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← Go to My Creative Connections Toolkit – Creativity Through Connection & Care
Welcome to mycctoolkit.com (“My CC Toolkit”), the website and online service of Watoto Play Ltd,” (“we”, “our” or “us”). My CC Toolkit is an online creative therapies software platform primarily for mental health care, wellbeing, educational and social care professionals.
My CC Toolkit consists of 4 distinct workspaces:
My Creative Workspace
The workspace provides a digital space where therapists and their clients can engage online in creative therapeutic activities. There is a library of therapeutic resources with suggestions on how the resources can be used. Creative artwork can be saved into the server from both the therapist’s and client’s accounts. The client’s account provides access to limited creative resources and the library of “learn more about each resource” is not available to the clients but only to therapists.
My Practical Workspace
This workspace is only available to therapists and consists of a data entry system where the therapist may log electronic health data about their clients, medical history, session notes, and clinical information. Therapists can also add electronic information about supervision, continuous professional development, a to do list and appointment bookings.
My Journal Workspace
This workspace is only available to the therapists’ clients, who may input journaling data about their wellbeing and health, sign consent forms and book appointments with their therapist. A client account can only be created when a therapist invites a client to join. The client account is a child account of the therapists account.
My Community Workspace
In this workspace, therapists can contact their clients via the internal messaging system. Therapists may also contact each other, but not other therapists’ clients.
This Agreement
This page explains the terms by which you may use our online and/or mobile services, website (including My CC Toolkit), materials and software provided on or in connection with the service (collectively the “Service”). By accessing or using our Service (such as by undertaking a free trial or subscribing to a paid plan) you agree to be bound by these Terms of Service, together with our Terms of Website Use and any other terms and policies referred to in these Terms of Service and/or our Terms of Website Use (“Agreement”).
In the event of any conflict between these Terms of Service and any other terms applicable to our Service these Terms of Service shall prevail, but only to the extent of the specific conflict in question.
Our Service
The Service is a fully hosted application accessible via the internet. The materials, software and database are hosted in a secure data centre located in the U.K in accordance with our Privacy Policy at https:// mycctoolkit.com/privacy-policy/. The Service is provided by, set up, managed and maintained by us and our appointed GDPR and HIPAA Compliant hosting partners.
To access the Service you must have an internet connection. If you have problems with your own local internet connection this will affect your access to the Service. In the event of your local internet connection not being available you will be unable to access the Service.
Periodically, we may make changes, add functionality, issue maintenance releases or introduce new features to the Service. These changes are made expressly at our discretion and where appropriate we will document these changes if they are material in nature.
Membership Levels
There are 4 membership levels available to access My CC Toolkit:
• Therapists, Teachers, Social Care Professionals (known as Therapist Users);
• Clients (also known as patients or team members); and
• Resource Creators.
• Organisations with customised accounts
Together these users are referred to as wp-signup.phped Users.
Your application to be a wp-signup.phped User constitutes an offer to purchase the Service in accordance with this Agreement. Your order will be deemed to be accepted when we allow you to use the Service on subscribing for the Services whether on a full or a trial basis at which point this Agreement shall come into existence.
Therapist User
For U.K
To become a Therapist User, you must be Level 4 and above qualified and hold a current membership with one of the following professional bodies
For The U.K and Rest of World Excluding North America:
For USA:
You license number will be checked prior to your account being verified.
(each a “Professional Body)
This list is not exclusive and if you are unsure please send support a message to enquire.
You must also be approved by us. We may ask for confirmation of your membership with a Professional Body at any time, which you must provide promptly. You must pay all subscription fees or charges when due. You agree that you will not be entitled to any refund in the event that we do not approve you as a Therapist User, or in the event that we suspend or terminate your access to My CC Toolkit. The approval process will be made available to you after you apply for to be a Therapist User. We reserve the right to refuse any individual from being a Therapist User at our sole discretion.
We may suspend or terminate your status as a wp-signup.phped User and/or access to My CC Toolkit in the event that we reasonably believe you are no longer eligible to be a wp-signup.phped User or you otherwise breach this Agreement.
Use of Our Service
You may use the Service only if you are a wp-signup.phped User and only in compliance with this Agreement and all applicable national, and international laws, rules, and regulations.
You must be 13 years old or older to use or access the Service. If you are under 13 years old, your use of the Service must be directly supervised by your parent or guardian or another authorised adult (e.g. a therapist or teacher) who agrees to be bound by this Agreement.
Any use or access to the Service by anyone under 13 who is not directly supervised by an adult is strictly prohibited and in violation of this Agreement. The Service may not be available to any individuals previously removed, suspended or barred from the Service by us.
By using the Service, you represent and warrant that you have the full right, power and authority to enter into this Agreement and to fully perform all of your obligations hereunder. You further represent and warrant that you are under no legal disability or contractual restriction that prevents you from entering into this Agreement.
My CC Toolkit Account
Your My CC Toolkit account gives you access to the Service and functionality that we may establish and maintain from time to time and in our sole discretion.
We may maintain different types of accounts for different types of wp-signup.phped Users. If you open a My CC Toolkit account on behalf of a company, organisation, or other entity, then (a) “you” includes you and that entity, and (b) you represent and warrant that you are an authorised representative of the entity with the authority to bind the entity to this Agreement, and that you agree to this Agreement on the entity’s behalf. By connecting to My CC Toolkit with a third-party service, you give us permission to access and use your information from that service as permitted by that service, and to store your log-in credentials for that service.
You may never use another wp-signup.phped User’s My CC Toolkit account without permission. When creating your My CC Toolkit account, you must provide accurate and complete information.
You are solely responsible for the activity that occurs on your My CC Toolkit account, and you must keep your My CC Toolkit account password secure.
We provide 2 factor authentication, permit logins from one device only and provide training to help keep your account secure.
We encourage you to use “strong” passwords (passwords that use a combination of upper and lower case letters, numbers and symbols) with your My CC Toolkit account.
You may not allow any other party to access or use the Service with your unique username, password, or other security code. You must notify us immediately of any breach of security or unauthorised use of your My CC Toolkit account at [email protected]. We will not be liable for any losses caused by any unauthorised use of your My CC Toolkit account.
Group Accounts
Certain portions of the Service may allow you to create or contribute to group accounts (“Group”). Access to a Group will be made available only to those wp-signup.phped Users who are authorised by the creator or controller of the Group (“Group Owner”). The Group Owner will be responsible for adding wp-signup.phped Users to the group, for managing permissions for authorised wp-signup.phped Users, and otherwise for managing the account as set forth in this Agreement.
Your My CC Toolkit Account Preferences
You may control your wp-signup.phped User profile and how you interact with the Service by changing the settings in your My CC Toolkit account. By providing us with your email address you consent to our using the email address to send you Service-related notices, including any notices required by law, in lieu of communication by postal mail.
We may also use your email address to send you other messages, such as changes to features of the Service and special offers. If you do not want to receive such email messages, you may opt out or change your preferences in your settings page. Opting out may prevent you from receiving email messages regarding updates, improvements, or offers.
My CC Toolkit Customised Account
For organisation accounts you may request for your account to be customised to include features such as data tables, digital forms, assessment tools and reports. These customisations are at the discretion of Watoto Play Ltd – the sole owners of My CC Toolkit. For such customisations you will communicate with our development team on our www.myeasyfile.uk platform.
By instructing us of customisations and us accepting your instructions you will be bound by our Service Level Agreement which can be found in your My Easy File account.
Privacy
We only use any personal data we collect about you through your use of My CC toolkit and the Services in the ways set out in our Privacy Policy
Our Privacy Policy includes further details of circumstances in which you will be the data controller of the personal data you contribute to My CC Toolkit. Acceptable Use
Our Acceptable Use Policy applies to your use of My CC Toolkit.
Changes to the Service
We may, without prior notice, change the Service, stop providing the Service or features of the Service, to you or to wp-signup.phped Users generally, or create usage limits for the Service. We may permanently or temporarily terminate or suspend your access to the Service without notice and liability for any reason, including if in our sole determination you violate any provision of this Agreement, or for no reason. Upon termination for any reason or no reason, you continue to be bound by this Agreement. If your account is terminated for any reason, you must obtain written authorisation from us prior to establishing another account. If you attempt to establish another account without obtaining such authorisation, we may permanently ban you from the Service. You may not have more than one active account at any time without our written consent in each instance.
You are solely responsible for your interactions with other My CC Toolkit wp-signup.phped Users. We reserve the right, but have no obligation, to
monitor disputes between you and other wp-signup.phped Users. We shall have no liability for your interactions with other wp-signup.phped Users, or for any wp-signup.phped User’s action or inaction.
Anti-discrimination
We do not support and will not tolerate the Service being used to discriminate against others, especially when based on race, religion, sex, sexual orientation, age, disability, ancestry or national origin. You are not permitted to use the Service in a manner which would or would likely incite, promote or support such discrimination and you must not use the Service to incite or promote hostility or violence. If we believe in our sole determination that your use of the Service is being used to discriminate, especially if based on race, religion, sex, sexual orientation, age, disability, ancestry or national origin, we may permanently or temporarily terminate or suspend your access to the Service without notice and liability for any reason.
Uploading and Publishing User Content to My CC Toolkit.
We take no responsibility and assume no liability for any material, content or interactions (including without limitation any material obtained directly or indirectly from a third party’s website) (“User Content”) that you or any other wp-signup.phped User or third party posts, publishes or prints in using the Service.
You shall be solely responsible for your User Content and the consequences of posting, publishing and printing it, and you agree that we are only acting as a passive conduit for your online distribution and publication of your User Content.
You understand and agree that you may be exposed to User Content that is inaccurate, objectionable, inappropriate for children, or otherwise unsuited to your purpose, and you agree that you shall not be liable for any damages you allege to incur as a result of User Content or your use of either in printed form. If you wish to complain about information and materials uploaded by other users please contact us [email protected].
You agree not to submit or use User Content that:
You agree that any User Content and our use of the same to provide the Service does not and will not violate third-party rights of any kind, including without limitation any Intellectual Property Rights or rights of privacy or publicity. We reserve the right, but are not obligated, to reject and/or remove any User Content that we believe, in our sole discretion, violates these provisions.
In the event that your User Content is alleged to be offensive, inappropriate for children, unlawful or otherwise in breach of these terms, you agree that we may disclose such User Content to law enforcement or other government authorities.
For the purposes of this Agreement, Intellectual Property Rights means patents, utility models, rights to inventions, copyright and related rights, trademarks and service marks, trade names and domain names, rights in get-up, goodwill and the right to sue for passing off or unfair competition, rights in designs, rights in computer software, database rights, rights to preserve the confidentiality of information (including know-how and trade secrets) and any other intellectual property rights, including all applications for (and rights to apply for and be granted), renewals or extensions of, and rights to claim priority from, such rights and all similar or equivalent rights or forms of protection which subsist or will subsist, now or in the future, in any part of the world.
My Community Workspace
The Community Workspace (“Community”) is a forum for Therapist Users only that wish to discuss or view online discussions on My CC Toolkit services and products. Therapist Users can share and view information, questions and comments from other Therapist Users, as well as follow, message and recognise other Users and review and recognise their posts (“Community Content”). Community Content will become public globally (including places without the same data protection as where you live).
My Community Workspace Guidelines
To participate in the Community, you must be over 18 and comply with the Community Guidelines, as amended from time to time.
Retention of Community Content
Please carefully consider the information you include on the Community and understand that even after you close your account on the Community or My CC Toolkit, your posts and other information will remain in anonymised form. To request removal of your information from the Community, please contact [email protected]. If we are unable to remove any of your information, we will let you know why.
Moderation
In addition to our other rights in this Agreement, we may comment on, move, correct, delete, edit or refuse to publish your Community Content to ensure it is accurate, not misleading and complete, to comply with this Agreement and our Community Guidelines or maintain the quality of the Community in our sole discretion.
Third Party Content
If you share a third party’s content on the Community, you must ensure you are permitted to do so under the laws applicable to you (including having a licence or their consent) and provide attribution (unless the third party waives this right or hasn’t consented to their personal information being shared on the Community).
Feedback
You may choose to, or we may invite you to, submit comments or ideas about the Service (including on the Community), including without limitation about how to improve the Service or our products (“Ideas”). By submitting any Idea, you agree that your disclosure is gratuitous,
unsolicited and without restriction and will not place us under any fiduciary or other obligation, and that we are free to use the Idea without any additional compensation to you, and/or to disclose the Idea on a non-confidential basis or otherwise to anyone. You further acknowledge that, by acceptance of your submission, we do not waive any rights to use similar or related ideas previously known to us, or developed by our employees, or obtained from sources other than you.
Paid Services
Certain aspects of the Service may be provided for a fee or other charge (“Paid for Service”). If you elect to use paid aspects of the Paid for Service, you agree to the pricing and payment listed for the Paid for Service which we may update from time to time. We may add new services for additional fees and charges, or amend fees and charges for existing services, at any time in its sole discretion; however, any price changes or changes to your subscription plans will apply no earlier than 30 days following notice to you.
All payments must be made by Stripe online payment system (https://stripe.com/). You acknowledge that Stripe is provided by a third party provider and agree that we shall have no liability for any loss, damages or costs incurred or suffered by you in using such third party service.
No Refunds
You may cancel your My CC Toolkit account at any time; however, there are no refunds for cancellation. In the event that we suspend or terminate your account (or you fail to successfully complete any approval process for membership) or this Agreement, you understand and agree that you shall receive no refund or exchange for any credits, any unused time on a subscription, any license or subscription fees for any portion of the Service, any content or data associated with your account, or for anything else.
Payment Information
All information that you provide in connection with a purchase or transaction or other monetary transaction interaction with the Service must be accurate, complete, and current. You agree to pay all charges associated with that transaction, including those incurred by users of your credit card, debit card, or other payment method used in connection with a purchase or transaction or other monetary transaction interaction with the Service at the prices in effect when such charges are incurred. You will pay any applicable taxes, if any, relating to any such transaction interactions.
Free Trials
We may offer free trials for certain paid subscription Services to allow you to try and trial our Service. My CC Toolkit reserves the right to set eligibility requirements for free trials.
At the end of your free trial period, we will charge the relevant subscription fee for the next billing cycle to your nominated payment method, unless you cancel your subscription prior to such fee becoming due.
Security
We care about the integrity and security of your personal information. However, we cannot guarantee that unauthorised third parties will never be able to defeat our security measures or use your personal information for improper purposes. You acknowledge that you provide your personal information (and if applicable, any personal information of a third party, such as your client) at your own risk.
Technology Limitations and Modifications
We will make reasonable efforts to keep our Service operational. However, certain technical difficulties, maintenance, or any other cause beyond our reasonable control (including (but not limited to) failure of the internet, natural disaster, labour shortage or dispute, or governmental act) may, from time to time, result in interruptions. We reserve the right at any time and from time to time to modify or discontinue, temporarily or permanently, functions and features of our Service with or without notice. You agree not to hold us liable for any such failure or delay in performance and we agree to make all reasonable efforts to restore our Service (or any part thereof) as soon as practicable. Following any disruption within our reasonable control we shall extend your access to any applicable Paid for Services for at least the duration for which those Paid for Services were inaccessible on written request to [email protected].
Third-Party Links
The Service may contain links to third-party websites, advertisers, services, special offers, or other events or activities, that are not owned or controlled by us.
We do not endorse or assume any responsibility for any such third-party apps, sites, information, materials, products, or services. If you access a third-party app or website from the Service, you do so at your own risk, and you understand that this Agreement and our Privacy Policy do not apply to your use of such sites.
You expressly relieve us from any and all liability arising from your use of any third-party app, website, service, events, training or content. Additionally, your dealings with or participation in promotions of advertisers found on the Service, including payment and delivery of goods, and any other terms (such as warranties) are solely between you and such advertisers. You agree that we shall not be responsible for any loss or damage of any sort relating to your dealings with such advertisers.
Our Responsibility for Loss or Damage Suffered by You
Whether you are a consumer or a business user, we do not exclude or limit in any way our liability to you where it would be unlawful to do so. This includes liability for death or personal injury caused by our negligence or the negligence of our employees, agents or subcontractors and for fraud or fraudulent misrepresentation.
Paid for Services
If you are using the Paid for Services: · Subject to the other exclusions and limitations of our liability in this Agreement, we are responsible to you for foreseeable loss and damage caused by us. If we fail to comply with this Agreement, we are responsible for loss or damage you suffer that is a foreseeable result of our breaking this Agreement or our failing to use reasonable care and skill, but we are not responsible for any loss or damage that is not foreseeable. Loss or damage is foreseeable if either it is obvious that it will happen or if, at the time this Agreement was made, both we and you knew it might happen.
We will also not be liable for:
Our liability to you shall be limited to the fees you have paid to us in the preceding 12 months, or where you have held a My CC Toolkit account for less than 12 months, the fee payable by you for your first year of access to the Paid for Services.
Other Services
For all Services which are not Paid for Services, the exclusions and limitations of liability set out in our Terms of Website Use shall apply.
General Principles
Whether using the Paid for Services, or any other of our Services
Indemnity
You agree to defend, indemnify and hold harmless us and our subsidiaries, agents, licensors, managers, and other affiliated companies, and their employees, contractors, agents, officers and directors, from and against any and all claims, damages, obligations, losses, liabilities, costs or debt, and expenses (including but not limited to legal fees) arising from: (i) your use of and access to the Service, including any data or content transmitted or received by you; (ii) your violation of any term of this Agreement, including without limitation your breach of any of the representations and warranties above; (iii) your violation of any third-party right, including without limitation any right of privacy, publicity, or Intellectual Property Rights; (iv) your violation of any applicable law, rule, or regulation; (v) any claim or damages that arise as a result of any use of your User Content, or any content that is submitted via your account; or (vi) any other party’s access and use of the Service with your unique username, password, or other appropriate security code.
Intellectual Property Rights
Subject to the terms and conditions of this Agreement, on becoming a wp-signup.phped User you are granted a non-exclusive, limited, non-transferable, terminable and freely revocable licence to use the Service and the content on My CC Toolkit as permitted by the features of the Service. We reserve all rights not expressly granted herein in the Service and in the content on My CC Toolkit and all the Intellectual Property Rights therein shall remain owned by us or our licensors. This licence will terminate when you cease to be a wp-signup.phped User, or otherwise on notice from us.
Additional terms may apply for any content that you download from, upload to or print from the Service. Any such additional terms will be made available to you prior to initiating any applicable uploads, downloads or prints.
The layout, design, content and graphics on My CC Toolkit are protected by UK and other international copyright laws. Unless expressly permitted in writing and other than printing a small proportion of content or displaying this on your screen or both, (strictly for your personal non-commercial use), no part of My CC Toolkit may be reproduced or stored in any medium, including but not limited to a retrieval system, or transmitted, in any form or by any means (electronic, mechanical, photocopying, recording, broadcasting), nor shown in public. You may not create any derivative work or make any other adaptation, without our prior written consent. You must not modify the copies you have displayed or printed in any way and you may not use any illustrations, photographs, videos or audio sequences or any graphics separately from any accompanying text.
If you print off or download any material from My CC Toolkit in breach of this Agreement, your right to use My CC Toolkit will cease immediately and you must at our option return or destroy any copies of the materials you have made. All rights not expressly granted in these terms or any express written license, are reserved. For all other uses of our content or images you must contact us and obtain our prior written permission.
Which Country’s Laws Apply to Any Disputes?
This Agreement, its subject matter and formation (and any non-contractual disputes or claims) are governed by the law of England and Wales. We both agree to the exclusive jurisdiction of the courts of England.
My CC Toolkit © Owned by Watoto Play Ltd. U.K Reg. No: 13150637
Introduction
Welcome to Watoto Play Limited’s (“Our Company”) privacy policy. We know that you do care on how information about you is used and shared.
Our Company is wholly committed to protecting and respecting the privacy of all our therapists, clients, customers, partners and the end users of our services and website.
Our Company’s privacy policy will inform you how we collect, use, maintain and disclose information collected from users of our website – mycctoolkit.com (“Our Website”).
Important information about our policies
This privacy policy aims to give you information on how Our Company collects and processes your personal data through your use of Our Website, including any data you may provide (about yourself of a third party) through Our Website when you sign up as a wp-signup.phped user.
This privacy policy together with:
and any other documents referred to in the Terms of Service and/or the Terms of Use Policy sets out the basis on which any personal data Our Company collects from you, or that you provide to Our Company, whether through Our Website or when you use our Services will be processed by us.
It is necessary that you read our privacy policy together with any other privacy policy or fair processing policy we may provide on specific occasions when we are collecting or processing personal data. This is so that you are fully aware of how and why we are using your data. Our privacy policy supplements other notices and privacy policies and is not intended to override them.
Children’s Privacy
This site is not intended for minors and we do not knowingly collect or solicit personal information from anyone under the age of 13. Therapist members of Our Website may submit information of children, subject to the conditions described below.
Changes to the privacy policy, and your duty to inform us of changes
We keep our privacy policy under regular review. We reserve the right to make changes to our privacy policy from time to time to acknowledge:
Accordingly, we suggest that you regularly check this page to ensure that you continue to be comfortable with the measures that we are taking to protect your privacy.
This policy was last updated on 20th January 2022.
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.
Our Company as controller
Except as described below in this privacy policy, Our Company will be the controller and responsible for your personal data. 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).
As controller, Our Company determines the purposes for which and the manner in your personal data is, or is to be, processed.
In this policy we describe the types of processing we may undertake with respect to your personal data.
The kind of information we may hold
As controller, we do not collect any 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). Nor do we collect any information about criminal convictions and offences.
We may also hold personal data submitted by our customers of their clients (“Client Data”). We will hold this Client Data as processor, and the relevant customer will be
the controller. The terms applicable to Client Data are described below in the section, The Customer as Data Controller, the Company as Data Processor.
How is your personal data collected?
We use different methods to collect data from and about you including through:
How we will use personal data
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:
Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by email.
Promotional offers from us
We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you (we call this marketing).
You will receive marketing communications from us if you have requested information from us or purchased services from us and you have not opted out of receiving that marketing.
Third-party marketing
As a general rule we do not share your personal data with any third party for marketing purposes. However if we do in the future we will get your express opt-in consent before we share your personal data with any third party for marketing purposes.
Opting out: You can ask us or third parties to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you.
Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of service purchase or other transaction.
Change of purpose
We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.
If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
Disclosures of your personal data
We may share your personal data with the parties set out below for the purposes set out in the table above.
· service providers acting as processors based provide IT, hosting and system administration services;
· professional advisers including lawyers, bankers, auditors and insurers based in who provide consultancy, banking, legal, insurance and accounting service;
· HM Revenue & Customs, regulators and other authorities who require reporting of processing activities in certain circumstances;
· Payment service providers, including Stripe (https://stripe.com/);
· Third parties to whom we may choose to sell, transfer or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy policy;
· Other third parties:
We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use
your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.
Where the Company will store personal data
We may hold personal information in electronic databases, such as our customer relationship management system. We take all reasonable steps to keep any personal information we hold about you (and any Client Data you submit) secure. All information which is provided to, or collected by, Our Company is:
Data security
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. 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.
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. Your data is encrypted on our servers during transit and at rest.
Passwords and Security
Where we have given you (or where you have chosen) a password which enables you to access your account, you are responsible for keeping this password confidential. Our Company asks you not to share a password with anyone.
Unfortunately, the transmission of information via the internet is not completely secure. Although the Company will do its best to protect your personal data, the Company cannot guarantee the security of your data transmitted via Our Website; any transmission is at your own risk.
Once Our Company has received your information, Our Company will use strict procedures and security features to try to prevent unauthorised access.
Security Best Practices
To assist with the security of your personal data you should:
How long Our Company will use personal data?
Our Company will retain your personal data for:
We may retain Customer Data where such retention is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.
Your rights as a data subject
Under certain circumstances, if you are an individual in respect of whom Our Company processes Personal Data, you have the following rights. Please note that this is a summary of your rights. If you wish to understand your rights in detail you should read the relevant laws of your country, guidance and regulations for a fuller explanation.
You have the right to:
No fee usually required: You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances.
What we may need from you: We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
Time limit to respond: We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
Withdrawal of consent
In any cases where the legal basis for our processing of your Personal Data is consent, you have the right to withdraw that consent at any time. Such withdrawal will not affect the lawfulness of any processing before you withdraw consent.
If you fail to provide personal information
If you, the Customer, fail to provide certain information when requested, Our Company may not be able to perform the Services and any contract we have entered into with you or we may be prevented from complying with our legal obligations. In which case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.
Third Party Links
The Website may, from time to time, contain links to and from the websites, plug-ins and applications of our partner networks, advertisers and affiliates. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. Please note that we do not control these third-party websites, which may have their own privacy policies, and that we are not responsible for their privacy statements.
When you leave Our Website, we encourage you to read the policy statement of every website you visit.
You are the controller of Client Data
Where you input Client Data to Our Website, which may be collected, stored and processed as a result of your use of the services, you will be the controller of the Client Data. Our Company will be a processor only. In cases where you are collecting, storing and processing Patient or client Data you will determine the purposes for which and the manner in which that Client Data is, or is to be processed.
You will also be responsible for:
Your Client Data is to be distinguished from Customer Data which Our Company has collected from you (our Customer). For example, you may have agreed to our collection, use, transfer and storage of Customer Data (including data of your staff) for Our Company’s own business purposes including administration of contractual arrangements, sales and marketing.
Conditions for Processing
You will ensure that you have all necessary appropriate consents and notices in place to enable lawful transfer of the Client Data to Our Company and/or lawful collection of the Client Data by Our Company on your behalf for the duration and purposes of the services we provide to you.
Our Company shall, in relation to any Client Data processed in connection with the performance by Our Company of the services we provide to you:
Applicable Laws with respect to security, breach notifications, impact assessments and consultations with supervisory authorities or regulators;
You acknowledge that Our Company uses various third-party suppliers to provide functionality within Our Website for your optional use to deliver and send text and email messages. You accept that such use will be in accordance with the third-party suppliers’ terms and conditions and their respective privacy policies.
You will ensure that you have obtained consent from any individual, or other authority, to share that individual’s Client’s Data via these communications.
Our Company confirms that it will notify you if it proposes to enter into any agreements with any third-party processor. In such cases, a written agreement with the third party processor will be entered into incorporating terms which are substantially similar to those set out in this privacy policy for processing by that third party.
You hereby consent to the following third party processors processing Client Data as part of our service.
At any time on not less than 28 days’ notice, Our Company may revise this part of the privacy policy by replacing it with any applicable controller to processor standard clauses or similar terms forming part of an applicable certification scheme (which shall apply when this policy is updated).
Our Company is not liable in respect of any Client Data which is controlled by you in breach of the Applicable Laws or outside the scope of the permissions granted to you by your client.
Client Data
Client Data, which may be personal data you enter and save into Our Website about your clients when using Our Website and our services. It may also be personal data your client enters and save’s directly into a Client Account. The personal data entered may include, but is not limited to:
and other information necessary for the operation of our services and/or Our Website.
This Client Data may be supplied by you when you:
This Client Data may be processed by us for the purposes of:
Our Processing of Client Data
The legal basis for this processing is:
We will assist you in any audit of our processing of Client Data, on your reasonable written notice and at reasonable times.
Duration of Processing
Where we are the processor, Our Company will only process Client Data in accordance with the conditions for processing set out in this policy.
We shall only process Client Data while our contract with you is continuing and shall cease such processing:
Following completion of the services we may retain the Client Data for a maximum period of 45 days from the date the Services end, unless you instruct us otherwise.
Contact
Questions, comments and requests regarding this privacy policy are welcomed and should be addressed to [email protected].
If you have any questions or have a complaint about this privacy policy please let us know us 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 at: [email protected]
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