Introduction

Welcome to my privacy notice. I, Dr. Siobhan Graham, am a sole trader registered in Northern Ireland, trading under the name Vitalis Health. My registered office is at 58 Howard street, Belfast BT16pj, Northern Ireland. I respect your privacy and am committed to protecting your personal data. This privacy notice will inform you as to how I look after your personal data when you visit my website and/or use my applications (regardless of where you visit or access them from) and tell you about your privacy rights and how the law protects you. This policy is implementing the requirements of the General Data Protection Regulation (the law which protects and controls the use of personal data) and with the Caldicott Principles which are guidelines designed to ensure that all UK patient data remains confidential unless consented to otherwise. I have developed systems and processes to ensure that the standards set out in both documents are met or exceeded.

This privacy notice is provided in a layered format so you can scroll through to the specific areas set out below.

  1. IMPORTANT INFORMATION AND WHO I AM

  2. THE DATA I COLLECT ABOUT YOU

  3. HOW IS YOUR PERSONAL DATA COLLECTED

  4. HOW I USE YOUR PERSONAL DATA

  5. DISCLOSURES OF YOUR PERSONAL DATA

  6. INTERNATIONAL TRANSFERS

  7. DATA SECURITY

  8. DATA RETENTION

  9. YOUR LEGAL RIGHTS

  10. GLOSSARY

1. Important information and who I AM

Purpose of this privacy notice

This privacy notice aims to give you information on how I collect and processes your personal data including through your use of my website and mobile applications, including any data you may provide through my websites or mobile applications including when you sign up to my newsletter, sign up to use any service made available via my’s mobile applications or request or submit any other information from her. Dr. Siobhan Graham’s websites and applications, at the date of inception of this policy are:

Websites

www.vitalishealth.co.uk

Apps

www.securevideo.com

My website and applications are not intended for children (being an individual under the age of 16 years old) alone and do not permit children to open accounts. However, I do permit children to use my services where an individual with parental responsibility registers a child in association and attaches them to their own account. I reserve the right to make enquiries to satisfy myself that you hold appropriate parental responsibly to be able to give clear informed consent for your child and I do not knowingly collect data relating to children without appropriate consent. It is important that you read this privacy notice together with any other privacy notice or fair processing notice I may provide on specific occasions when am collecting or processing personal data about you so that you are fully aware of how and why I am using your data. This privacy notice supplements the other notices and is not intended to override them.


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). I would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact me in the first instance.


Changes to the privacy notice and your duty to inform me of changes
It is important that the personal data I hold about you is accurate and current. Please keep me informed if your personal data changes during your relationship.

Third-party links

Dr. Siobhan Graham’s website and applications may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. I do not control these third-party websites and is not responsible for their privacy statements. When you leave my website, I encourage you to read the privacy notice of every website or service you visit.

2. The data I collect about you

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). 
I may collect, use, store and transfer different kinds of personal data about you which I have grouped together follows:

Non-Special Category of Personal Data

  • Identity Data includes first name, age, maiden name, last name, username or similar identifier, marital status, title, appearance, voice, date of birth and gender and GP details. This may include photographs and videos where required (and agreed to) including those required for consultations.

  • Contact Data includes billing address, delivery address, email address and telephone numbers.

  • Financial Data includes bank account and payment card details.

  • Transaction Data includes details about payments to and from you and other details of services you have purchased or requested from us.

  • Technical Data includes internet protocol (IP) address of your device, your login data, browser type and version, temporary or persistence unique device identifiers, mobile operating system type, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this website and/or application.

  • Profile Data includes your username and password, services requested by you via my applications, including consultation arrangements and request for prescriptions, your interests, preferences, feedback and survey responses.

  • Usage Data includes information about how you use my website, applications, and services including number of visits, length of consultations, interaction with the application and website pages (i.e. clicking page links).

  • Marketing and Communications Data includes your preferences in receiving marketing from me and my third parties and your communication preferences.

I also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, I may aggregate your Usage Data to calculate the percentage of users accessing a specific website or application feature. However, if I combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, I treat the combined data as personal data which will be used in accordance with this privacy notice.

Special Categories of Personal Data

This category of data was previously referred to as Sensitive Personal Data. This type of data is required for the provision of health care services intended to be provided by mywebsite and via myapplications. I may collect:

Medical Data: this may include blood pressure, weight, sexual orientation, glucose levels, test results, repeat prescription information, family information, genetic data, biometric data, medical history or other details contained in your health records.

If you fail to provide personal data

Where I need to collect personal data by law, or under the terms of a contract I have with you and you fail to provide that data when requested, I may not be able to perform the contract I have or are trying to enter into with you (for example, to provide you with an online consultation with a doctor). In this case, I may have to cancel a product or service you have with me but I will notify you if this is the case at the time.

3. How is your personal data collected?

I use different methods to collect data from and about you, including through:

  1. Direct interactions. You may give me your Identity, Contact, Medical, and Financial Data by filling in forms on my website or application or by corresponding with me by post, phone, email or otherwise. This includes personal data you provide when you:

  2. set up a user account;

  3. subscribe to my services;

  4. request and/or use services via your account (i.e. making arrangements for consultation with medical professionals or fulfilment of prescriptions);

  5. Make an order for medications, and/or repeat prescriptions through my app or website;

  6. request marketing to be sent to you;

  7. enter a competition, promotion or survey; or

  8. give me some feedback.

  9. Automated technologies or interactions. As you interact with my website, I may automatically collect Technical Data about your equipment, browsing actions and patterns. I collect this personal data by using cookies, server logs and other similar technologies. Please see the information regarding cookies in this policy.

  10. Third parties. I may receive personal data about you from various third parties as set out below:

  11. Technical Data from the following parties from analytics providers such as Google based outside the EU and from my third party providers for emails and communications.

  12. Contact, Financial and Transaction Data from providers of technical, payment and delivery services such as STRIPE, based outside the EU.

  13. Identity and Contact Data from the electoral roll and similar sources.

  14. Identity and Contact Data from third parties with whom you may be in contact with in reference to applying for a job or position at Now Healthcare Group.

4. How I use your personal data

I will only use your personal data when the law allows me to. Most commonly, I will use your personal data in the following circumstances:

  1. Where I need to perform the contract I am about to enter into or have entered into with you.

  2. Where it is necessary for my legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.

  3. Where processing is necessary for, medical diagnosis, the provision of health or social care or treatment.

  4. Where I need to comply with a legal or regulatory obligation.

Where I use a Special Category of data, including Medical Data, I am required to confirm an additional lawful basis (to that set out above) for the processing of such data which will most commonly include the following circumstances:

  • Where processing is necessary for, medical diagnosis, the provision of health or social care or treatment.

  • Express consent that is freely, affirmatively, and transparently, given with regards to the processing described.

In addition to the data protection laws which I adhere to, I also respect the common law right of confidentiality relation to your health and medical data. I will never share your records to any third party not involved in the provision of services (other than your registered GP or if required for the purposes of improving medical care and services  i.e. to the RQIA ) between us unless you expressly consent to me doing so (i.e. for continuity of care). I may also share details with insurers where you consent/request me to do so.

Purposes for which I will use your personal data

I have set out below, in a table format, a description of all the ways I plan to use your personal data, and which of the legal bases I rely on to do so.

Note that I may process your personal data for more than one lawful ground depending on the specific purpose for which I am using your data. Please contact me if you need details about the specific legal ground I am relying on to process your personal data where more than one ground has been set out in the table below.

Purpose/Activity Type of data Lawful basis

To register you as a new user including sending emails relating to your account set up, status and account credentials.

External Third Parties will be used for the hosting of such data.

Where you expressly authorise us, I may draw information into your account from authorised third parties.

  1. Identity

  2. Contact Performance of a contract with you (i.e. a user subscribing to my service via my website or application).

To deliver services to you in the manner of organisation, co-ordination and facilitation of consultations with medical practitioners and for managing payments, fees and charges relating to the same. I may disclose data (including Medical Data) to Practitioners (see Glossary) and other health care professionals for the purpose of providing you with online diagnosis services, at my request and direction.

External Third Parties may be used for facilitation of payments and hosting.

  1. Identity

  2. Contact

  3. Financial

  4. Transaction

  5. Medical Data - Performance of a contract with you

  6. Necessary for my legitimate interests (to recover debts due to us)

In addition, with regards to Special Data /Medical Data:

  1. Performance of a contract with you (i.e. the request for an online consultation service)

  2. Medical diagnosis, the provision of health or social care or treatment or the management of health or social care systems

To allow for recording and archiving of records of services provided to you and the audit, review, activity monitoring, waiting list management, and production of datasets to submit for commissioning purposes and national collections, including disclosure of the same to the Care Quality Commission or General Medical Council. I may process your data to anonymise it for the above purposes.

  1. Identity

  2. Contact

  3. Financial

  4. Transaction

Medical Data - For compliance with a legal obligation, being theRegulation and Quality Improvement Authority (RQIA).

  1. Regulatory framework that applies to all providers of medical and health services.

  2. Medical diagnosis, the provision of health or social care or treatment or the management of health or social care systems

To disclose information to NHS Digital for commissioning and planning purposes as directed by law other legal obligation.

  1. Identity

  2. Contact

  3. Transaction

  4. Medical Data - For compliance with a legal obligation

  5. Medical diagnosis, the provision of health or social care or treatment or the management of health or social care systems

To deliver services to you in the manner of medicine prescription fulfilment, ordering of repeat prescriptions (and sending by post), delivery of prescriptions and for managing payments, fees and charges relating to the same. I will disclose data (including Medical Data) to your chosen UK pharmacy for the purpose of fulfilling, processing and recording prescriptions (and maintaining the NHS database).

External Third Parties may be used for facilitation of payments and hosting.

  1. Identity

  2. Contact

  3. Financial

  4. Transaction

  5. Medical Data - Performance of a contract with you (i.e. the processing and shipping of medicines requires an address which forms part of your Contact Details)

  6. Necessary for my legitimate interests (to recover debts due)

In addition, with regards to Special Data/ Medical Data:

  1. Performance of a contract with you; Your chosen pharmacy may require disclosure of Medical Data prior to dispensing medicines, and without which, the fulfilment of prescription cannot occur.

  2. Medical diagnosis, the provision of health or social care or treatment or the management of health or social care systems

To verify with a third party your identity, status of Parental Responsibility (and consent of a child), validity and information regarding private prescriptions as required for regulatory and legal reasons.

External Third Parties may be used for verification purposes.

  1. Identity

  2. Contact

  3. Financial

  4. Transaction

Medical Data - for compliance with a legal obligation being the Regulation and Quality Improvement Authority (RQIA)

  1. Regulatory framework that applies to all providers of medical and health services.

  2. Processing is necessary for reasons ensuring high standards of quality and safety of health care and of medicinal products or medical devices

  3. Processing is necessary to protect the vital interests of the data subject or of another natural person where the data subject is physically or legally incapable of giving consent

To internally review and evaluate the quality of services, including insuring that the quality of live video and audio consultations, provided meet or exceed clinical care standards.

  1. Identity

  2. Contact

  3. Financial

  4. Transaction

  5. Medical Data - Necessary for my legitimate interests (to improve and better the services provided and, considering your rights, to ensure you and third parties receive the required standard of care)

In addition, with regards to Special Data/Medical Data:

  1. Necessary for my legitimate interests (to improve and better the services provided and, considering your rights, to ensure you and third parties receive the required standard of care)

  2. Medical diagnosis, the provision of health or social care or treatment or the management of health or social care systems

To manage my relationship with you which will include:

  1. Notifying you about changes to my terms or privacy policy

  2. Asking you to leave a review or take a survey

  3. Contacting you by email or phone regarding your account (welcoming you to my service), reminding you of appointments and dates, re-engaging with you, maintenance of your account and updating of details.

I may use External Third Parties for the processing of data to assist in sending emails and other correspondence.

  1. Identity

  2. Contact

  3. Profile

  4. Marketing and Communications (a) Performance of a contract with you

  5. Necessary to comply with a legal obligation

  6. Necessary for my legitimate interests (to keep my records updated and to study how customers use my products/services)

To enable you complete a survey or provide feedback.

I may use External Third Parties for the processing of data to assist in sending emails and other correspondence.

  1. Identity

  2. Contact

  3. Profile

  4. Usage

  5. Marketing and Communications (a) Performance of a contract with you

  6. Necessary for my legitimate interests (to study how customers use my products/services, to develop them and grow my business)

To administer and protect my business, website and applications (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data).

I may use External Third Parties for the hosting of data, applications, website and technical support of the same.

  1. Identity

  2. Contact

  3. Technical - Necessary for my legitimate interests (for running my business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise)

  4. Necessary to comply with a legal obligation

To deliver relevant website and application content and advertisements to you and measure or understand the effectiveness of the advertising Iserve to you.

I may use External Third Parties for the processing of data to assist in sending emails and other correspondence.

  1. Identity

  2. Contact

  3. Profile

  4. Usage

  5. Marketing and Communications

  6. Technical - Necessary for my legitimate interests (to study how customers use my products/services/applications, to develop them, to grow my business and to inform my marketing strategy)

To use data analytics to improve my website and applications, products/services, marketing, customer relationships and experiences and to ensure my website and applications display and operate properly on your devices.

  1. Technical

  2. Usage - Necessary for my legitimate interests (to define types of customers for my products and services, to keep my website and applications updated and relevant, to develop my business and to inform my marketing strategy)

To make suggestions and recommendations to you about services that may be of interest to you

  1. Identity

  2. Contact

  3. Technical

  4. Usage

  5. Profile - Necessary for my legitimate interests (to develop my products/services and grow my business)

If you apply for a job either direct to me or, in some instances, where you apply via a third party.

Where you apply via a third party I will obtain information from that third party.

  1. Identity

  2. Contact

Necessary for my legitimate interests (to assess suitability of candidates)

Marketing

I strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising. I have established the following personal data control mechanisms:

  • Promotional offers from us

I may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what I think you may want or need, or what may be of interest to you. This is how I decide which products, services and offers may be relevant for you (I call this marketing).

You will receive marketing communications from me if you have requested information from me or received services from me or if you provided me with your details when signed up or registered in the application or website and, in each case, you have not opted out of receiving that marketing.

  • Third-party marketing

I will get your express opt-in consent before I share your personal data with any party other than my for marketing purposes.

  • Opting out

You can ask me or third parties to stop sending you marketing messages at any time by amending your preferences in your user account (via the website or application) and checking or unchecking relevant boxes to adjust your marketing preferences or by following the opt-out links on any marketing message sent to you or by contacting me at any time.

Where you opt out of receiving these marketing messages, this will not apply to personal data provided to me as a result of using the services, requesting services, ordering prescriptions, or providing feedback or surveys.

Cookies

I use a technology called Cookies across all of its websites and applications in order to deliver the best possible user experience. Cookies are files that are stored on your device each time you visit a website or use an application and enables understanding of your preferences and habits.

Cookies do not contain person-identifiable information such as Medical Data, Identity, Contact Data or Financial Data.

Dr. Siobhan Graham’s website and booking application are set to allow cookies and if you browse the sites and use my applications you consent to this. If you would prefer to deactivate cookies, you can do so by updating your browser settings. Please note that disabling cookies will limit the service that I can provide. For more information on how to update your settings, visit https://ico.org.uk/for-the-public/online/cookies/

I use three types of cookie:

  • Session cookies: These enable the tracking of your movement across the websites and applications and save information to make life easier. For instance, a session cookie might save an item to your shopping basket, without which you would be forced to order each item separately.

  • Persistent cookies: These enable your preferences and settings to be saved each time you visit my websites and use my applications. This makes using the site faster and reduces the need to re-enter data.

  • Third party cookies: These enable tracking of user activity outside the websites and applications and optimise campaigns and analytics better.

Change of purpose and other lawful disclosures

I will only use your personal data for the purposes for which I collected it, unless I reasonably consider that I 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 I need to use your personal data for an unrelated purpose, I will notify you and I will explain the legal basis which allows me to do so.

Please note that I may process your personal data without your knowledge or consent, where this is required or permitted by law. For example, I may be required to disclose your data in the interests of public health, national security, or serious threats to health and/or safety (including child abuse or neglect). I may also have to make available information in response to requests from the General Medical Council or Regulation and Quality Improvement Authority (RQIA). I shall always identify a valid basis for disclosure of data including the following examples:

  • Where data is required to be disclosed, for example, as compelled by the Childrens Acts 1989 and 2004 for the protection of a child such disclosure shall be on the basis of:

  • For the performance of a task carried out in the public interest or in the exercise of official authority and:

  • It is necessary for the purposes of carrying out the obligations and exercising the specific rights of the controller or of the data subject in the field of social protection law in so far as it is authorised by Union or Member State law.

  • Where data is required to be disclosed, for example, in the interest of national security such disclosure shall be on the basis of:

  • For the performance of a task carried out in the public interest or in the exercise of official authority and:

  • It is necessary for reasons of substantial public interest, on the basis of Union or Member State law which shall be proportionate to the aim pursued, respect the essence of the right to data protection and provide for suitable and specific measures to safeguard the fundamental rights and the interests of the data subject.

5. Disclosures of your personal data

I may have to share your personal data with the parties set out below for the purposes set out in the table in paragraph 4 above.

  • Internal Third Parties as set out in the Glossary.

  • External Third Parties as set out in the Glossary.

  • Third parties to whom I may choose to sell, transfer, or merge parts of my business or my assets. Alternatively, I may seek to acquire other businesses or merge with them. If a change happens to my business, then the new owners may use your personal data in the same way as set out in this privacy notice.

I require all third parties to respect the security of your personal data and to treat it in accordance with the law. I do not allow my 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 my instructions.

I do not allow the integration and/or transfer of information to any other mobile applications in your device.

6. International transfers

Some of my External Third Parties are based in the US outside the European Economic Area (EEA) so their processing of your personal data will involve a transfer of data outside the EEA.

Whenever I transfer your personal data out of the EEA, I ensure a similar degree of protection is afforded to it as per GDPR. As my providers are based in the US, I may transfer data to them if they are part of the Privacy Shield which requires them to provide similar protection to personal data shared between the Europe and the US. 

Please contact me using the DPO contact detail in section 1 if you want further information on the specific mechanism used by me when transferring your personal data out of the EEA.

7. Data security

I 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. I use SSL encryption to transfer information between your device andour servers . All data is encrypted at rest. This means the data stored on my systems has been encrypted. In addition, I 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 my instructions and they are subject to a duty of confidentiality.

I 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 I am legally required to do so.

8. Data retention

How long will you use my personal data for?

I will only retain your personal data for as long as necessary to fulfil the purposes I collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

To determine the appropriate retention period for personal data, I consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which I process your personal data and whether I can achieve those purposes through other means, guidance as made by the Information Governance Alliance (the IGS, which is a group comprising of the Department of Health, NHS England, NHS Digital and Public Health England) and the applicable legal requirements.

Details of retention periods for different aspects of your personal data are available in my retention policy which you can request from me by contacting us.

Where I have anonymised your personal data (with consent where appropriate) or collected aggregated data for research or statistical purposes, I may continue to use that data indefinitely without further notice to you.

In some circumstances you can ask me to delete your data: see Request erasure below for further information.

9. Your legal rights

Under certain circumstances, you have rights under data protection laws in relation to your personal data. 

·      Request access to your personal data.

  • Request correction of your personal data.

  • Request erasure of your personal data.

  • Object to processing of your personal data.

  • Request restriction of processing your personal data.

  • Request transfer of your personal data.

  • Right to withdraw consent.

If you wish to exercise any of the rights set out above, please contact us.

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, I may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, I may refuse to comply with your request in these circumstances.

What I may need from you

I may need to request specific information from you to help me 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. I may also contact you to ask you for further information in relation to your request to speed up my response.

Time limit to respond

I try to respond to all legitimate requests within one month. Occasionally it may take me longer than a month if your request is particularly complex or you have made a number of requests. In this case, I will notify you and keep you updated.

10. Glossary

LAWFUL BASIS

Legitimate Interest means the interest of my business in conducting and managing my business to enable me to give you the best service/product and the best and most secure experience. I make sure I consider and balance any potential impact on you (both positive and negative) and your rights before I process your personal data for my legitimate interests. I do not use your personal data for activities where my interests are overridden by the impact on you (unless I have your consent or are otherwise required or permitted to by law). You can obtain further information about how I assess my legitimate interests against any potential impact on you in respect of specific activities by contacting us.

Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract. With regards to Dr. Siobhan Graham, this is the terms you agree to upon opening an account, following which you can request consultations and other services.

Comply with a legal or regulatory obligation means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that I am subject to.

Medical diagnosis, the provision of health or social care or treatment or the management of health or social care systems means the processing of your data is necessary for the purpose of providing you consultations, fulfilment of prescriptions, and other services related to your health as provided by me as requested by you, and for the improvement and management of health care systems more generally.

For compliance with a legal obligation means the processing of data is required by me to comply with my legal obligations for instance, allowing the Regulation and Quality Improvement Authority (RQIA)to audit and review Vitlais Health Ltd services.

THIRD PARTIES

External Third Parties

  • Service providers acting as processors who provide IT and system administration services.

  • Marketing service providers (including email list providers) who act as processors for my engagement correspondence and marketing with users.

  • Verification service providers who verify the identity of individuals who register for child accounts.

  • Online survey providers (including Survey Monkey) who convey information supplied by customers to Now Healthcare Group.

  • Practitioners, being qualified medical practitioners as regulated and by the General Medical Council, acting as processors based in Northern Ireland who provide medical consulting services.

  • NHS, the health service for Northern Ireland, being a joint controller of your health data for fulfilment of regulatory requirements and other national interest uses as it so determines.

  • Payment providers, as processors of payment information, including Stripe.

  • Postal and delivery service providers acting as processors.

  • HM Revenue & Customs, regulators and other authorities based in the United Kingdom who require reporting of processing activities in certain circumstances.

YOUR LEGAL RIGHTS

You have the right to:

Request access to your personal data (commonly known as a "data subject access request"). This enables you to receive a copy of the personal data I hold about you and to check that I are lawfully processing it.

Request correction of the personal data that I hold about you. This enables you to have any incomplete or inaccurate data I hold about you corrected, though I may need to verify the accuracy of the new data you provide to us. Please note that I may object to amending your health records that may be held by me in the interests of maintaining the integrity of this data and benefitting your healthcare. Should you wish to update your Medical Data please contact us.

Request erasure of your personal data. This enables you to ask me to delete or remove personal data where there is no good reason for me continuing to process it. You also have the right to ask me to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where I may have processed your information unlawfully or where I am required to erase your personal data to comply with local law. Note, however, that I may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.

Object to processing of your personal data where I am relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where I are processing your personal data for direct marketing purposes. In some cases, I may demonstrate that I have compelling legitimate grounds to process your information which override your rights and freedoms.

Request restriction of processing of your personal data. This enables you to ask me to suspend the processing of your personal data in the following scenarios: (a) if you want me to establish the data's accuracy; (b) where my use of the data is unlawful but you do not want me to erase it; (c) where you need me to hold the data even if I no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to my use of your data but I need to verify whether I have overriding legitimate grounds to use it.

Request the transfer of your personal data to you or to a third party. I will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for me to use or where I used the information to perform a contract with you.

Withdraw consent at any time where I am relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, I may not be able to provide certain products or services to you. I will advise you if this is the case at the time you withdraw your consent.