Pregma Ltd understands that your privacy is important to you and that you care about how your personal data is used. We respect and value the privacy of everyone who visits this website, www.pregma.co.uk (“the Pregma Site”) and will only collect and use personal data in ways that are described here, and in a way that is consistent with our obligations and your rights under the law. The information set out here also applies to any information you give us by telephone or by mail.
1. Definitions and Interpretation
In this Policy the following terms shall have the following meanings:
“Account” means an account required to access and/or use certain areas and features of the Pregma Site;
“Cookie” means a small text file placed on your computer or device by the Pregma Site when you visit certain parts of it and/or when you use certain features. Details of the Cookies we use are set out in section 12, below;
“Cookie Law” means the relevant parts of the Privacy and Electronic Communications (EC Directive) Regulations 2003 (or any update of or replacement for these regulations).
2. Information About us
The Pregma Site is owned and operated by Pregma Ltd, a limited company registered in England and Wales under company number 11832444
Registered address: 1121 19 St George Wharf, London, England, SW8 2FG
VAT number: 333175910
Data Protection Officer: Faezeh SAFARI
Email address: Info@pregma.co.uk
Telephone number: 0203 608 2031
3. Your rights
You have the following rights, which you may exercise at any time by contacting us as set out in section 13 below:
b) The right to access (receive a copy of) the personal data we hold about you.
c) The right to have your personal data corrected if any of your personal data held by us is inaccurate or incomplete.
d) The right to be forgotten, i.e., the right to ask us to delete all your personal data that we hold (unless we are still providing services to you).
e) The right to restrict (i.e. prevent) the processing of your personal data.
f) The right to object to us using your personal data for a particular purpose or purposes.
g) The right to withdraw consent. This means that, if we are relying on your consent as the legal basis for using your personal data, you are free to withdraw that consent at any time.
h) The right to data portability. This means that, if you have provided personal data to us directly, we are using it with your consent or for the performance of a contract, and that data is processed using automated means, you can ask us for a copy of that personal data to re-use with another service or business in many cases. As Pregma provides a personal service, it is unlikely that this will be applicable.
i) Rights relating to automated decision-making and profiling. We do not use your personal data in this way.
For more information about Pregma’s use of your personal data or exercising your rights as outlined above, please contact us using the details provided in section 13.
It is important to us that your personal data is accurate and up-to-date. If any of the personal data we hold about you changes, please let us know.
Further information about your rights can also be obtained from the Information Commissioner’s Office (the UK body responsible for data protection regulation) or your local Citizens Advice Bureau.
If you have any cause for complaint about our use of your personal data, you have the right to lodge a complaint with the Information Commissioner’s Office who you can reach at ico.org.uk or at 0303 123 1113. We would welcome the opportunity to resolve your concerns ourselves, however, so please contact us first, using the details in section 13.
4. What Data Do You Collect and How?
Depending upon your use of the Pregma Site and/or any telephone contact between us, we may collect and hold some or all of the personal and non-personal data set out in the table below, by the methods set out in the table. Please also see section 12 for more information about Cookies and similar technologies. We do not collect any data relating to criminal convictions and/or offences.
|Data Collected||How we Collect the Data|
|Identity Information including name, title, date of birth, gender.||When you send us an enquiry via our website or telephone. Also, when you complete a registration form.|
|Contact information including email, postal address, contact telephone number.||When you send us an enquiry via our website or telephone. Also, when you complete a registration form.|
|Business information including business name, professional services provided.||When you send us an enquiry via our website or telephone. Also, when you complete a registration form.|
|Payment information including card details.||When you make payment by telephone or through the Pregma website.|
|Technical information including your PC’s internet protocol address, operating system, the pages of our website that you visit, the time and date of your visit, the time spent on those pages.||This is collected as you move through the website by cookies. Please see section 12 for more information on cookies.|
|Medical or health information*||When you request services we may need to ask questions relating to your health|
* Medical or health information is classed as “Special Category” personal data by Data Protection Law. This means that we need to take extra care in our storage and use of this data, and also that we need your specific permission to collect it. When you complete an enquiry form on the Pregma Site, we will ask you for this permission.
We may need to pass this information on to healthcare professionals we introduce you to. Please note that any medical or health information you give directly to a medical professional we introduce you to will not be given by them to Pregma. That is confidential between you and the medical professional.
The Pregma Site is not intended for children and we do not knowingly collect any information from children. If you give us information about your child in order for us to introduce you to a medical professional who can treat them, we will treat that information in the same way as data we collect about you.
5. How Do You Use My Personal Data?
Under the Data Protection Legislation, we must always have a lawful basis for using personal data. The following table describes how we may use your personal data, and our lawful bases for doing so:
|What we do||What Personal Data we use||Lawful Basis|
|Registering you on the Pregma Site.||Name, contact details.||Legitimate interests (provision of our services)|
|Supplying services to you.||Name, contact details, medical information.||Fulfilment of contract.|
|Managing payments for services||Name, contact details, card number.||Fulfilment of contract.|
|Communicating with you (marketing)||Name, contact details.||Legitimate interests (provision of our services)|
|Placing cookies||IP address||Legitimate interests (tracking the use of our website)|
As indicated above, we may use your personal data for marketing purposes, which may include contacting you by email and telephone with information, news, and offers on our services.
We will always work to fully protect your rights and comply with our obligations under the Data Protection Legislation, and each email you receive from us will give you the opportunity to opt-out of email marketing. We will always ask for your permission before sharing your personal data with third parties for marketing purposes, and you will be able to opt-out at any time.
We will only use your personal data for the purpose(s) for which it was originally collected unless we reasonably believe that another purpose is compatible with that or those original purpose(s) and need to use your personal data for that purpose.
In some circumstances, where permitted or required by law, we may process your personal data without your knowledge or consent. This will only be done within the bounds of the Data Protection Legislation and your legal rights.
7.How Long Will You Keep My Personal Data?
We will not keep your personal data for any longer than is necessary in light of the reason(s) for which it was first collected. Your personal data will therefore be kept for the following periods:
|Type of Data||How Long we Keep It|
|Identity Information including name, title, DOB||12 months following the termination of our services.|
|Contact information including postal and email address and contact numbers.||12 months following the termination of our services.|
|Business information including business name and qualifications.||12 months following the termination of our contractual agreement.|
|Payment information including card details.||will be deleted as soon as the payment is received|
8. How and Where Do You Store or Transfer My Personal Data?
We will normally only store and transfer your Data within the UK. If we need to send any of your personal data outside of the UK (for example if we use cloud storage in another country) this will be done in full compliance with UK Data Protection Law, for example by having Standard Contractual Clauses in place with the cloud provider.
The security of your personal data is essential to us, and to protect your data, we take a number of important measures, including the following:
- limiting access to your personal data to those employees, agents, contractors, and other third parties with a need to know and ensuring that they are subject to duties of confidentiality;
- procedures for dealing with data breaches (the accidental or unlawful destruction, loss, alteration, unauthorised disclosure of, or access to, your personal data) including notifying you and/or the Information Commissioner’s Office where we are legally required to do so.
9. Do You Share My Personal Data?
We will not share any of your personal data with any third parties for any purposes, subject to the following exception[s].
In some limited circumstances, we may be legally required to share certain personal data, which might include yours, if we are involved in legal proceedings or in order to comply with legal obligations, a court order, or the instructions of a government authority. We will tell you about this in advance, unless we are not permitted to do so by law.
We will share your personal data with other companies or our Health Care Professionals in our group to ensure the provision of our services.
We may sometimes contract with the following third parties to supply certain information or services:
|Recipient||Activity Carried Out||Sector||Location|
|Health Care Professionals who provide services to our clients.||Introduction to professionals.||Health and Wellbeing care.||UK|
|Accountants||Accounts and invoicing||Accountancy||UK|
|Support service provider||Legal, marketing and administration||Business Support Services||UK|
If any of your personal data is shared with a third party, as described above, we will take steps to ensure that your personal data is handled safely, securely, and in accordance with your rights, our obligations, and the third party’s obligations under the law.
10. Can I Withhold Information?
You may access the Pregma Site without providing any personal data at all (save for automatic cookies, which you can delete or restrict). However, in order to receive our services, we will need to collect personal data from you.
11. How Can I Access My Personal Data?
If you want to know what personal data we have about you, you can ask us for details of that personal data and for a copy of it. This is known as a “subject access request”.
It is helpful to us if a subject access request is made in writing and sent to the email or postal addresses shown in section 13.
We will respond to your subject access request within one month of receiving it. Normally, we aim to provide a complete response, including a copy of your personal data within that time.
In some cases, however, particularly if your request is more complex, more time may be required up to a maximum of three months from the date we receive your request. You will be kept fully informed of our progress.
Please note that we may need to ask for confirmation of your identity in some cases to be certain that we are providing the correct personal data to the correct person.
All Cookies used by and on the Pregma Site are used in accordance with current Cookie Law.
Before Cookies are placed on your computer or device, you will be shown a Cookie alert pop up requesting your consent to set those Cookies. By giving your consent to the placing of Cookies you are enabling us to provide the best possible experience and service to you. You may, if you wish, deny consent to the placing of Cookies; however certain features of the Site may not then function fully or as intended.
The following first-party Cookies (i.e., ones placed by us) may be placed on your computer or device:
|Name of Cookie||Purpose||Strictly Necessary|
|ForceFlashSite||When viewing a mobile site (old mobile under m.pregma.co.uk) it will force the server to display the non-mobile version and avoid redirecting to the mobile site||no|
|smSession||Identifies logged in site members||yrs|
and the following third-party Cookies may be placed on your computer or device (i.e., ones placed by our service providers):
|Name of Cookie||Provider||Purpose|
|c_user||facebook.com||Tracking and Targeting|
|TSxxxxxxxx (where x is replaced with a random series of numbers and letters)||wordpress.com||Security|
|TSxxxxxxxx_d (where x is replaced with a random series of numbers and letters)||wordpress.com||Security|
In addition to the controls that we provide, you can choose to enable or disable Cookies in your internet browser. Most internet browsers also enable you to choose whether you wish to disable all Cookies or only third-party Cookies. For further details, please consult the help menu in your internet browser or the documentation that came with your device.
You can choose to delete Cookies on your computer or device at any time, however you may lose any information that enables you to access the Pregma Site more quickly and efficiently including, but not limited to, login and personalisation settings.
It is recommended that you keep your internet browser and operating system up-to-date and that you consult the help and guidance provided by the developer of your internet browser and manufacturer of your computer or device if you are unsure about adjusting your privacy settings.
13. How Do I Contact You?
To contact us about anything to do with your personal data and data protection, including to make a subject access request, please use the following details:
for the attention of: the Data Protection Officer: Faezeh SAFARI
Email address: firstname.lastname@example.org
Telephone number: 02077354999
we may change this Privacy Notice from time to time. This may be necessary, for example, if the law changes, or if we change our business in a way that affects personal data protection.