Introduction 

Welcome to CPPP UK Limited’s privacy policy. 

We respect your privacy and are committed to protecting your personal data. This privacy policy tells you how we look after your personal data whenever you engage with us, whether you are making an enquiry with us, are one of our patients or are visiting our website (regardless of where you visit it from) and sets out your privacy rights and how the law protects you. 

It is important that you read this privacy policy so that you are fully aware of how and why we are using your data.  

Important Information and Who We Are 

About us 

CPPP UK Limited is the controller of and is responsible for your personal data (referred to as "CPPP", "we", "us" or "our" in this privacy policy). 

We have appointed a data protection officer (DPO) who is responsible for overseeing questions in relation to this privacy policy. If you have any questions about this privacy policy, including any requests to exercise your legal rights, please contact the DPO using the details set out below. 

As a patient your treatment/procedure and consultations regarding them will be conducted by a registered medical practitioner. 

Contact details 

If you have any questions about this privacy policy or the processes we have in place to protect your privacy practices, please contact us/our DPO in the following ways: 

Full name of legal entity: CPPP UK Limited company number 15848046 

Email address: dpo@cppclinics.eu 

Complaints 

You have the right to make a complaint to the Information Commissioner’s Office (ICO), the UK regulator for data protection issues (www.ico.org.uk). However, before doing so please make sure you have first made your complaint to us or asked us for clarification if there is something you do not understand. The ICO will expect you to have done this before reviewing your complaint. If you would like to receive the form by post then please email us at the addresses above to provide details of your complaint.  

Changes to the privacy policy and your duty to inform us of changes 

We keep our privacy policy under regular review and may make changes to it from time to time.  

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 

This 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 policy of every website you visit. 

1. The Data We May Collect About You 

Throughout your relationship with us we may collect personal data from or about you. The type of information we collect depends on how and why you got in touch with us and the type of services we are providing to you.   

What is personal data?  

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 this can include your full-name (maiden name), username or similar identifier, marital status, title, date of birth and gender. This may also include your image (as captured in photographs or recordings we make of procedures/treatments for the purpose of delivering our services).  

• Contact Data this will include the information that we need to get in touch with you and includes your home address, email address and telephone numbers. 

• Financial Data may include bank account and payment card details. 

• Health if you chose to use our services then we will need to collect (and will create) certain information about your health and/or medical history. When you meet with one of our medical practitioners, they will determine the extent of health information they need to be able to provide services to you.  

• Special Category Data Your health information is known as Special Category Data. Special Category Data is a certain set of personal data to which additional protections apply under data protection law. To allow us to provide our services to you, we may collect other Special Category Data about you in addition to your Health Data, including information about your racial or ethnic origin. We set out below how we process your Special Category Data.  

• Technical Data if you view our website then we may collect details about your 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 this website. 

• Usage Data includes information about how you use our website. 

• Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences. 

1. How Do we Collect Your Personal Data? 

We use different methods to collect data from and about you including through: 

• Direct interactions. You may give us your Personal Data (including Special Category Data) by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you: 

• make enquiries with us via telephone/email/social media or our website; 

• request information (including marketing information) to be sent to you; 

• complete any medical history forms or consent forms;  

• engage or attend consultations with our staff and medical practitioners; or 

• give us feedback or contact us. 

• Automated technologies or interactions. As you interact with our website, we will 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. Please see our cookie policy CPP Europe | Premier Physician-Led Medical Aesthetic Clinics in Europe for further details. 

• Third parties or publicly available sources. In some circumstances we may receive your personal data from various third parties and public sources, examples are set out below: 

• other aesthetic clinics or healthcare providers - if you have been referred to us by another clinic or by a healthcare provider or if you are seeking a second opinion then we may receive relevant health records from that other provider - you have been asked to consent to this transfer of personal data depending on the circumstances; and 

• publicly available sources - this may assist with contact information or scheduling.    

1. How We Use Your Personal Data 

We are only allowed to use your personal data where the law allows us to.  

We set out further detail about the lawful grounds that we rely on in the table below, but in short, we use your personal data: 

• to perform our contract with you (including steps that we need to take to enter into the contract). 

• where it is necessary for us to provide health and medical treatment to you. In particular, we are unable to provide our services without having health and medical information about you. 

• you have given us your consent. 

• where it is necessary for our legitimate interests of providing a clinic.  

• where we need to comply with a legal obligation that we are subject to. 

Where we process special category data we have to have additional grounds on which to process the data. We will only process your special category data where one of those additional grounds exists.  

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 use your personal data, and the lawful grounds we rely on to do so.  

Note that we may process your personal data for more than one purpose or on more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us 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. 

It is sometimes necessary to share your personal data with third parties and we provide more information about this below. We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions. 

Your personal data will never be sold on to external parties or organisations for marketing purposes. 

Third Parties 

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions. 

We may share your data with third parties as set out below:  

• Our parent company and group companies. 

• Professional advisers acting as processors or joint controllers including lawyers, bankers, auditors and insurers based in the United Kingdom who provide consultancy, banking, legal, insurance and accounting services. 

• HM Revenue & Customs, regulators and other authorities acting as processors or joint controllers based in the United Kingdom who require reporting of processing activities in certain circumstances. 

• Those who regulate our services including the Care Quality Commission/Care Inspectorate Wales/Healthcare Improvement Scotland/Regulatory and Quality Improvement Authority. 

• Those who regulate our healthcare professionals, these bodies may include the General Medical Council, the Health and Care Professionals Council and the Nursing and Midwifery Council. 

• Those who provide services to us to assist us with the running of our business such as IT providers, payment service providers or marketing providers. They will only be able to see such data as is necessary for them to do their work.  

Third-party marketing 

We will get your express opt-in consent before we share your personal data with any third party for marketing purposes. We will never share any of your Special Category Data to a third-party for marketing purposes.  

Cookies 

You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly. For more information about the cookies we use, please see CPP Europe | Premier Physician-Led Medical Aesthetic Clinics in Europe.  

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. 

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. 

1. International Transfers 

We share your personal data with our parent company. This will involve transferring your personal data outside of the UK to our oversees offices in Switzerland, Ireland, Poland, Belgium, France, Spain, Germany, the Netherlands and the USA.  

Whenever we share your personal data outside of the UK to countries which have laws that do not provide the same level of protection as the UK, we will always ensure that a similar degree of protection is afforded to that data be ensuring that standard contractual clauses are put in place. 

All of our group companies have entered into a data sharing agreement containing the relevant standard contractual clauses required to ensure that the transfer is accordance with data laws.  

1. Data Security 

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. 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. 

1. Data Retention 

How long will you use my personal data for? 

We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements.  

We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you. 

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 unauthorised 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, regulatory, tax, accounting or other requirements. 

By law we have to keep basic information about our patients/clients including Contact, Identity, Financial and Transaction Data for six years after they cease being clients for tax purposes. 

We are also required to retain Health Data in compliance with our regulatory obligations / insurance obligations. 

In some circumstances you can ask us to delete your data: see below for further information. 

In some circumstances we will anonymise 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. 

1. Your Legal Rights 

You have rights under data protection laws in relation to your personal data.  

You have the right to: 

• Request access to your personal data (commonly known as a "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 in certain circumstances. 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 of 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) as the legal basis for that particular use of your data (including carrying out profiling based on our legitimate interests). In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your right to object. 

• You also have the absolute right to object any time to the processing of your personal data for direct marketing purposes (see the table above for details of how to object to receiving direct marketing communications). 

• 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 (see the table above for details of when we rely on your consent as the legal basis for using your 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. 

• Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in one of the following scenarios: 

• If you want us to establish the data's accuracy; 

• Where our use of the data is unlawful but you do not want us to erase it; 

• 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 

• You have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it. 

If you wish to exercise any of the rights set out above or have any other queries or concerns, please don't hesitate to contact us at dpo@cppclinics.eu 

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 could 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 you 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 could 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.