Privacy policy
Cloud 18 BTA
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Privacy Policy
The following privacy policy outlines how Cloud 18 BTA collects, uses, protects and transfers your personal data. Cloud BTA is a training school currently located in London.
The data protection officer for Cloud 18 BTA is Akash Rajput. You can contact the data protection officer by sending an email to akash@cloud18uk.com or writing to Cloud 18 BTA, 18 James Street, London, W1U 1EQ
Website Hosting
The current hosting is provided by ionos.co.uk. The website files and data is currently located and stored in Gloucester UK.
Our website is aimed at members of the public who are 16 years or over who live in the United Kingdom. Persons under 16 are permitted to access the website, however only persons 18 or over can become customers at Cloud 18 BTA.
Personal Data Collected
Cloud 18 BTA collects personal data through our website contact us form. We also collect data via the telephone, email communications and with our treatment/appointment cards.
The personal data that we collect is:
· Name
· Home address
· Email Address
· Phone number
· Date of Birth
· Allergies and Health Conditions
· User IP Address
· Device Type
· Time and date of entry
Purpose and Legal basis for processing your Data
Cloud 18 BTA takes your privacy very seriously and we will never sell or rent your personal data to any third-party. The sharing of your personal data and direct marketing activities are only carried out with your express consent, which you are free to withdraw at any time.
We need to obtain and process your personal data to provide you with our products, services and treatments and to fulfil our business and legal obligations. We will never collect any personal information from you that we do not need or retain any data that is no longer necessary for the purposes specified in this notice.
Where we request sensitive personal data from you (i.e. health or medical data), the reason(s) for the request will be clearly given along with the purposes of the processing. Explicit consent through a signature will always be required for us to obtain and process your health information.
Who is Processing my Data?
Cloud 18 BTA, registered office, 4th Floor, 18 James Street, London, W1U 1EQ are the data controller and processes your personal information for the purposes laid out in this privacy notice.
Your personal data is processed to:
· Collect specific personal data (name, address, email, contact number) that is required to enter into a contract to sell a product or service.
· Engage in communication with you including confirmation and reminders of appointments and requests to cancel or change bookings.
· Collect Health information to perform the agreed services appropriately, and potentially highlight areas that products and services may cause issues to clients because of their health.
· Ensure a safe service and provide industry standard advice.
· Select relevant offers, promotions and information for you.
· Estimate the number of customers we have.
· Hold personal data that is required by law or to respond to legal process.
· Hold for insurance purposes.
· Store customer records.
Your Rights as the Individual
If your personal data is held by Cloud 18 BTA, you hold particular rights over it.
Where you have provided consent for us to contact you as part of our marketing services, you have the right to modify or withdraw your consent at any time by using the unsubscribe option accompanied with all of our direct marketing or by contacting the Cloud 18 BTA Data Protection Officer.
You also have the right:
· To be informed of how your personal data will be used before it is collected.
· To access your personal data personal data and to information on how your information is used after it has been gathered.
· To have personal data corrected if it is incomplete, inaccurate or out-of-date.
· To request the removal or deletion of personal data where there is no compelling reason for its continued processing.
· To restrict processing , to ‘block’ processing of your personal data.
· To data portability, having your data moved, copied or transferred from Cloud 18 BTA to another organisation in an easily readable format.
· To object to direct marketing from us.
Cookies and Third Party Apps on our Website
We do use cookies and third party apps to improve your experience on our website. These are:
Crazy Egg – https://help.crazyegg.com/article/165-crazy-eggs-gdpr-readiness – heat mapping and video recording sessions to allow us to improve the user experience, specifically improvements with website navigation. This data is kept for 140 days.
Google Analytics – https://privacy.google.com/businesses/compliance/#?modal_active=none – analytical data to improve the user experience and website navigation. Google Analytics data is currently set to expire after 26 months.
Wordfence – security software that scans our website for Malware. Wordfence provides us visitor IP addresses, device types and time of entry for the basis of detecting and blocking unwanted bots, crawlers and cyberattacks. Any IP’s that we block are stored for the entirety of the websites lifespan or until we decide to discontinue use of Wordfence. IP addresses that are not immediately blocked are held only for a limit of 2000 stored entries, this is approximately 7 days. After this time, they are securely deleted.
Special categories of Personal Data Collected
Health questions are asked in many of our consent forms to potentially highlight treatments that may have a negative effect on your health due to medication they are taking or a condition they may have. Cloud 18 BTA asks for consent prior to gathering and processing this information. At any time after giving consent, you can withdraw your consent, subject to legal, insurance and contractual restrictions (see more on ‘your rights as an individual’). Your privacy is very important to us and we only use this information for determining your suitability for the treatment.
Process of Collection
Your personal data is collected when you provide it to us on our website, over the phone, by email, social media, in writing or any other means by which you provide it to us. Information is stored on our website as well as some level of paper record keeping. Cloud 18 BTA gives you access to information on each visit, for the limited purpose of viewing and updating that information.
Children’s Privacy
Cloud 18 BTA does not collect the personal data of children under the age of 16 without parental or guardian consent. If you believe that we hold any information from or about a child under age 16, please contact Cloud 18 BTA and if we cannot immediately obtain appropriate parental or guardian consent, will remove the personal data from storage.
Data Sharing
Cloud 18 BTA do not share your name, address, phone or email information with any third parties, nor do we sell any personal data that we collect. Your IP address, IP location, device type and country of IP is shared with Wordfence for the purpose of security and to prevent cyberattacks.
Use of Data Processors
Where we use a third-party, we have strict agreements in place governing the processing of your personal data, on which no action can be taken without instruction from us. The third-parties with whom we work will never share or disclose your personal information and will hold it securely at all times.
How long do we keep your Data?
Cloud 18 BTA retains your personal data for as long as necessary to provide you with our services as our client. Cloud 18 BTA are required under tax laws to keep your personal data for a minimum of 7 years. Health and Safety records will be retained for 10 years and where we have your consent for marketing purposes, we will retain the minimum required data until you notify us that you no longer wish to receive such information.
The criteria for which we would continue to process your personal information
includes:
· Where there is a legal basis, obligation or legitimate interest to continuing processing your personal information
· Where processing is necessary for the establishment, exercise or defence of legal claims
Transfers of Personal Information
When your personal data is processed through the website, it is currently stored in the UK and is compliant with EU GDPR regulations.
Consequences of not providing your Personal Information to Cloud 18 BTA
In the event that you want to purchase a product or service from Cloud 18 BTA, certain personal information is required to enter into a contract with you.
Cloud 18 BTA will not be able to enter into a contract with you to fulfil an attempt to purchase a product or service if you do not provide your personal information.
As noted in this privacy statement, we are processing your personal data to comply with legal and statutory obligations and in the performance of a contract. You can always choose not to provide personal information; however, we will be unable to provide certain products, services and treatments in these instances.
Safeguarding your Personal Data
Appropriate measures are taken to protect your personal data from access from unauthorised persons or inappropriate access, internal or external.
Any paper files recording your personal data are held in a locked filing cabinet or safe which can only be accessed by authorised personnel in the academy.
Complaints
In the occurrence that you want to make a complaint about how your personal data was gathered, how it is being processed by Cloud 18 BTA (or third parties used by Cloud 18 BTA or you are not satisfied about how a complaint has been handled, you retain the right to lodge a complaint directly with the supervisory authority and Cloud 18 BTA and also the Cloud 18 BTA Data Protection Officer/ GDPR Owner.
Data Protection Supervisory Authority
Data Protection Commissioner, Information Commissioner’s Office, Wycliffe House,
Water Lane, Wilmslow, Cheshire , SK9 5AF
Akash Rajput – Data Protection Officer/GDPR Owner
Cloud 18 BTA, 18 James Street, London, W1U 1EQ