About us – this notice explains how your information may be held and used by companies that form part of NHC Holdings limited that also trades as Niagara Healthcare Ltd, Adjustamatic Beds Limited, Niagara Therapy Limited, Vibrant Medical Limited, Varimatic, Canissage and Niagara Equissage Pulse to cover its range of products and services.
Our Commitment to Protecting Your Information – your privacy is important to us. This policy explains our practices and informs you of the choices you can make about the way your information is collected and used. This statement will be supplemented by ‘specific to customer’ privacy notices when needed.
The personal information we hold about you:
Basic contact information for the purposes of communicating with you. Typically, this will be names, addresses, telephone numbers and an email address;
Credit or debit card details when taking payment, but these details are not stored on our systems;
Information that relates to your health which is necessary to ensure our products are suitable to your needs. The law provides this information as being in a special category because of its sensitivity to you. We can only collect this information where you have given us explicit consent.
Where we collect your personal data from - we collect information about you in the following ways:
Electronically from our tablet when you complete a healthcare questionnaire and when you place an order;
When you make an enquiry for our products or services. Collection starts at the point of the initial enquiry, either through the web page contact form, or on the telephone to one of our employees;
The phone number you are calling from (if it is not withheld).
When you opt in to our direct marketing materials or respond to our advertising campaigns;
When you participate in one of our competitions;
When you voluntarily complete a consumer survey or an online survey through a third party website;
When you complete a telephone survey through one of our carefully selected data providers that have spoken to you;
When visiting one of our retail stores or one of our exhibition stands;
through a carer acting on your behalf where you are the intended recipient of a product or service;
From an existing customer who has referred you to us and with whom we have checked that we have your valid consent for us to contact you;
Through a third party telephone answering service called JAM who answer telephone calls on our behalf which are made outside of our normal opening hours. JAM only collect the personal information from you which allows us to process your request, including your name, address, email address and phone number. They do not store any of your personal details on their systems.
Why we need your personal information and what we use it for - Data Protection legislation requires us to have one of more of the following reasons for using your information:
Contract performance – as our customer, the information we need to process your order and deliver your goods or service e.g. we will need to hold your personal contact details for warranty or service purposes and for our staff to continue to communicate with you throughout our relationship.
Legitimate interests – with regards to prospective customers, where we have received your personal data from one of our carefully selected data providers and rely on legitimate interests to contact you for the purposes of introducing you to our products that we believe may be of interest to you based on the answers to the telephone survey you completed, or where we have a legitimate interests to respond to your general enquiries that you make to us and to contact you. This occurs where, on balance, the benefits of doing so are not outweighed by your interests or legal rights. Upon our initial contact with you, we will inform you of your right to object to such processing before proceeding further, including profiling to the extent that it is related to such marketing activity.
Identifying other products and services you may find useful – the range of products and services we offer is developing all the time. We have an interest in knowing what our customers do and don’t like so we can offer better products and services and inform you of any new developments that we think may interest you, but only where we are permitted to do so. The lawful basis we rely on to do this is legitimate interests and consent.
Profiling Information - we may analyse and combine the information collected to understand your interests and preferences so we can provide appropriate products and services to you.
Consent – in some cases we obtain your consent to use your information in a particular way or where the law requires consent to be obtained e.g. where you have given your consent to one of our data providers to be contacted by us for the purposes of introducing you to our products and services that we believe will be of interest to you based on the answers to surveys you have completed and where you have given your consent directly to us to contact you and process your personal data for other purposes.
For marketing activity, we will ask for your consent to use your information. We will not send you irrelevant or excessive information. We will only contact you in the ways you have told us are acceptable to you. If you have told us that you do not want to receive marketing information, then we will not send this to you. You can also opt in to, or out of, receiving marketing information at any time after our initial contact by contacting our Privacy Officer.
Whenever ‘consent’ is the only reason for us using the information you have the right to change your mind. You also have the right to withdraw your consent at any time. However, where we have formed a contract with you, we may need to process information relating to your health in order to ensure the suitability of our products and keep informed of any changing health needs. We will keep this information accurate and up-to-date.
Who we share information with – we treat the information we hold about you as confidential. We also share your personal data with the following third parties who provide elements of services for us. They are also required to keep your information confidential, safe and secure:
Other companies who provide products and services which may be of benefit to you, but only with your permission;
Our sales representatives (who become data processors) working on our behalf. We have a contract in place with our sales representatives. This means that they cannot do anything with your personal information other than share this with us. They will not share your information with anyone else;
An email distribution company called Dotmailer Ltd who send you marketing emails on our behalf;
A third-party data processing company called Harvest Your Data used to complete orders by our sales representatives and also to collect feedback on our service delivery;
A third-party mailing house for the purposes of communicating with our customers by post;
Courier companies for the delivery of products when necessary;
Our data providers to fulfil any requests made by you to be provided with your personal data;
With one of our finance providers for the purposes of financing your order;
We will process your data in the European Economic Area (EEA) and the USA. First line personal data processing takes place in the UK. We also use a cloud service provided by Harvest Your Data that is based in the USA. It should be noted that no personal data is stored on any of our website servers.
How long we hold information - we retain information for no longer than is necessary to manage your relationship with us. This will mean that we will continue to hold some information for a period of time after our relationship has ended. There are some circumstances where we must cooperate with and help other regulatory bodies in handling complaints or investigations. This may lead to sharing personal information only if it is relevant. Also, for these and monitoring purposes, we audio record calls, our staff may also listen in or listen to your call for training and quality assurance purposes, or to resolve any problems or complaints you may have.
In these situations, we’ll satisfy ourselves that we have a lawful basis on which to share the information and keep appropriate documentation to support our decision making.
At the end of retention - we will either destroy or delete or anonymise your personal data and any associated and relevant documentation. If it is technically impractical to delete electronic copies of personal data, it will put it beyond operational use.
Your legal rights relating to your information – the General Data Protection Regulation defines your legal rights we have set out below:
Access to information – you have the right to ask whether or not we hold information about you and what that information is, why we are holding it and the ways it is being used. You are entitled to a copy of this information.
Rectification of information – we always want to ensure the information we hold about you is up to date and accurate. We will update any out of date information straight away and correct if this is necessary, please let us know by contacting our Privacy Officer.
Erasure of Information – you have the right to ask us to erase or delete information where you consider there is no longer a justification for us holding it. If you feel this applies to your information then please contact us. This may be because the information is no longer needed for the reason we collected it, or we held and used the information based only on your consent, which you have now withdrawn. There may also be a legal obligation on us to erase the information.
Portability of information – you have the right to receive some of your information from us in a machine readable format.
Objecting to us using your information - we have informed you about the ways in which we use the information we hold.
Where we have told you that any use of that information is based on ‘legitimate interest’, you can raise an objection to that use. When you make an objection we will respond to you in one month. We will stop using the information in this way unless we have a legal justification for continuing to use it which we will explain to you.
You can always simply opt out of receiving marketing communications at any time. Please contact our Privacy Officer.
Restricting some uses of information – in some situations you have a right to block or limit the use of information by us. This may arise if you have challenged the accuracy of the information we hold and we are checking this, or you have objected to a use of information.
You can contact us at any time to discuss how we hold and use your information and your rights. You can also contact our Privacy Officer for further information and to request these rights. Please be aware that we will need to confirm your identity before responding fully. Where it is necessary, you will be asked for proof of your identity so that we will be able to proceed with your request.
Other websites - where we provide links to websites of other organisations, this privacy notice does not cover how that organisation processes personal information. We encourage you to read the privacy notice on the other websites you visit.
Further details on your rights can be found on the Information Commissioner’s Office (ICO) website. Please visit www.ico.org.uk