDPR includes Consent of the Data Subject, Contractual Necessity, Compliance with a legal obligation, Vital Interests, Public Interest, Legitimate Interest, Explicit Consent, Employment Law, Charity or not for Profit Bodies, Data Manifestly made public by the data subject, Legal Claims, Reason of Substantial Public Interest, Medical Diagnosis and Treatment, Public Health and Historical, Statistical and Scientific purposes.
We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising. We have established the following personal data control mechanisms: you may unsubscribe from marketing emails at any time by clicking on the unsubscribe link on the email, you can contact us via telephone 0330 053 9115, email us at [email protected] write to us at: Marketing Department, The Pines Hospital, 192 Altrincham Road, Manchester, M22 4RZ or send us a message via our website contact page. You can unsubscribe to our marketing via the email unsubscribe link or by contacting us directly. The General Data Protection Regulations (GDPR) provides rights for individuals, the right to be informed, the right of access, the right to rectification, the right to erasure, the right to restrict processing, the right to data portability and the right to object. Please see our contact us page for further information on Subject Access Requests.
PROMOTIONAL OFFERS FROM US
We may use your Identity, Contact, Technical, Usage and Profile 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 for marketing purposes.
You will receive marketing communications from us if you have requested information from us or purchased goods or services from us and in each case, you have not opted out of receiving that marketing.
We will get your express opt-in consent before we share your personal data with any company outside the Transform group of companies for marketing purposes.
You can ask us or third parties to stop sending you marketing messages at any time by Contacting us.
Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a product or service purchase, warranty registration, product or service experience or other transactions.
CHANGE OF PURPOSE
We will only use your personal data for the purposes for which we collected it unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to obtain an explanation as to how the processing for the new purpose is compatible with the original purpose, please Contact us.
If we need to use your personal data for an unrelated purpose, we will notify you to obtain your consent and we will explain the legal basis which allows us to do so.
Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
5. DISCLOSURES OF YOUR PERSONAL DATA
We may have to share your personal data with the parties set out below:
• Service providers who provide IT and system administration services.
• Professional advisers including lawyers, auditors and insurers who provide consultancy, legal, insurance and accounting services.
• HM Revenue & Customs, 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 notice.
We require all third parties to respect the security of your personal data and to treat it in accordance with UK legislation. 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.
6. INTERNATIONAL TRANSFERS
We do not transfer your personal data outside the European Economic Area (EEA).
7. DATA SECURITY
We have put in place appropriate security measures and take reasonable precautions to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. Of course, data transmission over the internet is inherently insecure and we cannot guarantee the security of the data sent over the internet. We will store all personal information you provide on our secure servers.
We have put in place procedures to deal with any suspected personal data breach, a Data Breach Investigation Policy and we will notify you and any applicable regulator of a breach where we are legally required to do so.
The material on this website is protected by law including but not limited to UK copyright law. The copyright in the content of the Website is owned by Transform. Details of the Copyright, Designs and Patents Act 1988 can be found on the Office of Public Sector Information website: www.opsi.gov.uk. All trademarks are the property of Transform.
Service Availability and Limitation of Liability
We aim to ensure the continuous 24/7 availability of this website and its services. However, Transform accepts no responsibility for direct, indirect, special, incidental, consequential or punitive loss or damage caused by interruptions, delays or inability to use or access any part of the website, however, caused or under any circumstances, in respect of claims or damages. You understand and agree that Transform will not be liable for any direct, indirect, incidental, special, consequential or exemplary damages including but not limited to damages for any loss of profits, goodwill, use, data or other tangible losses (even in the event that we have been advised of the possibility of such damages), resulting from the use or inability of use of the Website Services, the unauthorised access to or alteration of your transmission of data, statements of conduct of any third party on the service or any other matter relating to the Service. Access to the site may be suspended temporarily and without notice in the case of system failure, maintenance or repair work beyond the company’s control. The office opening hours are between 8.30am to 9 pm Monday to Sunday except for Christmas Day and we are therefore only able to respond to email or telephone enquiries during these times.
8. DATA RETENTION
HOW LONG WILL YOU USE MY PERSONAL DATA FOR?
We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for 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.
Details of retention periods for different aspects of your personal data are available in our retention policy which you can request from us by Contacting us.
In some circumstances you can ask us to delete your data: see Request erasure below for further information.
In some circumstances, we may anonymize 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.
9. YOUR RIGHTS
Under certain circumstances by law, you have the right to:
· 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 valid reason or legal requirement 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.
· 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 the transfer (Data Portability) of your personal information to another party.
If you would like to review, verify, correct or request erasure of your personal information, object to the processing of your personal data or request that we transfer a copy of your personal information to another party, please email:
NO FEE FOR SUBJECT ACCESS REQUESTS
You will not be charged for submitting a Subject Access Request, in accordance with the General Data Protection Regulations 2018.
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 legitimate requests within one month. Occasionally it may take us longer than a month to respond if your request is particularly complex or you have made a number of requests. If there is a delay with in this case, we will notify you and keep you updated.
Your right to complain to the ICO
You also have the right to complain to the Information Commissioner’s Office (the “ICO”) if you are not satisfied with the way we use your information. You can contact the ICO by writing to Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF.
Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights 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). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by Contacting us.
Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.
Comply with a legal or regulatory obligation means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.
What’s a cookie?
A cookie is a small file of letters and numbers that we store on your browser or the hard drive of your computer if you agree. Cookies contain information that is transferred to your computer’s hard drive.
The cookies we use:
We use the following cookies:
• Strictly necessary cookies. These are cookies that are required for the operation of our website. They include, for example, cookies that enable you to log into secure areas of our website, use a shopping cart or make use of e-billing services.
• Analytical/performance cookies. They allow us to recognise and count the number of visitors and to see how visitors move around our website when they are using it. This helps us to improve the way our website works, for example, by ensuring that users are finding what they are looking for easily.
• Functionality cookies. These are used to recognise you when you return to our website. This enables us to personalise our content for you, greet you by name and remember your preferences (for example, your choice of language or region).
• Targeting cookies. These cookies record your visit to our website, the pages you have visited and the links you have followed. We will use this information to make our website and the advertising displayed on it more relevant to your interests. We may also share this information with third parties for this purpose.
You can find more information about the individual cookies we use and the purposes for which we use them in the table below.
We use third-party cookies:
You block cookies by activating the setting on your browser that allows you to refuse the setting of all or some cookies. However, if you use your browser settings to block all cookies (including essential cookies) you may not be able to access all or parts of our site.
Changing your cookie settings: