Privacy Policy

WEBSITE AND MARKETING PRIVACY NOTICE

This Privacy Notice describes how we, The Spine Hub, collect and use personal data when you visit our website (regardless of where you visit it from) and tells you about your privacy rights and how the law protects you. It is important that you read this Privacy Notice together with any other Privacy Notice we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This Privacy Notice supplements the other notices and is not intended to override them.

Who is the controller?

The Spine Hub is the 'controller' for the purposes of data protection law (also referred to in this notice as 'we' or 'us'). This means that we are responsible for deciding how we hold and use personal data about you.

What type of personal data do we collect about you?

We collect personal data about you in order to provide information about our services, including, for example: name, contact details, age or date of birth, your requirements for our services, related biographical and background information relevant to our services. 

We also collect data about how you use our website and may collect, use, store technical data which includes internet protocol (IP) address, your login data, browser type and version, 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. We refer to this as ‘Technical Data’. 

We also collect, use and share aggregated data such as statistical or demographic data. This 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, we may aggregate your information to calculate the percentage of users accessing a specific website feature. However, if we combine or connect any aggregated data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy notice.

We do not collect any special categories of personal data about you via our website (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, genetic and biometric data and data concerning criminal convictions and offences).

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.

How is your data protection collected?

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

• Direct interactions. You may give us your personal data by contacting us or requesting marketing to be sent to you; 
• Automated technologies or interactions. As you interact with our website, we may automatically collect technical data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, and other similar technologies; or 
• Third parties or publicly available sources. We may receive Technical Data about you from third parties and public sources such as analytics providers, advertising networks and search information providers.

Why do we collect your personal data and on what legal grounds?

We hold and use your personal data for the purposes of providing access to our website, information about our services, responding to your enquiries, and for sending you related communications. Data protection law requires us to have a legal ground for each use of personal data. Most commonly, we rely on the following legal grounds when we process your personal data:

• Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests. For example, for provision of administration and IT services, network security, running our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data). It is also necessary to deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you and to respond to queries made through the website.
• Where you have given us consent, which means that you have given us clear consent for us to process your data for a specific purpose, for example to send you marketing material when you have signed up for a newsletter. You have the right to withdraw consent to marketing at any time by contacting us. You can ask us to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you or by contacting us at any time. 
• Where we need to comply with a legal obligation, which means processing your personal data where it is necessary for compliance with a legal obligation that we are subject to.

Direct marketing 

We do not make or send unsolicited direct marketing communications (by telephone, email, SMS, post or other method) to any individuals without obtaining any required consents and giving such individuals the right to opt-out or object. Consents must be specific, informed and freely given. Marketing communications may include communications which promote our services, related events or training courses, or any other party's goods or services. 

We will assess our obligations to obtain consent or provide an option to refuse marketing at the time an individual's contact details are collected. All marketing communications will contain details of how to opt out of future marketing.

Use of cookies

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

We use the following types of cookies on our website:

• Strictly necessary cookies. These are cookies that are required for the operation of our website. They include, for example, cookies that enable you to log into secure areas of our website.
• Analytical or performance cookies. These allow us to recognise and count the number of visitors and to see how visitors move around our website when they are using it. This helps us to improve the way our website works, for example, by ensuring that users are finding what they are looking for easily.
• Functionality cookies. These are used to recognise you when you return to our website. This enables us to personalise our content for you, greet you by name and remember your preferences (for example, your choice of language or region).
• Targeting cookies. These cookies record your visit to our website, the pages you have visited and the links you have followed. We will use this information to make our website and any advertising displayed on it more relevant to your interests.

You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly. 

Third party links

Our website 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. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy notice of every website you visit.

Disclosure of your personal data

We may have to share your personal data with external third parties including service providers based in the UK who provide IT, system administration services and e-marketing on our behalf. We may also share your personal data with professional advisers including lawyers and insurers based in the UK and with official authorities such as HMRC. 

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We only permit our third-party service providers to process your personal data for specified purposes and in accordance with our instructions and do not allow them to use your personal data for their own purposes.

Data retention

We will not keep your personal data for longer than we need it for our legitimate purposes.

To determine the appropriate retention period for personal data, we 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 we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.

If you want to know more about how long we hold your data, please feel free to contact us.

Transferring personal data outside the UK

We do not ordinarily transfer your personal data outside the UK.

Your rights 

You have a number of legal rights relating to your personal data, as follows. 

1. The right to withdraw any consent you have given in relation to the use of your personal data.
2. The right to make a subject access request. This enables you to receive certain information about how we use your personal data, as well as to receive a copy of it. 
3. The right to request that we correct incomplete or inaccurate personal data that we hold about you. 
4. The right to request that we delete or remove personal data that we hold about you where there is no good reason for us continuing to process it, or where you have withdrawn any consent relating to that processing. You also have the right to ask us to delete or remove your personal data where you have exercised your right to object to processing (see below).
5. The right to object to our processing your personal data where: (a) we use it for direct marketing purposes; or (b) where we are relying on our legitimate interest (or those of a third party) as our legal ground. In the case of (b), note that we may continue the processing if we can show a compelling reason to do so. 
6. The right to request that we restrict our processing of your personal data. This enables you to ask us to suspend the processing of personal data about you, for example if you want us to establish its accuracy or the reason for processing it.
7. The right to request that we transfer your personal data to you or to another party, in a structured format. This right applies in respect of data that you have provided where our legal ground for using the data is that it is necessary for the performance of a contract or that you have consented to us using it (this is known as the right to “data portability”).

If you would like to exercise any of the above rights, contact our Data Privacy Manager. Note that these rights are not absolute and in some circumstances we may be entitled to refuse some or all of your request. 

If you have any questions or concerns about how your personal data is being used by us, you can contact our Data Privacy Manager.

Complaints

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.