Privacy Policy
1. Introduction
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This Privacy Policy (together with our terms and conditions and any other documents referred to in it) describes the type of information that we collect from you ("you/your") through the use of our services ("Services"), or the use of our website www.rtnmentalhealthsolutions.com ("Website"), how that information may be used or disclosed by us and the safeguards we use to protect it.
Our Website and Services may contain links to third-party websites that are not covered by this Privacy Policy. We, therefore, ask you to review the privacy statements of other websites and applications to understand their information practices.
We have drafted this Privacy Policy to be as clear and concise as possible. Please read it carefully to understand our policies regarding your information and how we will treat it.
By using or accessing our Website or the Services, you agree to the collection, use and disclosure of information in accordance with this Privacy Policy. This Privacy Policy may change from time to time and your continued use of the Website or the Services is deemed to be acceptance of such changes, so please check periodically for updates.
Please check back regularly to keep informed of updates to this Privacy Policy. Please read this Privacy Policy carefully and ensure that you understand it. Your acceptance of our Privacy Policy is deemed to occur upon your first use of our Website. If you do not accept and agree with this Privacy Policy, you must stop using our Website immediately.
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. 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.
If you have any comments on this Privacy Policy please email them to enquiries@rtnmentalhealthsolutions.com.
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2. Who We Are
2.1 Here are our details:
- Our Website address is: www.rtnmentalhealthsolutions.com
- Our company name is: RTN Mental Health Solutions Limited
- Our trading name is: RTN Mental Health Solutions Limited
- Our registered address is: 71-75 Shelton Street, Covent Garden, London, WC2H 9JQ
- Our nominated Data Protection Officer is Graeme Scott, who can be contacted at graeme@rtnmentalhealthsolutions.com
2.2 We respect your right to privacy and will only process personal information about you or provided by you in accordance with the Data Protection Legislation which for the purposes of this Privacy Policy shall mean: (i) the retained EU law version of the General Data Protection Regulation ((EU) 2016/679) (UK GDPR), the Data Protection Act 2018 and any other national implementing laws, regulations and secondary legislation, as amended or updated from time to time, in the UK and then (ii) any successor legislation to the UK GDPR or the Data Protection Act 2018 and other applicable privacy laws.
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3. What We May Collect
3.1 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)
3.2 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, last name, username or similar identifier. When you
email, phone, live chat or otherwise, we may collect information such as your first
name, last name, email address and phone number.
- Contact Data includes billing address, invoicing address, email address and telephone
numbers.
- Financial Data includes bank account and payment card details.
- Transaction Data includes details about payments and other details of our 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
this Website.
- Profile Data includes your username and password, reservations made by you, your
interests, preferences, feedback and survey responses.
- Usage Data includes information about how you use our Website and Services.
- Marketing and Communications Data includes your preferences in receiving
marketing from us and our third parties and your communication preferences.
- Interaction Data includes any information that you might provide to any discussion
forums on the Website.
- Cookies Data like many websites, we use "cookies" to enhance your experience and
gather information about visitors and visits to our websites. Please refer to the "Do we
use "cookies"?" section below for information about cookies and how we use them
and what kind.
- Third Parties and Information we receive from other sources. We may receive
information about you if you use any of the other websites we operate or through the
Services we provide. In this case, we will have informed you when we collected that
data that may be shared internally and combined with data collected on our
Website. We are also working closely with third parties (including, for example,
business partners, suppliers, sub-contractors, advertising networks, analytics
providers, and search information providers) and may receive information about you
from them.
- Analytics includes third-party analytics services (such as Google Analytics) to evaluate
your use of the Website, compile reports on activity, collect demographic data, analyse
performance metrics, and collect and evaluate other information relating to our
Website and internet usage. These third parties use cookies and other technologies to
help analyse and provide us with the data. By accessing and using the Website, you consent
to the processing of data about you by these analytics providers in the manner and for
the purposes set out in this Privacy Policy.
3.3 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 Policy.
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3.4
Where we do collect Special Categories of Personal Data about you (this includes
details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual
orientation, political opinions, trade union membership, information about your health
and genetic and biometric data) and it is necessary to do so for our business, we will
obtain your specific consent, unless we have another lawful basis to do so.]
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3.5 Under UK GDPR we will ensure that your personal data is processed lawfully, fairly,
and transparently, without adversely affecting your rights. We will only process your
personal data if at least one of the following basis applies:
a) You have given consent to the processing of your personal data for one or more
specific purposes;
b) processing is necessary for the performance of a contract to which you are a party
or in order to take steps at the request of you prior to entering into a contract;
c) processing is necessary for compliance with a legal obligation to which we are
subject;
d) processing is necessary to protect the vital interests of you or of another natural
person;
e) processing is necessary for the performance of a task carried out in the public
interest or in the exercise of official authority vested in the controller; and/or
f) processing is necessary for the purposes of the legitimate interests pursued by us or
by a third party such as our financial payments, except where such interests are
overridden by the fundamental rights and freedoms of the data subject, in particular
where the data subject is a child.
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3.6 If you provide personal information to us about another data subject, you are
responsible for ensuring that you have their consent to provide that data for the uses
set out in this Privacy Policy and for bringing this Privacy Policy to their attention.
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4. How We May Collect and Use Your Data
4.1 We (or third party data processors, agents and sub-contractors acting on our
behalf) may collect, store and use your personal information by way of different
methods to collect data from and about you including through:
Direct interactions. You may give us your information by filling in forms via our
Website or by corresponding with us by post, phone, email or otherwise. This includes
personal data you provide when you:
a) present Website content;
b) use any of our Services;
c) create an account on our Website;
d) subscribe to our Services or publications;
e) request marketing to be sent to you;
f) enter a competition, promotion or survey; or
g) give us some feedback.
4.2 In addition to the above, we may use the information in the following ways:
a) To personalise your Website experience and to allow us to deliver the type of
content and product offerings in which you are most interested.
b) To administer a contest, promotion, survey or other site feature.
c) If you have consented to receive our e-mail newsletter, we may send you periodic e-
mails. If you would no longer like to receive promotional e-mail from us, please refer
to the "How can you opt-out, remove or modify information you have provided to us?"
section below. If you have not opted-in to receive e-mail newsletters, you will not
receive these e-mails. Visitors who register or participate in other site features such as
marketing programs and "members-only" content will be given a choice whether they
would like to be on our e-mail list and receive e-mail communications from us.
d) Present Website content effectively to you.
e) Provide information, and services that you request, or (with your consent) which we
think may interest you.
f) Carry out our contracts with you.
g) Provide the relevant Services to you
h) Tell you our charges.
4.3 If you are already our customer, we will only contact you electronically about
things similar to what was previously sold to you.
4.4 If you are a new customer, you will only be contacted if you agree to it.
4.5 We may keep a record of those links which are used the most to enable us to
provide the most helpful information but we agree to keep such information
confidential and you will not be identified from this information.
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4.6 In addition, if you don"t want us to use your personal data for any of the other
reasons set out in this Section 4, you can let us know at any time by contacting us at
enquiries@rtnmentalhealthsolutions.com, and we will delete your data from our
systems. However, you acknowledge this will limit our ability to provide the best
possible [products and] services to you.
4.7 In some cases, the collection of personal data may be statutory or contractual
requirement, and we will be limited in the [products and] services we can provide you
if you don"t provide your personal data in these cases.
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4.8 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:
a) Where we need to perform the contract we are about to enter into or have entered
with you.
b) 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.
c) Where we need to comply with a legal or regulatory obligation, for example
compliance with health and safety, tax or other statutory obligations.
4.9 Generally we do not rely on consent as a legal basis for processing your personal
data other than in relation to our marketing communications or 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 at
enquiries@rtnmentalhealthsolutions.com, and we will either delete your data from
our systems or move your data to our "unsubscribe list". However, you acknowledge
this will limit our ability to provide the best possible services to you.
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4.10 As already indicated above, with your permission and/or where permitted by law,
we may also use your data for marketing purposes which may lead to us contacting
you by email and/or telephone with information, news and offers on our Services. We
agree that we will not do anything that we have not agreed to under this Privacy
Policy, and we will not send you any unsolicited marketing or spam. We will take all
reasonable steps to ensure that we fully protect your rights and comply with our
obligations under the UK GDPR and the Privacy and Electronic Communications (EC
Directive) Regulations 2003, as amended.
5. Cookies
5.1 All Cookies used by and on our website are used in accordance with the current UK
Cookie Law.
5.2 We use cookies to distinguish users and improve our Website. Please look at our
Cookie Policy at www.rtnmentalhealthsolutions.com/cookie-policy for more cookie
information.
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6. Where We Store Your Data and Security
6.1 We may transfer your collected data to storage outside the UK. It may be
processed outside the UK to fulfil your order and to receive our Services and deal with
payment. If we do store or transfer data outside the UK, we will take all reasonable
steps to ensure that your data is treated as safely and securely as it would be within
the UK and under the UK GDPR. Such steps may include, but not be limited to, the use
of legally binding contractual terms between us and any third parties we engage with
and the use of approved Model Contractual Arrangements. Your acceptance of this
Privacy Policy shall be your consent permitting us to store or transfer data outside the
The UK if it is necessary for us to do so.
6.2 Data security is of great importance to us, and to protect your data we have put in
place suitable physical, electronic and managerial procedures to safeguard and secure
data collected through our Website. 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.
6.3 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.
6.4 By giving us your personal data, you agree to this arrangement. We will do what we
reasonably can keep your data secure.
6.5 Any payments made by you, will be encrypted.
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6.6 We have implemented security measures such as a firewall to protect any data and
maintain a high level of security.
6.7 Notwithstanding the security measures that we take, it is important to remember
that the transmission of data via the internet may not be completely secure and that
you are advised to take suitable precautions when transmitting to us data via the
internet and you take the risk that any sending of that data turns out to be not secure
despite our efforts.
6.8 If we give you a password upon registration on our Website, you must keep it
confidential. Please don"t share it.
6.9 We will keep personal data for as long as is necessary which is usually the life of
our relationship and up to a period of seven years after our relationship has ended.
We may however be required to retain personal data for a longer period of time to
ensure we comply with our legislative and regulatory requirements. We review our
data retention obligations to ensure we are not retaining data for longer than we are
legally obliged to.
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7. Disclosing Your Information
We are allowed to disclose your information in the following cases:
7.1 We are allowed to disclose your information in the following cases:
7.1.1 If we want to sell our business or our company, we can disclose it to the
potential buyer.
7.1.2 We can disclose it to other businesses in our group.
7.1.3 We can disclose it if we have a legal obligation to do so, or in order to
protect other people"s property, safety or rights.
7.1.4 We can exchange information with others to protect against fraud or credit
risks.
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7.2 We may contract with third parties to supply services to you on our behalf. These
may include payment processing, search engine facilities, advertising and marketing. In
some cases, the third parties may require access to some or all of your data. These are
the third parties that have access to your information:
-Stripe – Payment Processing
7.3 Where any of your data is required for such a purpose, we will take all reasonable
steps to ensure that your data will be handled safely, securely, and in accordance with
your rights, our obligations, and the obligations of the third party under UK GDPR and
the law. Any third party that we share data with will not be permitted to use it for any
other purposes than fulfilling their contract with us.
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8. Your Rights
8.1 When you submit information via our Website, you may be given options to restrict our use of your data. We aim to give you strong controls on our use of your data (including the ability to opt-out of receiving emails from us which you may do by unsubscribing using the links provided above in this Privacy Policy.
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8.2 Under the UK GDPR, you have the right to: - Request access to, deletion of or correction of, your personal data held by us at no cost to you; - request that your personal data be transferred to another person (data portability); - be informed of what data processing is taking place; - restrict processing; - to object to the processing of your personal data; and - complain to a supervisory authority.
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8.3 You also have rights with respect to automated decision-making and profiling as set out in section 11 below.
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8.4 You have the right to ask us not to process your personal data 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 such purposes.
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8.5 To enforce any of the foregoing rights or if you have any other questions about our Website or this Privacy Policy, please contact us at enquiries@rtnmentalhealthsolutions.com.
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9. Links to Other Sites
9.1 Please note that our terms and conditions and our policies will not apply to other websites that you get to via a link from our Website. We have no control over how your data is collected, stored or used by other websites and we advise you to check the privacy policies of any such websites before providing any data to them.
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10. Changes
10.1 If we change our Privacy Policy, we will post the changes on this page so please check this page for our current policy.
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11. Automated Decision-Making and Profiling
11.1 In the event that we use personal data for the purposes of automated decisionmaking and those decisions have a legal (or similarly significant effect) on you, you have the right to challenge such decisions under UK GDPR, requesting human intervention, expressing their own point of view, and obtaining an explanation of the decision from us.
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11.2 The right described in section 11.1 does not apply in the following circumstances:
a) the decision is necessary for the entry into, or performance of, a contract between you and us; b) the decision is authorised by law; or
c) you have given your explicit consent.
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11.3 Where we use your personal data for profiling purposes, the following shall apply:
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a) Clear information explaining the profiling will be provided, including its significance and the likely consequences;
b) Appropriate mathematical or statistical procedures will be used;
c) Technical and organisational measures necessary to minimise the risk of errors and to enable such errors to be easily corrected shall be implemented; and
d) All personal data processed for profiling purposes shall be secured in order to prevent discriminatory effects arising out of profiling.
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12. Terms and Conditions
12.1 Please also visit our Terms and Conditions section at www.rtnmentalhealthsolutions.com/terms-and-conditions establishing the use, disclaimers, and limitations of liability governing the use of our Website.
13. Your agreement
13.1 By using our Website and by way of acknowledgement, you agree to our Privacy Policy.
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14. Dispute Resolution
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14.1 We will use our best efforts to negotiate in good faith and settle any dispute that may arise out of or relate to this Privacy Policy or any breach of it.
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14.2 Any dispute shall not affect our ongoing obligations under this Privacy Policy.
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14.3 This Privacy Policy and any dispute or claim relating to or connected with it (including non-contractual disputes or claims) shall be governed by and construed in accordance with the laws of England and Wales and the courts of England and Wales are the only place where disputes or claims relating to or connected with this Privacy Policy (including non-contractual disputes or claims) may be decided.
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