Privacy & Cookies

INTRODUCTION

This privacy policy sets out the way Back Stronger Limited trading as The SpineXchange (“TSX”) processes your personal information. It deals with how TSX collects information, what TSX does with it, how TSX protects it and what controls or rights you have. 

TSX is committed to protecting the privacy of its users and anyone who interacts with TSX, and will treat all such information with due care. TSX promises to:

  • Tell you why TSX collects personal information, how TSX does this and what TSX uses it for.

  • Only collect the information TSX needs to deliver the service to you.

  • Keep the personal information up to date and ensure it is safe and secure.

Please read this Privacy Policy carefully to understand how TSX processes your personal data. By providing your personal data to TSX or by using its services or this website you are accepting or consenting to the practices in this Privacy Policy.

TSX may change this policy from time to time. The date this policy was last updated is shown at the end of this document. Please check back frequently to see if the policy has been updated. 

 As a data controller, TSX fully complies with the Data Protection Act 2018 (DPA), the Privacy and Electronic Communications Regulations 2003 and the UK General Data Protection Regulations (UKGDPR). TSX is recorded on the ICO Data Protection Register under registration number ZB354376.

WHO IS TSX

In this policy references to “TSX” are to Back Stronger Ltd trading as The SpineXchange whose address is 1st Floor, Health Aid House, Marlborough Hill, Harrow, HA1 1UD. The data controller is Mr Steve Taylor at The SpineXchange.

WHAT INFORMATION IS COLLECTED

TSX collects personal information about you to enable TSX to provide its services.  The term personal data means any information about an individual from which that individual may be identified. TSX may collect, store and use some or all of the following categories of data about you.

When you use TSX’s website, it may record: 

  • technical information, including the type of device you use to access TSX’s website, the Internet Protocol (IP) address, your login data, the type and version of your browser, your time zone setting and location, browser plug-in types and versions, operating system, platform and mobile network information; and

  • your usage of TSX’s website, including the full Uniform Resource Locators (URL), the pages you viewed, the page response times, any download errors, the length of time you were on a particular page, how you interacted with the page (such as scrolling, clicks and mouse-overs), and how you browsed away from the page.

The personal information TSX collects may include:

  • Name and address, marital status.

  • Email address and telephone numbers.

  • The country you live in, your gender, date of birth, the language you speak.

  • Details of your employment.

  • The name and contact details of your next of kin. It is your responsibility to ensure that if you provide TSX with any information about another person and that they are aware of the terms of this privacy policy.

  • Recordings of telephone calls or video calls TSX receives or makes.

  • Your photograph and photographs.

  • Video and sound recordings.

  • Details of services you may have received from TSX.

  • Reports or notes on the surgery you have had or are awaiting, including the name of the Hospital, the Consultant, the date and the country. 

  • Patient feedback and treatment outcome information you provide.

  • Information about complaints and incidents.

  • When you visit TSX’s website, TSX collects information about your IP address and pages you visit. This does not tell TSX who you are or your address, unless you choose to provide that information. 

  • Your payment information (e.g. credit card details) provided when you make a payment to TSX.

  • The result of any credit or anti-fraud checks TSX has made on you.

TSX may also collect Special category data – sometimes called sensitive personal information. This may include:

  • Information about your race, ethnic origin and religion.

  • Information about your physical or mental health, genetic data or biometric data.

  • Information about your sex life or sexual orientation.

  • Information about risk and safeguarding.

  • Information about criminal offences.

HOW TSX COLLECTS PERSONAL INFORMATION

TSX collects the personal information in the following ways:

  • When you enquire about TSX’s service.

  • When you provide information by filling in a form on registration or information provided at any other time.

  • When you correspond with TSX by email, phone or other ways.

  • During the course of the provision of TSX services to you.

  • When you contact TSX by email, telephone, social media or in any other way.

  • When you visit TSX’s website.

  • When you fill in a form or survey for TSX.

  • Information from emergency services, local authority and other public organisations.

  • Information from third parties including business partners, service providers, technical sub-contractors, payment and delivery services or advertisers when you have given permission to share it with TSX

  • From publicly available services to keep your information up to date for example the NHS national data base.

  • When you participate in discussion forums or other social media on TSX’s site or sites managed by TSX.

PERSONAL INFORMATION PROVIDED BY OTHER SOURCES

TSX may collect personal data about you from other sources and these can include:

  • from publicly-accessible sources (for example the internet, LinkedIn or Companies House);

  • directly from a third party where the issue involves someone else;

  • from automated technologies or interactions with TSX’s website through the use of cookies and similar; and

  • via TSX’s systems.

HOW TSS USES THE INFORMATION AND WHY TSX NEEDS IT

TSX uses personal information to provide its service. This may include:

  • Processing – this will include using the information to fulfil any request made by you or someone on your behalf to receive TSX’s services. 

  • Contract – if TSX has a contract with you, TSX will process your personal information to fulfil that contract

  • Consent – generally TSX will only ask for your consent to process your personal information if there is no other legal ground to process. Where TSX needs your consent, TSX will ensure you are as fully informed as possible and use that consent solely for the reason you have given it to TSX. You will be able to change your mind at any time by contacting TSX at the address above.  Any direct marketing email or text to you will have a link to let you do so.

  • Necessary to defend legal claims or a court action.

  • Vital interests – where it is necessary to protect your vital interests or those of another person.

  • Employment – when necessary to fulfil TSX duties under employment law.

  • Public interest – this is usually in line with any applicable laws such as protecting against dishonesty, malpractice or other seriously improper behaviour.

  • Information you have made public.

LEGITIMATE INTERESTS

TSX also processes your data when it is in TSX’s legitimate interests to do this and when these interests do not override your rights. These legitimate interests include: –

  • providing you with information on products, services, competitions, feedback, offers by partner service providers. 

  • Keeping TSX records up to date.

  • For statistical research and analysis and to enable TSX to monitor and improve services.

  • To monitor how TSX is meeting its performance.

  • Sharing your personal information with people or organisations in order to comply with any legal or regulatory obligations or to enable TSX to run its organisation.

  • To fulfil laws that apply to TSX and the third parties TSX works with.

  • To take part in or be the subject of any merger, sale or purchase of all or part of TSX business.

  • Managing TSX’s relationships with you and third parties who assist TSX to provide the services to you.

WHO WILL SEE THE INFORMATION

Your information will only be accessible to TSX staff and only where it is appropriate in respect of the role they are carrying out. TSX will never sell your information or let other organisations use it for their own purposes. 

TSX will only share your personal information:

  • If consent is necessary, TSX will have taken your consent and will provide information for the specific reason your consent was given. You will have the opportunity to withhold consent when you complete the form on which TSX collects the data or you can do so by contacting TSX at the address above, at any time.

  • Where it is necessary to protect your vital interest (i.e. your life or health).

  • Other organisations you belong to confirm your entitlement to TSX services.

  • The police or other law enforcement agencies to assist them perform their duties if TSX must do this by law or under a court order.

  • To organisations who you have requested TSX to supply information so that they can provide services or products you have requested.

  • Organisations providing IT systems, IT support and hosting in relation to IT systems on which information is stored.

  • When using auditors and professional advisors. 

  • When TSX is legally required to, or because of a lawful request by a governmental or law enforcement authority.

  • If TSX merges with another organisation, forms a new entity, sells its business or purchases a business.

Where a third-party data processor is used, TSX ensures they operate under a contract which includes confidentiality and security of personal data and their obligations under the Data Protection legislation.

SECURITY

The security of your personal information is very important to TSX. TSX protects all personal data it holds and ensures TSX has appropriate organisational and technical measures in place to prevent unauthorised access or unlawful processing of personal data and to prevent data being lost, destroyed or damaged.

TSX will keep your personal data only for as long as is necessary. In working out how long TSX needs to keep your personal data TSX takes into account the amount, nature and sensitivity of the personal data, the potential for harm to arise from its unauthorised use or disclosure, the purposes for which TSX processes it, and as to whether those purposes may be achieved by other means, and the applicable legal requirements. Since retention periods will differ for different types of personal data please contact TSX for further details.

All information you provide to TSX is stored on TSX secure servers. Any payment transactions will be encrypted. Where TSX has given you (or where you have chosen) a password which enables you to access certain parts of TSX’s site, you are responsible for keeping this password confidential. TSX asks you not to share a password with anyone. 

Unfortunately, the transmission of information via the internet is not completely secure. Although TSX will do its best to protect your personal data, TSX cannot guarantee the security of your data transmitted to its site; any transmission is at your own risk. Once TSX has received your information, TSX will use strict procedures and security features to try to prevent unauthorised access.

All the personal data is processed in the UK however for IT hosting and maintenance your information may be situated outside the European Economic Area (EEA).

You might find links to third party websites on TSX’s website. These websites should have their own privacy policies, which you should check. TSX does not accept any responsibility or liability for their policies whatsoever as TSX has no control over them.

YOUR RIGHTS

You benefit from a number of rights in respect of the personal data TSX holds about you. These rights apply for the period in which TSX processes your personal data. More information is available from the Information Commissioner's Office website (https://ico.org.uk/for-organisations/guide-to-the-general-data-protection-regulation-gdpr/invidual-rights/). TSX has summarised the rights which may be available to you below:

  • Transparency over how TSX uses your personal information (right to be informed).

  • To request a copy of the personal information TSX holds about you, which will be provided to you within one month (right of access).

  • An update or amendment of the personal information TSX holds about you (right of rectification).

  • To ask TSX to stop using personal information (right to restrict processing).

  • Ask TSX to remove your personal information from TSX’s records (right to be forgotten). 

  • Request TSX to remove your personal information for marketing purposes (right to object).

  • To obtain and reuse your personal data for your own purposes (right to portability) or to transfer it to another party.

  • Not to be subject to a decision based on automated processing.

You can contact TSX about any of these rights at the address above. To protect your privacy, TSX may ask you to prove your identity before it agrees to respond to any request. 

TSX will provide the information free of charge unless your request is manifestly unfounded or excessive or repetitive, in which case TSX is entitled to charge a reasonable fee. TSX may also charge you if you request more than one copy of the same information.

TSX will provide the information you request as soon as possible and in any event within one month of receiving your request. If the request contains a large amount of data, TSX reserves the right to provide the data within three months of the initial request. If TSX needs more information to comply with your request TSX will let you know.

In some circumstances TSX may not be able to do what you have asked, for example if there is a statutory or contractual requirement for TSX to process your data.

If you are not satisfied with the way in which TSX deals with your request, you can contact the Information Commissioner's Office on 0303 123 1113 or at their website www.ico.org.uk.

COOKIES

TSX’s website uses cookies to distinguish you from other users of TSX’s website. This helps TSX to provide you with a good experience when you browse TSX’s website and allows TSX to improve its site. By continuing to browse the site, you are agreeing to TSX’s use of cookies.

A cookie is a small file of letters and numbers that TSX stores on your browser or the hard drive of your computer if you agree. Cookies contain information that is transferred to your computer’s hard drive.

 TSX uses the following cookies: 

  • Strictly necessary cookies. These are cookies that are required for the operation of TSX’s website. They include, for example, cookies that enable you to log into secure areas of TSX’s website, use a shopping cart or make use of e-billing services.

  • Analytical/performance cookies. These allow TSX to recognise and count the number of visitors and to see how visitors move around the website when they are using it. This helps TSX to improve the way its website works, for example, by ensuring that users are finding what they are looking for easily.

  • Functionality cookies. These are used to recognise you when you return to TSX’s website. This enables TSX to personalise its content for you, greet you by name and remember your preferences (for example, your choice of language or region).

  • Targeting cookies. These cookies record your visit to TSX’s website, the pages you have visited and the links you have followed. TSX will use this information to make its website and the advertising displayed on it more relevant to your interests. TSX may also share this information with third parties for this purpose.

Third Party cookies. These are used where TSX has third party applications on its website to customise the services that it provides, or to provide increased functionality. They may relate to the use of social media or the use of another complimentary service.

RETENTION OF INFORMATION 

TSX holds your information only for as long as necessary for each purpose TSX uses it. TSX uses the following guidelines: –

  • Any time limits set by law or recommended by regulators, professional bodies or associations.

  • Time limits for making a claim.

  • For as long as TSX has a reasonable need for managing its relationship with you or running its organisation.

Complaints and How to contact TSX

If you have any questions about this privacy policy or your rights regarding the processing of your personal information, please email our Data Protection Manager at: 

info@thespinexchange.com

Or in writing to :

Data Protection Officer 

Back Stronger LTD

1st Floor

HealthAid House

Marlborough Hill

Harrow

HA1 1UD

 

Should you have any complaints or queries about anything relating to the privacy of your personal data, or any other data protection issues, please let TSX know using the contact details above and TSX will do its best to deal with them. However, you also have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK’s supervisory authority for data protection issues. The ICO may be contacted on their helpline number which is 0303 123 1113 between 9am and 5pm Monday to Friday, or by other contact methods as set out on their website: www.ico.org.uk.

This policy was last updated on 24 August 2022