This is the privacy notice of I ,Alastair MacKinnon of Populi Therapy. In this document, "we", "our", or "us " refer to Populi Therapy. I am the registered data controller and my registered address is 3 Prospect Bank Crescent, Edinburgh EH6 7NW.
This notice informs you of our policy about all information that we record about you. It sets out the conditions under which we may process any information that we collect from you, or that you provide to us. It covers information that could identify you (“personal information”) and information that could not. In the context of the law and this notice, “process” means collect, store, transfer, use or otherwise act on information.
We regret that if there are one or more points below with which you are not happy, your only recourse is to leave our website immediately.
We take seriously the protection of your privacy and confidentiality. We understand that all our clients and visitors to our website are entitled to know that their personal data will not be used for any purpose unintended by them, and will not accidentally fall into the hands of a third party.
We undertake to preserve the confidentiality of all information you provide to us.
Our policy complies with UK law accordingly implemented, including that required by the EU General Data Protection Regulation (GDPR).
The law requires us to tell you about your rights and our obligations to you in regards to the processing and control of your personal data. We do this now, by requesting that you read the information provided at www.knowyourprivacyrights.org
Except as set out below, we do not share or disclose to a third party, any information collected through our website.
The bases on which we process information about you
The law requires us to determine under which of six defined bases we process different categories of your personal information, and to notify you of the basis for each category.
If a basis on which we process your personal information is no longer relevant then we shall immediately stop processing your data.
If the basis changes, then if required by law, we shall notify you of the change and of any new basis under which we have determined that we can continue to process your information.
Information we process because we have a contract with you
When you become our client, a contract is formed between you and us.
The service we provide to you as a client necessarily entails you providing us with personal information.
We process this information on the basis there is a contract between us, or that you have requested we use the information before we enter into a legal contract.
Additionally, we may aggregate this information generally to use it to provide class information, for example to monitor the performance of a particular service we provide. If we use it for this purpose, you as an individual will not be personally identifiable.
We shall continue to process this information until the contract between us ends or is terminated by either party under the terms of the contract.
Information we process with your consent
Through certain actions, when otherwise there is no contractual relationship between us, such as when you browse our website or ask us to provide you more information about our services, you provide your consent to us to process information that may be personal information.
Wherever possible, we aim to obtain your explicit consent to process this information.
Sometimes you might give your consent implicitly, such as when you write to us requesting a response.
Except where you have consented to our use of your information for a specific purpose, we do not use your information in any way that would identify you personally. We may aggregate it in a general way and use it to provide class information.
We continue to process your information on this basis until you withdraw your consent or it can be reasonably assumed that your consent no longer exists.
You may withdraw your consent at any time by writing to us at our registered address or by e-mail at [email protected] If you do so, we shall not be able to provide our services further.
Information we process for the purposes of legitimate interests
We may process information on the basis there is a legitimate interest, either to you or to us, of doing so.
Where we process your information on this basis, we do so after having given careful consideration to:
whether we could achieve the same objective by other means
whether processing (or not processing) might cause you harm
whether you would expect us to process your data, and whether you would, in the round, consider it reasonable to do so
For example, we may process your data on this basis for the purposes of:
record-keeping for the proper and necessary administration of our business
protecting and asserting your rights, our rights, or the rights of any other third party
insuring against or obtaining professional advice that is required to manage business risk
protecting your interests where we believe we have a duty to do so
Information we process because we have a legal obligation
We are subject to the law like everyone else. Sometimes, we must process your information in order to comply with a statutory/legal obligation.
For example, we may be required to give information to legal authorities if they so request or if they have the proper authorisation such as a search warrant or court order.
This may include your personal information.
Specific uses of information you provide to us
5.Information relating to your method of payment
If you choose to pay by debit or credit card , your debit or credit card number and other payment information is never taken by us either through our website or otherwise.
When you contact us, whether by telephone, by post, through our website or by e-mail, we collect the data you have given to us in order to reply with the information you need. Our website email contact form only captures an enquirer's name and email address along with IP address of the computer used to make the request. No cookies are captured.
We may keep personally identifiable information associated with your message, such as your name and email address so as to be able to track our communications with you to provide a high quality service.
When we receive a complaint, we record all the information you have given to us.
We use that information to resolve your complaint.
If your complaint reasonably requires us to contact some other person, we may decide to give to that other person some of the information contained in your complaint. We do this as infrequently as possible, but it is a matter for our sole discretion as to whether we do give information, and if we do, what that information is.
We may also compile statistics showing information obtained from this source to assess the level of service we provide, but not in a way that could identify you or any other person.
If you complain about any of the content on our website or in any leaflet, we shall investigate your complaint. If we feel it is justified or if we believe the law requires us to do so, we shall remove the content while we investigate.
If we think your complaint is vexatious or without any basis, we shall not correspond with you about it.
Use of information collected through automated systems when you visit our website
Cookies are small text files that are placed on your computer's hard drive by your web browser when you visit any website. They allow information gathered on one web page to be stored until it is needed for use on another, allowing a website to provide you with a personalised experience and the website owner with statistics about how you use the website so that it can be improved.
Some cookies may last for a defined period of time, such as one day or until you close your browser. Others last indefinitely.
Your web browser should allow you to delete any you choose. It also should allow you to prevent or limit their use.
Note that Social Media companies usually design cookies in a way that enable them to track your activity across multiple websites and this may be a reason you choose to disable cookies.
Taking Control of Your Cookies
You have the ability to accept or decline cookies by modifying the settings in your browser, however you may not be able to use all the interactive features of our site if cookies are disabled. To find out more about cookies, including how to see what cookies have been set and how to manage and delete them, visit www.aboutcookies.org.
9. Personal Identifiers from your browsing activity
Requests by your web browser to our servers for web pages and other content on our website are recorded.
We record information such as your geographical location, your Internet service provider and your IP address. We also record information about the software you are using to browse our website, such as the type of computer or device and the screen resolution.
We use this information in aggregate to assess the popularity of the webpages on our website and how we perform in providing content to you.
If combined with other information we know about you from previous visits, the data possibly could be used to identify you personally, even if you are not signed in to our website.
Access to your information
10. Access to your personal information
At any time you may review or update or request that we remove personally identifiable information that we hold about you. To obtain a copy of any information that is not provided on our website you may send us a request at [email protected]
After receiving the request, we will tell you when we expect to provide you with the information.
When we receive any request to access, edit or delete personal identifiable information we shall first take reasonable steps to verify your identity before granting you access or otherwise taking any action. This is important to safeguard your information.
If a dispute is not settled then we hope you will agree to attempt to resolve it by engaging in good faith with us in a process of mediation or arbitration.
If you are in any way dissatisfied about how we process your personal information, you have a right to lodge a complaint with the Information Commissioner's Office. This can be done at https://ico.org.uk/concerns/
Retention period for personal data
Except as otherwise mentioned in this privacy notice, we keep your personal information only for as long as required by us:
to provide you with the services you have requested;
to comply with other law, including for the period demanded by our tax authorities;
to support a claim or defence in court.
Compliance with the law
We may update this privacy notice from time to time as necessary. The terms that apply to you are those posted here on our website on the day you use our website. You may wish to print a copy for your records.