CryoCube is committed to protecting and respecting your privacy. CryoCube understands that your personal data is entrusted to us and appreciates the importance of protecting and respecting your privacy.
What personal data may we collect from you?
When we refer to personal data in this policy, we mean information that can or has the potential to identify you as an individual. We may hold and use personal data about you as a customer or in any other capacity e.g. when you visit our websites, complete a form, access our services or speak to us.
Personal data we collect from you may include the following:
- Information that you give us when you enquire or become a customer or apply for a job with us including name, address, contact details (including email address and phone number)
- The name and contact details (including phone number) of your next of kin
- Details of services and/or treatment you have/may received from us
- Information obtained from customer surveys, promotions and competitions that you have entered or taken part in
- Recordings of calls we receive from you or make to you in the CryoCube
- Details of your attendance at the CryoCube
- Any information about complaints and incidents concerning you
- Information you give us when you make a payment to us for use of the CryoCube services
- Any other information received from other sources, including from your use of websites and other digital platforms we operate or the other services we provide
Where you use any of our websites, we may automatically collect personal data about you including:
- Technical information, including the Internet protocol (IP) address used to connect your computer to the Internet, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform,
- Information about your visit, including the full Uniform Resource Locators (URL), clickstream to, through and from our site (including date and time), products you viewed or searched for, page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), methods used to browse away from the page.
The data that we request from you may include special category data. This includes information that relates to the following:
- racial or ethnic origin, or
- political opinions, or
- religious or philosophical beliefs, or
- trade union membership, or
- genetic data, biometric data for the purpose of uniquely identifying a natural person, or
- health data,
- or data concerning a natural person’s sex life or sexual orientation.
When do we collect personal data about you?
We may collect personal data about you if you:
- Visit one of our websites
- Enquire about any of our services via phone; email; website and/or any other media
- Fill in a form or survey for us
- Participate in any marketing activity
- Make online payments
- Contact us by email, telephone, social media or any other media
- Participate in interactive features on any of our websites
What personal data we may receive from third parties and other sources?
We may collect personal data about you from third parties such as:
- If you are an employee of one of our corporate clients who has taken up one of our services, we may
be passed your name, contact number and email address, in order to get in touch with you to arrange an appointment or collect further information from you;
- Your work/business contact information e.g. name, job title, address, email, contact number, which may have been collected from agencies, partner organisations or other third parties, for the purpose of business to business marketing activity, to allow CryoCube to provide you with direct marketing communication about relevant products or services to you in your professional capacity or your organisation
How do we lawfully process your personal data?
Set out below are some of the ways in which we process personal data although to do so lawfully we need to have a legal ground for doing so. We normally process personal data if it is:
- Necessary to provide you with our services – to enable us to carry out our obligations to you arising from any contract entered into between us and you including relating to the provision by us of services or treatments to you and related matter such as billing, accounting and audit, credit or other payment card verification and anti-fraud screening
- In our or a third party’s legitimate interests to do so – see details below. For further information about direct marketing to businesses and legitimate interest, please see the ‘Marketing’ section below
- Required or allowed by any applicable law
- With your explicit consent for example: direct consumer marketing communications.
Generally, we will only ask for your consent to processing if there is no other legal grounds to process. In these circumstances, we will always aim to be clear and transparent about why we need your consent and what we are asking it for. Where we are relying on consent to process personal data you have the right to withdraw your consent at any time by contacting us using the details below and we will stop the processing for which consent was obtained.
To process special category data we rely on additional legal grounds and generally, they are as follows:
With your explicit consent
- It is necessary to establish, make or defend legal claims or court action
- It is necessary so that we can comply with employment law
- It is necessary for a public interest purpose in line with any laws that are applicable.
Processing of personal data which you have made public:
As stated above, one of the legal grounds for processing data is where it is in our legitimate interest to do so, taking into account your interest’s rights and freedoms. This allows us to manage the relationship that exists between you and us and can include the following reasons:
- Provide you with information, products or services that you request from us
- Allow you to participate in interactive features of our services
- Notify you about changes to our products or services
- Keep our records up to date
- Respond to requests where we have a legal or regulatory obligation to do so
- To conduct and analyse market research
- To ensure that content from any of our websites is presented in the most effective manner for you and for your computer
- To share your personal information with people or organisations in order to run our business or comply with any legal and/or regulatory obligations including to defend ourselves from claims, exercise our rights and adhere to laws and regulations that apply to us and the third parties we work with
- To take part in, or be the subject of, any sale, purchase, merger or takeover of all or part our business
- To personalise the marketing emails we send you, where you have consented to us doing so
- To administer your membership to a CryoCube service
- To monitor your usage of our CryoCube service
The security of your personal data
We protect all personal data we hold about you by ensuring that we have appropriate organisational and technical security measures in place to prevent unauthorised access or unlawful processing of personal data and to prevent personal data being lost, destroyed or damaged.
Any personal data you provide will be held for as long as is necessary having regard to the purpose for which it was collected and in accordance with all applicable UK laws.
All information you provide to us is stored securely. Any payment transactions on our website will be processed securely by third party payment processors. Where we have given you (or where you have chosen) a password that enables you to access certain parts of our website, you are responsible for keeping that password confidential. We ask you not to share a password with anyone.
The transmission of information via the internet cannot be guaranteed as completely secure. However, we ensure that any information transferred to our websites is via an encrypted connection. Once we have received your information, we will use strict procedures and security features to minimise the risk of unauthorised access.
At your request, we may occasionally transfer personal information to you via email, or you may choose to transfer information to us via email. Email is not a secure method of information transmission; if you choose to send or receive such information via email, you are acknowledging the risks associated with doing so.
How long do we retain your personal data?
Unless we explain otherwise to you, we will retain your personal data on the basis of the following guidelines:
- For as long as we have a reasonable business need, such as managing our relationship with you and managing our business
- For as long as we provide services and/or treatment to you and then for as long as someone could bring a claim against us (in general this is a period of 8 years); and/or
- In line with legal and regulatory requirements or guidance.
Disclosure of your personal data to third parties
In the usual course of our business we may disclose your personal data (which will be limited to the extent reasonably necessary) to certain third party organisations that we use to support the delivery of our services. This may include the following:
- Organisations providing IT systems support and hosting in relation to the IT systems on which your information is stored,
- Third party debt collectors for the purposes of debt collection,
- Third party service providers for the purposes of storage of information and confidential destruction, third party marketing companies for the purpose of sending marketing emails, subject to having an appropriate lawful basis for such processing.
Where a third-party data processor is used, we ensure that they operate under contractual restrictions with regard to confidentiality and security, in addition to their obligations under Data Protection Laws.
We may also disclose your personal data to third parties in the event that we sell or buy any business or assets or where we are required by law to do so.
Special Category/Health information collected during provision of treatment or services
What do we do with any non-personal information collected when accessing the website?
We may also use other companies to set cookies on our websites and gather cookie information for us – please refer to the information detailed below. From time to time we may also analyse Internet Protocol (IP) addresses or other anonymous data sources.
By law, website operators are required to ask for a website user’s permission when placing certain kinds of cookie on their devices for the first time.
Where consent is required, the law states that it should be “informed consent”, which means we must ensure that you understand what cookies are and why we want to use them.
What are Cookies?
Cookies are text files containing small amounts of information which are downloaded to your device when you visit a website. Cookies are then sent back to the originating website on each subsequent visit, or to another website that recognises that cookie. Cookies are useful because they allow a website to recognise a user’s device.
Cookies do lots of different jobs, like letting you navigate between pages efficiently, remembering your preferences, and generally improving your user experience.
They can also help to ensure that adverts you see online are more relevant to you and your interests.
CryoCube carries out two types of direct marketing: 1) Business to Consumer (B2C) which means, if you engage with CryoCube in your capacity as an individual then we may process your personal data for marketing purposes but only if we have your prior consent to do so; and 2) Business to Business (B2B) which means, if you engage with CryoCube in your professional capacity e.g. if you represent a company with whom CryoCube has an existing or prospective business relationship, CryoCube may keep you up to date with services we offer/provide.
Our premises are surveyed by CCTV for the purposes of security. Images and videos may be retained for 30 days in accordance with ICO guidelines.
Your Rights under Data Protection Laws
The law gives you certain rights in respect of the personal data that we hold about you as well as information about what we do with it, who we share it with and how long we will hold it for. We may make a reasonable charge for additional copies of that data beyond the first copy, based on our administrative costs. The website of the Information Commissioner’s Office (http://www.ico.org.uk) has a wealth of useful information in respect of your rights in your personal data. In addition to your right to stop marketing, detailed above, below is a short overview of the most commonly-used rights.
- Data Subject Access Request – With some exceptions designed to protect the rights of others you have the right to a copy of the personal data that we hold about you as well as information about what we do with it, who we share it with and how long we will hold it for. We may make a reasonable charge for additional copies of that data beyond the first copy, based on our administrative costs.
- The Right of Erasure (‘Right to be Forgotten’) – the right to have your personal information erased where we have no reason to continue processing;
- Data Portability – the right to move, copy or transfer personal information you have provided to us;
- Rights in relation to automated decision making which has a legal effect or otherwise significantly affects you.
- Right to Rectification – You have the right to have the personal data we hold about you corrected if it is factually inaccurate. If any of your personal data has changed, especially contact information such as: email address, postal address and phone number please get in touch with CryoCube immediately so we can ensure your personal data is kept up to date.
If you want to exercise your rights in respect of your personal data, the best way to do so is to write to us for the attention of the data protection officer at the address on the CryoCube website.