Henley Hearing Care
This Website (http://www.henleyhearingcare.co.uk) is owned and operated by Henley Hearing Care.
This Policy explains how we collect and use your information. In this Policy, “we”, “us” and “our” means Henley Hearing Care.
We may change this Policy from time to time so please check back when you use our services to make sure that you have seen the most up to date version.
If you have any questions about this Policy, or would like to exercise your rights, you can email our Data Protection Officer at email@example.com or telephone us at 01491 576927.
Who we are?
Henley Hearing Care is a trading name of SLM Agency Limited, a private limited company incorporated in England and Wales (Company number 09279274), with a registered office at 69 Clifton Street, Lytham St Annes, FY8 5ER and a branch at 28 Hart Street, Henley on Thames, RG9 2AU.
We are registered with the Information Commissioner’s Office (ICO) as a data controller in the United Kingdom, with registration number ZA074024. You can find out more about our registration with the ICO by visiting the ICO’s website.
When do we collect information about you?
Some of the information we collect about you can be used to identify you. This type of information is defined as “Personal Data” under the UK Data Protection Act 1998 and, from 25 May 2018, the EU General Data Protection Regulation (EU) 2016/679. In this Policy we use the words “Personal Information” to talk about your Personal Data.
We collect your Personal Information:
- when you make enquiries through our Website form or request a Free Hearing Information Brochure
- when you visit our Website and cookies are placed on your computer;
- when you make enquiries via the press;
- when you email, call us or write to us, visit our branches or provide us with information in any other way.
- when a relative or friend gives us information about you during discussions about such person’s hearing, or where an individual has indicated that he or she would like you to accompany them to a hearing assessment, hearing aid fitting or service appointment.
We also check your contact information against lists which we receive from third party service providers, or from public sources such as the electoral roll, to make sure that we have recorded your contact details correctly. This helps us to keep our records up to date and ensure that we can provide you with relevant information and services.
What types of Personal Information do we collect and process?
We process the following kinds of personal information if you provide it to us:
(a) Information about you, including your name, title, postal address, telephone number and email address, and, if you make a purchase with us, credit or debit card details;
(b) Information about your use of our branch
(c) Information you provide to us during communications you have with us and with our staff, whether by email, post, telephone, in person or through our Website, for example comments or queries about the products and services we provide.
(d) If you register for a hearing test with us, answer our online hearing test questions; give us information about your hearing in store or, over the telephone, or purchase one of our hearing aids, you may give us sensitive information about your health. This could include, for example, whether you currently use a hearing aid and if so what type of hearing aid, information about your hearing condition and, where appropriate, your family history. We will only ever collect and use this kind of information with your consent.
(e) If you decide to purchase one of our products using credit, we will pass your information to our preferred lender, Hitachi Capital, who will assess your suitability for credit and progress your application accordingly.
Each time you visit the Website we may automatically gather the following information:
(f) technical information about your computer such as domain name, browser type and version, operating system and platform, IP address, cookie information and time zone setting; and
(g) information about your visit including the full Uniform Resource Locators (URL) clickstream to, through and from the Website (including date and time), what web pages you visited on the Website and how long you spent on each page, page interaction information (such as scrolling, clicks and mouse-overs), page response times, download errors, traffic data, location data, weblogs, history of resources accessed on the Website, methods used to browse away from the page and information on what websites you visited before accessing the Website.
When a friend or relative gives us information about you which could include, for example, your name, your relationship to the individual and your comments or reactions to that individual’s hearing.
When we collect information about you it is stored in our customer relationship management system. Within this system, we categorise loosely based on information such as postcodes, age, sale details and requirements, which then affects:
(a) How often we contact you; and
(b) The content of our messages and the way that they are written.
This automatic profiling does not disadvantage you in any way: our aim is to make our communications with you as relevant and as tailored as possible, to provide you with a better service. You have the right to opt out of marketing communications at any time. We will always respect your wishes.
Why do we collect and use your information and what are our lawful grounds for doing so?
We use your Personal Information for the following purposes:
(a) To process and respond to requests, enquiries and complaints received by you, in accordance with our legitimate interest to provide our customers with a responsive service.
(b) To provide services and products requested and/or purchased by you or an attorney on your behalf and to communicate with you or your attorney about such services and/or products. We do this as necessary in order to carry out a contract with you, for the purpose of our legitimate interest to operate a business which offers products and services related to hearing.
(c) To update our records and for audit purposes, in accordance with our legitimate interest to do so.
(d) To prevent or detect fraud, in accordance with our legitimate interest to do so.
(e) Where legally required or where it is in our legitimate interests to do so, to comply with requests from law enforcement and regulatory authorities.
(f) To carry out customer satisfaction research, for our legitimate interest to aim to enhance, modify, personalise and improve our services and communications for the benefit of our customers.
(g) To recommend products and services we think you will be interested in. For this we use our legitimate interest to carry out direct marketing to our customers or, where we use your health data or electronic methods such as email, with your consent.
(h) To enable our service providers to carry out any of the purposes set out above on our behalf. Service providers include, for example, call centre operators, website developers, cloud storage providers, mailing house, media agencies. For this processing, we use our legitimate interest to run our business as efficiently as possible. Our service providers will always be under a duty to keep your Personal Information safe and confidential.
How we share your Personal Information
We share your Personal Information with companies within our corporate group. We will only share your Personal Information with unrelated third parties as described within this Policy.
We may share your Personal Information with our service providers for tasks such as:
(a) assisting us with administering or troubleshooting our Website;
(b) assisting us with the supply or design of our products or with our business administration;
(c) assisting us with our marketing campaigns;
(d) providing us with electronic or physical storage services or systems.
We will only share your information in these circumstances if it is necessary to do so in order for our service providers to perform the service for us. These companies are not authorised to keep or use your Personal Information for any other purpose.
If we sell all or any part of our business, the parties which buy it may have access to your Personal Information.
How long do we keep your Personal Information?
We hold your personal information for as long as we need to for legitimate legal or business reasons, including to comply with any regulatory obligations.
We aim to keep your Personal Information secure. In order to prevent unauthorised access or disclosure, we use appropriate physical, technical and organisational measures to keep the Personal Information we collect secure. Our service providers are required to do the same.
Unfortunately, transmission of information via the internet is not completely secure.
Although we will do our best to protect your Personal Information once we receive it, we cannot guarantee the security of your Personal Information transmitted to our Website; any transmission is at your own risk. Once we have received your Personal Information, we will use strict procedures and security features to try to prevent unauthorised access or loss.
Links to other websites
The Website may contain links to the websites of other companies and organisations which may be of interest (“Third Party Sites”).
Once you have used these links to leave our Website, we do not have any control over how other companies use your Personal Information collected through such Third Party Sites. We cannot therefore be responsible or liable for the protection and privacy of any Personal Information which you provide whilst visiting them.
Third Party Sites are governed by their own privacy policies. Please be careful when accessing Third Party Sites and make sure that you check the applicable privacy policies.
Controlling your Personal Information
You have the right to ask us not to process your Personal Information for marketing purposes.
We will usually inform you (before collecting your data) if we intend to use your data for such purposes, or if we intend to disclose your information to any third party for their own marketing purposes.
You can ask us to stop sending you marketing communications at any time by contacting us at firstname.lastname@example.org or 01491 576927.
We will never sell your Personal Information, and we will only share your Personal Information as described in this Policy.
If we are processing your Personal Information on the basis of your consent, you have the right to withdraw your consent at any time.
Access to your Personal Information, deletion, restriction, rectification and transfer
You have the right to request details (and a copy of) the Personal Information we hold about you and to ask us to delete, restrict, correct (rectify) or transfer (port) your Personal Information. Our response will depend on which legal grounds we are using to process the data in question, and the circumstances of the particular processing. You can find out more about your rights by viewing guidance from the Information Commissioner’s Office.
You can exercise your rights by sending us a written request to 28 Hart Street, Henley on Thames, RG9 2AU or by emailing us at email@example.com.
With each request please include identification information (such as a copy of your passport or driving licence and a recent utility bill).
Complaints to the ICO
If you are unhappy with us, our service, or with the way that we treat your Personal Information, please contact us and we will work with you to resolve your issue.
You also have the right to contact the UK Data Protection Authority, the Information Commissioner’s Office (ICO). You can contact the ICO through its website www.ico.org. You can also call the ICO helpline from the UK on 0303 123 1113, or +44 1625 545 745 if calling from outside of the UK.
If you have any questions on this Policy, or would like to exercise your rights, you can contact our Data Protection Officer, Angie Walker by email at firstname.lastname@example.org, by telephone on 01491 57692, or by post at:
Angie Walker, Data Protection Officer
Henley Hearing Care
28 Hart Street
Henley on Thames