Updated May 2018
This Privacy Policy (“Privacy Policy”) is designed to help you understand how Charter Harley Street Ltd (“Charter”, “we” or “us”) collects and processes the information that you share when you use our website located at https://www.charterharleystreet.com. For purpose of the Data Protection Act 1998, the data controller of the information that you share is CHARTER HARLEY STREET LTD, c/o Thorne Lancaster Parker, 4th Floor Venture House, 27-29 Glasshouse Street, London W1B 5DF.
Before submitting information to the Service, please review this Privacy Policy carefully. By using or accessing the Service, you accept the practices described in this Privacy Policy. If you prefer that we do not collect and process information about you, please do not provide it to us and do not access the Service.
We do not knowingly collect any Personal Information from children under 16. Where any such information is inadvertently collected, we will delete the information as soon as possible. If you believe a child under 13 has provided us with Personal Information, please contact us here (link).
1. Information We Collect
We collect the information that you share with us, including:
- Personal Information: “Personal Information” is information that can personally identify you, such as your name, email address, telephone number and mailing address. We maintain one database to store your Personal Information and may retain it as reasonably required to serve you and operate the Service. Personal Information that we collect depends on how you use the Service. Providing your Personal Information to us is your choice.
- General Technical Information: When you visit the Service, we may collect various categories of general technical information (“General Information”). General Information includes the date, time, length of stay and specific pages accessed during your visits to the Service. We are also working closely with third parties such as analytics and marketing services providers, and may receive aggregated and anonymised data relevant to your demographic from them that we use to target advertising based upon your interests.
- General Information and Personal Information may be combined and/or linked to Third Party Information for the purposes described in more detail below.
- Special Categories Personal Information: As a client of Charter, we will hold information relating to your medical treatment which is known as a special category of personal data under the law, meaning that it must be handled even more sensitively. The special categories of personal information we hold about you may include the following:
- Details of your current or former physical or mental health. This may include information about any healthcare you have received (both from Charter directly and other healthcare providers such as GPs, dentists or hospitals [private and/or NHS]) or need, including about clinic and hospital visits and medicines administered. We provide further details below on the manner in which we handle such information.
Details of services you have received from us
Details of your nationality, race and/or ethnicity
Details of your religion
Details of any genetic data or biometric data relating to you
Data concerning your sex life and/or sexual orientation
The confidentiality of your personal information is important to Charter. We make every effort to prevent unauthorised access to and use of information relating to your current or former physical and mental health. In doing so, Charter complies with UK data protection law, including the Data Protection Act 2018, and all applicable medical confidentiality guidelines issued by professional bodies including, but not limited to, the BACP and UKCP.
From 25 May 2018, the current Data Protection Act will be replaced by the EU General Data Protection Regulation (GDPR) and a new Data Protection Act. All uses of Charter information will comply with the GDPR and the new Data Protection Act from that date onwards.
a) Registering for the Service
If you register to use the Service, we may collect Personal Information including your name, email address, and telephone number.
b) Online Identification Tools
Like many website providers, we use your IP address to help diagnose problems with our server and provide a better web experience. Your IP address is used to help identify you and gather General Information.
We use web beacons (a.k.a. clear GIFs, web bugs or pixel tags) to personalise your experience of the Service and to generate information about Service traffic and trends. Web beacons collect General Information, such as the type of browser that you use and your IP address. Web beacons may be used alone or in conjunction with cookies; when web beacons are used with cookies, they may link General Information to Personal Information. Web beacons usually are not visible to you.
We also use session and persistent cookies for purposes like personalising the Service. A cookie is a small file stored by your internet browser on your computer. You can find more information about cookies and how to manage them at www.allaboutcookies.org. A “session cookie” stores temporary information that is erased when you close your web browser or turn off your computer. A “persistent cookie” enables the Service to recognise you when you return to it and remains stored on your computer until you delete it. Your web browser is usually set up to initially accept cookies. If you set your browser to reject cookies, the Service will not be able to personalise the content that you see. We do not and cannot use cookies to gather other information that may be stored on your hard drive.
c) Third Party Features
The Service also may include an activity feed, social media buttons and widgets, such as the Facebook “Like” button or the “Share This” button. These features may collect and display your Personal Information, your IP address and the page you are visiting on the Service and may set a cookie to enable the feature to function properly. These features are either hosted by a third party or hosted directly on the Service and your interactions with them are governed by the privacy policy of the third party that provides the feature.
d) Third-Party Links
We may provide links to third-party web sites that we do not own or control. We are not responsible for the information collection practices of any website that we do not own or control. We encourage you to review and understand the privacy practices of third-party websites before providing any information to or through them.
2. How Your Personal Information is Used, Processed and Disclosed
Except as specified in this Privacy Policy, Charter does not rent, sell, trade or disclose your Personal Information to any third parties without your prior consent. Charter may, however, use, process and disclose Personal Information to: 1. send information to customers about services; 2. process and collect your payments; 3. customise, analyse, adjust and improve the Service to better meet your needs; 4. provide you with important administrative information regarding the Service, such as changes to this Privacy Policy and our Terms of Use 5. prevent fraud and other prohibited or illegal activities; and 6. comply with potential requests for information from law enforcement or data protection agencies. 7. To comply with the ‘Mental Health Act 1983’ in relation to Charter’s duty of care to the individual, to report any event in which a client is considered to be at risk of harm to himself/herself or others.
We may use your General Information and de-identified Personal Information to prepare anonymised, aggregated data about our users (“Anonymised Data”). We may provide third parties with Anonymised Data in describing the Service to prospective partners, advertisers and other third parties, and for all other lawful purposes. As communicated to third parties, the Anonymised Data does not include any information permitting the recipient to identify, locate or contact you.
a) Third Party Service Providers
Charter employs other companies and individuals to perform functions on our behalf, such as sending postal mail and e-mail, serving ads on our behalf, providing search results and links, and processing credit card payments. These third-party service providers have access to Personal Information needed to perform their functions but may not use it for any other purpose.
b) Blogs, Reviews and Forums
The Service also may from time to time offer publicly-accessible blogs, Service reviews or forums. Any information you provide in these areas may be read, collected and used by others who access them. To request removal of your Personal Information from blogs, customer reviews or forums, please contact us here (link). Please note that in some cases we may be unable to remove your Personal Information.
c) Inviting Others
You may choose to invite someone else to use the Service by providing his or her name and email address. You must ensure that you have permission from the individual before sharing their details with us. We may use this information to send invitations to such individuals on your behalf and to track the results of such invitation referrals. Anyone who receives an email invitation to use the Service may opt out of receiving such emails in the future by following the opt-out instructions in the email. We take commercially reasonable steps to implement all opt-out requests promptly, but those who opt out may still receive communications from us as we process the opt-out request.
3. Retention of Personal Information
GDPR requires that personal information should not be held for longer than is necessary for the purpose for which it is being processed. However, it is a fundamental requirement that all of Charter’s treatment records are retained for a minimum period of time for legal, operational, research and / or safety reasons. The length of time for retaining records be 5 years.
4. Accessing and Updating Your Personal Information and Preferences
a) Modifying or Deleting Your Personal Information
If you would like to modify or delete your Personal Information, please contact us here (link) with clear instructions about what you would like to be modified or deleted. We will respond to your request promptly.
You have the right to access the information that we hold about you. Should you wish to receive details that we hold about you please contact us using the contact details under Section 7 below.
b) Changing Your Subscription Preferences
If you tell us that you do not want us to use your Personal Information to contact you, Charter will respect your wishes.
You may instruct Charter to stop sending you emails, newsletters or other information by following the ‘unsubscribe’ instructions provided in the email or by sending an email to info@charterharleystreet. Charter may, however, continue to use your Personal Information to contact you to service your account or as otherwise authorized by law. Please note that if you use more than one name or e-mail address when communicating with Charter or using the Service, you may continue to receive communications from Charter to any name and/or email address not specified in your opt-out request.
5. Security Information
We take every precaution to protect our users’ information and do not hold debit or credit card information.
6. Changes to Our Privacy Policy
We may occasionally update this Privacy Policy to reflect changes in our practices. When we post modifications to this Privacy Policy, we will revise the “Last Updated” date at the top of this web page. The modified Privacy Policy will be effective immediately upon posting on the Service. Your continued use of the Service after the posting of the modified Privacy Policy constitutes your agreement to abide and be bound by it. If we make any material change, we will notify you by email (sent to the e-mail address specified in your account) or by means of a notice on this Service prior to the change becoming effective. We encourage you to periodically review this page for the latest information on our privacy practices. If you object to any modification, your sole recourse is to stop using the Service.
7. Questions About Our Privacy Policy
If you have questions about this Privacy Policy or Charter generally, please contact us here: info@charterharleystreet.com. You can also send us physical mail to:
CHARTER HARLEY STREET LTD, c/o Thorne Lancaster Parker, 4th Floor Venture House, 27-29 Glasshouse Street, London W1B 5DF. TEL: 020 7323 4970