Privacy Notice
We appreciate your interest in our Privacy Policy. At W1 Anaesthesia, we take the protection of your data very seriously, and in the below we explain what data we collect when you use our website www.w1anaesthesia.co.uk and how it is used.
General Information
a) What law applies?
Our use of your Personal Data is subject to both the UK`s Data Protection Act (“DPA”) and the EU`s General Data Protection Regulation (“GDPR”), and of course we process your Personal Data accordingly.
b) What is Personal Data?
Personal Data is any information relating to personal or material circumstances that relates to an individual. This may include a name, date of birth, e-mail address, postal address, or telephone number but also online identifiers such as IP addresses or device ID`s.
c) What is Special Category Data?
Special Category Data means Personal Data that needs more protection because it is sensitive. This includes among others data concerning health and medical information. In order to lawfully process Special Category Data, it is necessary to consent to the processing.
d) What is processing?
"Processing" means any operation or set of operations which is performed upon Personal Data, whether or not by automatic means. The term is broad and covers virtually any handling of data.
e) Who is responsible for data processing?
The responsible party within the meaning of the DPA and the GDPR is W1 Anaesthesia of 4 Cavendish Square, London, W1G 0PG, United Kingdom (“W1 Anaesthesia“, “we”, “us”, or “our”).
If you have any questions about this policy or our data protection practices, please contact us using contact@w1anaesthesia.co.uk, call 020 7636 9155 or write to us at the above address.
f) What are the legal bases of processing?
In accordance with the DPA and the GDPR, we have to have at least one of the following legal bases to process your Personal Data:
● For the fulfilment of contractual obligations
o The purposes of the data processing are primarily based on the service we provide.
● Within the framework of our legitimate interests
Where necessary, we process your data beyond the actual performance of the contract in order to safeguard legitimate interests of us or third parties. Examples are:
o Ensuring IT security and IT operations,
o Measures for business management and further development of our services,
o Defence against third-party claims and enforcement of own claims.
● Based on your consent
o Insofar as you have given us your consent to process personal data for certain purposes.
g) Is there an obligation for me to provide data?
Within the scope of our business relationship, you are only required to provide personal data that is necessary for the establishment, implementation, and termination of a business relationship or that we are legally obliged to collect. Without this data, we will usually have to refuse to conclude the contract or will no longer be able to perform an existing contract and may have to terminate it.
Data we collect automatically
a) Log data
Each time you visit our website, our system automatically records the following data from the visiting device and stores it in a so-called log file: i) Name of the retrieved file, ii) date and time of the visit, iii) amount of data transferred, iv) message about successful retrieval, type of browser and version used, v) IP address (identification of the user's device), vi) Operating system of the visiting device, vii) Internet service provider of the visiting device, viii) website from which you access our website, and ix) which of our website pages you are accessing. The legal basis for processing is our legitimate interest.
b) Hosting
The hosting service used by us for the purpose of operating our website is Wix.com LTD. In doing so Wix processes inventory data, contact data, content data, usage data, meta data and communication data of customers, interested parties and visitors of our website and services, on the basis of our legitimate interests.
c) Content Management System
We also use the Content Management System (CMS) of Wix to publish and maintain the created and edited content and texts on our website. This means that all content and texts submitted to us is transferred to Wix. This represents a legitimate interest.
d) Use of cookies
We use so-called cookies on our website. Cookies are pieces of information that are transmitted from our web server or third-party web servers to your web browser and stored there for later retrieval. For further information on the Cookies we use, please refer to our Cookie Policy.
e) Google Maps
Our website uses Google Maps API to visually display geographical information. When using Google Maps, Google LLC also collects, processes and uses data about visitors' use of the map functions (You can find more information about data processing by Google in the Google privacy policy). The integration of Google Maps represents a legitimate interest.
Data we collect directly
a) Contacting us
In addition to your name, company name, and e-mail address, IP address or telephone number, if provided, we usually collect the context of your message which may also include certain Personal Data. The Personal Data collected when contacting us is to handle your request and the legal basis is both your consent and contract.
Please note:
As a rule, we do not require any Special Category Data in order to contact you. We ask you not to provide us with such information from the outset. If such information is relevant for making contact, we will process it together with your other data. Your data will not be used by us for automated decision-making or profiling, nor will it be passed on to third parties. Your data is processed by us or on our behalf.
b) Contractual services
We process the Personal Data involved in your use of our services in order to be able to provide our contractual services. This includes in particular our support, correspondence with you, invoicing, fulfilment of our contractual, accounting and tax obligations. The data processed includes the master data of our contractual partners (e.g., names and addresses), contact data (e.g., e-mail addresses and telephone numbers) as well as contractual data (e.g., services used, contents of the contract, contractual communication, names of contact persons), certain Special Category Data and financial data.
As a matter of principle, we do not process Special Category Data, unless they are part of a commissioned or contractual processing. Accordingly, the data is processed on the basis of fulfilling our contractual obligations, our legal obligations, your consent and your specific consent in relation to Special Category Data.
c) Administration, financial accounting, office organisation, contact management
We process data in the context of administrative tasks as well as organisation of our business, and compliance with legal obligations, such as archiving. In this regard, we process the same data that we process in the course of providing our contractual services. The processing bases are our legal obligations and our legitimate interest.
General Principles
a) Who receives my data?
Within W1 Anaesthesia, those that need your data to fulfil our contractual and legal obligations will receive access to it.
Processors used by us may also receive data for these purposes. These are companies in the categories of IT services, telecommunications, and marketing. Where we use processors to provide our services, we take appropriate legal precautions and corresponding technical and organisational measures to ensure the protection of personal data in accordance with the relevant legal provisions.
Data is only passed on to third parties within the framework of legal requirements. We only pass on users' data to third parties if this is necessary, for example, for contractual purposes or on the basis of legitimate interests in the economic and effective operation of our business or you have consented to the transfer of data.
b) How long will my data be stored?
As far as necessary, we process and store your personal data for the duration of our business relationship, which also includes, for example, the initiation and execution of a contract. In addition, we are subject to various storage and documentation obligations, which result from the minimum statutory retention periods and HMRC, among others. The retention and documentation periods specified there are two to 6 years.
c) How do we secure your data?
Our website uses SSL or TLS encryption to ensure the security of data processing and to protect the transmission of content or contact requests that you send to us. We have also implemented numerous security measures (“technical and organisational measures”) for example encryption or need to know access, to ensure the most complete protection of Personal Data processed through this website.
Nevertheless, internet-based data transmissions can always have security gaps, so that absolute protection cannot be guaranteed. And databases or data sets that include Personal Data may be breached inadvertently or through wrongful intrusion. Upon becoming aware of a data breach, we will notify all affected individuals whose Personal Data may have been compromised as expeditiously as possible after which the breach was discovered.
d) Is data transferred to a third country or to an international organisation?
We may transfer your Personal Data to other companies and/or staff members as necessary for the purposes described in this Privacy Policy. In order to provide adequate protection for your Personal Data when it is transferred, we have contractual arrangements regarding such transfers. We take all reasonable technical and organisational measures to protect the Personal Data we transfer.
e) Special Category Data
Unless specifically required when using our services and explicit consent is obtained for that service, we do not process special category data.
f) Minors
We do not request Personal Data from minors and children and do not knowingly collect such data or pass it on to third parties.
g) Automated decision-making
Automated decision-making is the process of making a decision by automated means without any human involvement. Automated decision-making including profiling does not take place.
h) Do Not Sell
We do not sell your Personal Data.
Your Rights and Privileges
a) Privacy rights
Under the DPA and GDPR, you can exercise the following rights:
● Right to information
● Right to rectification
● Right to object to processing
● Right to deletion
● Right to data portability
● Right of objection
● Right to withdraw consent
● Right to complain to a supervisory authority
● Right not to be subject to a decision based solely on automated processing.
If you have any questions about the nature of the Personal Data we hold about you, or if you wish to exercise any of your rights, please contact us.
b) Updating your information
If you believe that the information we hold about you is inaccurate or that we are no longer entitled to use it and want to request its rectification, deletion, or object to its processing, please do so by contacting us.
c) Withdrawing your consent
You can revoke consents you have given at any time by contacting us. The legality of the data processing carried out until the revocation remains unaffected by the revocation.
d) Access Request
In the event that you wish to make a Data Subject Access Request, you may inform us in writing of the same. We will respond to requests regarding access and correction as soon as reasonably possible. Should we not be able to respond to your request within thirty (30) days, we will tell you why and when we will be able to respond to your request. If we are unable to provide you with any Personal Data or to make a correction requested by you, we will tell you why.
e) Complaint to a supervisory authority
You have the right to complain about our processing of Personal Data to a supervisory authority responsible for data protection. The supervisory authority in the UK is: The Information Commissioner's Office (ICO) is located at Wycliffe House, Water Ln, Wilmslow SK9 5AF, UK www.ico.org.uk
Validity and questions
This Privacy Policy was last updated on Friday, 5th of January, 2024, and is the current and valid version. However, we want to point out that from time to time due to actual or legal changes a revision to this policy may be necessary. If you have any questions about this policy or our data protection practices, please contact us using contact@w1anaesthesia.co.uk, call 020 7636 9155 or write to us at the above address.