Introduction

Thank you for reading our privacy notice. We respect your privacy and are committed to protecting your personal data. This privacy notice will inform you as to how we look after your personal data 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. Alternatively, you can download a pdf version of the notice here. Please also use the Glossary to understand the meaning of some of the terms used in this privacy notice.

• IMPORTANT INFORMATION AND WHO WE ARE
• THE DATA WE COLLECT ABOUT YOU
• HOW IS YOUR PERSONAL DATA COLLECTED
• HOW WE USE YOUR PERSONAL DATA
• SHARING YOUR DATA WITH OTHERS
  • INTERNATIONAL TRANSFERS
• DATA SECURITY
• DATA RETENTION
• YOUR LEGAL RIGHTS
• GLOSSARY

1. IMPORTANT INFORMATION AND WHO WE ARE

Purpose of this privacy notice

This privacy notice aims to give you information on how we collect and process your personal data, including any data you may provide to us directly via our website or otherwise. It is important that you read this privacy notice together with any other privacy notice, fair processing notice, or privacy policy 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.

Controller

The Mather Group Limited is the controller and responsible for your personal data (collectively referred to as the Company, "we", "us" or "our" in this privacy notice). We have appointed a data privacy manager 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 data privacy manager using the details set out below.

Contact details

Our full details are:

• Full name of legal entity: The Mather Group Limited, a company incorporated in England and Wales with company registration number 12587276 whose registered offices are located at 127 Zellig Gibb Street, Birmingham B9 4AT.
• Name or title of data privacy manager: [NAME]
• Email address: [ADDRESS]
• Telephone number: [NUMBER]

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

This version was last updated on [DATE], 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.

Third-party links

Our 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. When you leave our website, we encourage you to read the privacy notice of every website you visit.

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, last name, marital status, title, date of birth, gender, sex, nationality, and national insurance number.

• Contact Data

  Includes physical address, email address, and telephone numbers.

• Special Categories Data

  Includes racial and ethnic origin, religion, biometric data, and health/medical records.

• Financial Data

  Includes 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 our website.

• Profile Data

  Includes your username and password, profile picture, feedback, and survey responses.

• Usage Data

  Includes information about how you use our website services.

• Marketing and Communications Data

  Includes your preferences in receiving marketing from us and 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.

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 trying to enter into 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:
    • avail of 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

  • As you interact with our website, we may automatically collect Technical Data about your equipment, browsing actions, and patterns. We collect this personal data by using cookies, server logs, and other similar technologies. We may also receive Technical Data about you if you visit other websites employing our cookies.

• Third parties or publicly available sources

  • We may receive personal data about you from various third parties and public sources.
  • Technical Data from the following parties:
    • analytics providers;
    • advertising networks; and
    • search information providers.
  • Contact, Financial, and Transaction Data from providers of technical, payment, and delivery services.
  • Identity and Contact Data from data brokers or aggregators.
  • Identity and Contact Data from publicly available sources such as Companies House and the Electoral Register.

4. HOW WE USE YOUR PERSONAL DATA

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

• Where we need to perform the contract we are about to enter into or have entered into 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 [LINK].

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 ground depending on the specific purpose for which we are using your data. Please contact us [LINK] if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.

How and why we use your personal data—Special category personal data

Certain personal data we collect is treated as a special category to which additional protections apply under data protection law:

• Personal data revealing racial or ethnic origin;
• Biometric data (when used to uniquely identify an individual);
• Data concerning health, or sexual orientation.

Where we process special category personal data, we will also ensure we are permitted to do so under data protection laws, e.g.:

• We have your explicit consent;
• The processing is necessary to protect your (or someone else’s) vital interests where you are physically or legally incapable of giving consent; or
• The processing is necessary to establish, exercise or defend legal claims.

Marketing

We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising.

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 (we call this marketing).

You will receive marketing communications from us if you have requested information from us or purchased goods or services from us or if you provided us with your details when you entered a competition or registered for a promotion and, in each case, you have not opted out of receiving that marketing.

Third-party marketing

We will get your express opt-in consent before we share your personal data with any company outside our group of companies for marketing purposes.

Opting out

You can ask us or third parties to stop sending you marketing messages at any time by contacting us [LINK] at any time.

Where you opt out of receiving marketing messages, this will not apply to personal data provided to us as a result of a product/service purchase, warranty registration, product/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 get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us [LINK].

If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis that 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. SHARING YOUR DATA WITH OTHERS

We may share your personal data with members of our corporate groups and partner organizations to help deliver services to you.

We may share your personal data with companies we have hired to provide services on our behalf, including those who act as data processors on our behalf, acting strictly under contract in accordance with data protection legislation. Those data processors are bound by strict confidentiality and data security provisions, and they can only use your data in the ways specified by us.

We may share aggregated data with commercial partners that does not personally identify you, but which shows general trends, for example, the number of users of the service.

We will, where necessary for the provision or funding of treatment or care, share your information with your insurer and with other health and social care providers. For example, your NHS GP and other NHS bodies, specialist referral services, therapists, pharmacists, hospitals, accident and emergency services, pathology service providers, diagnosis centers chosen by you for the purpose of imaging requests, and other health and care bodies. This may include sharing information with such services for safeguarding purposes in accordance with our legal obligations.

We may share your information with relevant policyholders (including your employer if you're covered under a group scheme), funders arranging services on your behalf, and people acting on your behalf (for example, brokers and other agents).

We may preserve or disclose information about you to comply with a law, regulation, legal process, or governmental request; to assert legal rights or defend against legal claims; or to prevent, detect, or investigate illegal activity, fraud, abuse, violations of our terms, or threats to the security of our services or the physical safety of any person.

We may have to share your personal data with the parties set out below for the purposes set out in the table in paragraph 4 above.

• External Third Parties as set out in the Glossary [LINK].

5.1 INTERNATIONAL TRANSFERS

Some of our external third parties may be based outside the UK and the European Economic Area (EEA), so the processing of your personal data may involve a transfer of data outside the UK and EEA.

Whenever we transfer your personal data out of the UK or the EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

• We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission. For further details, see European Commission: Adequacy of the protection of personal data in non-EU countries.
• Where we use certain service providers, we may use specific contracts approved by the European Commission that give personal data the same protection it has in Europe. For further details, see European Commission: Model contracts for the transfer of personal data to third countries.

6. DATA SECURITY

We have put in place appropriate security measures to prevent your personal data from being altered or disclosed, accidentally lost, used, or accessed in an unauthorized way. In addition, we limit access to your personal data to those employees, agents, contractors, and other third parties who have a business need to know. They will only process your personal data on our instructions, and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

This website uses Google Analytics, a web analysis service provided by Google. Google utilizes the data collected to track and examine the use of [insert your website address] to prepare reports on its activities and share them with other Google services. Google may use the data collected to contextualize and personalize the ads of its advertising network. The personal data collected are cookies and usage data. The place of processing is the United States of America. Your rights with respect to the data being collected by Google are set out in their privacy policy here.

7. DATA RETENTION

We will retain your personal data, including medical records, in accordance with national best practice, particularly the advice by the Department of Health (2006) Records management: NHS code of practice, and summary guidelines issued by the British Medical Association. In general, we will hold your personal data indefinitely or until the purpose for which we collected it, including satisfying any legal, accounting, or reporting requirements, has been fulfilled, or in the event that we receive a request from you to delete it.

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 unauthorized 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.

By law, we have to keep certain information about our patients for a minimum period. This includes:

• Contact, Identity, Special Categories for at least 11 years for adults and for children up to 11 years or up to their 25th birthday, whichever is longer.
• GP records: 10 years after death or after the patient has permanently left the country unless the patient remains in the EU. In the case of a child, if the illness or death could have potential relevance to adult conditions or have genetic implications for the family of the deceased, the advice of the clinicians should be sought as to whether to retain the records for a longer period.
• Maternity records: 25 years after the birth of the last child.
• Records relating to persons receiving treatment for a mental disorder within the meaning of the mental health legislation: 20 years after the date of the last contact or 10 years after the patient's death, if sooner.
• Financial and Transaction Data: at least six years after they cease being a patient for tax purposes.

Details of other retention periods for different aspects of your personal data can be requested by contacting us [LINK].

In some circumstances, you can ask us to delete your data, and 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.

8. YOUR LEGAL RIGHTS

Under certain circumstances, you have rights under data protection laws in relation to your personal data. If you wish to exercise or find out more about any of the rights set out below, please email [Insert email address] using the below within the subject headline:

• Request access to your personal data.
• Request correction of your personal data.
• Request erasure of your personal data.
• Object to the processing of your personal data.
• Request restriction of processing your personal data.
• Request the transfer of your personal data.
• Right to withdraw consent.

No fee usually required

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive, or excessive. Alternatively, we may refuse to comply with your request in these circumstances.

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 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 if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

9. GLOSSARY

LAWFUL BASIS

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 [LINK].

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.

THIRD PARTIES

External Third Parties

• Service providers who may act as processors based inside or outside the EU and who provide IT, system administration, and other services.
• Professional advisers who may act as processors, including lawyers, bankers, auditors, and insurers based inside or outside the EU, who provide consultancy, banking, legal, insurance, and accounting services.
• HM Revenue & Customs, regulators, and other authorities who may act as processors based inside or outside the EU, who require reporting of processing activities in certain circumstances.

YOUR LEGAL RIGHTS

You have the right to:

• Request access to your personal data (commonly known as a "data subject access request"). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
• Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
• Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully, or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request for erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
• 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 which 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.
• 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: (a) if you want us to establish the data's accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) 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 (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
• 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 which you initially provided consent for us to use or where we used the information to perform a contract with you.
• Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. 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.