Client Specific Privacy Notice
We are Finbogo Limited (a private limited company registered with company number: 15397665) (Finbogo, we, us, our). Our registered office is located at Fernhill Estate Office Fernhill Road, Sutton, Newport, Shropshire, United Kingdom, TF10 8DJ.
This Client Specific Privacy Notice specifically addresses how we collect, use and look after personal data that we categorise as 'Health Data', which in most instances, will include special categories of data.
1. Important Information
1.1 What is Health Data – Health Data is any personal data of a Client that relates to any medical history, previous and current medical conditions, diagnosis, treatments and medications (including those provided by Service Users) and records and documents created by Service Users via the Platform Services (i.e. notes from appointments and treatment forms) of the Client that are uploaded to the Platform by the Client, their Representative or a Service User (as applicable), or are created through the use of or as part of any interaction with the Platform Services either by you, your Representative, us, or a Service User.
1.2 Who are Clients – You are a Client where you (or your Representative) interact with the Platform Services as an individual to make bookings and/or create health records and you are not acting in the course of your business or as a Service User.
1.3 How is Health Data created and/or collected – Health Data is created and/or collected in a variety of ways:
- 1.3.1 you may provide Health Data when registering for an account to access our Platform Services;
- 1.3.2 you may upload Health Data to your account as part of your use of the Platform Services from time to time;
- 1.3.3 you may create Health Data when completing onboarding forms to register or book a treatment with a Service User, or otherwise communicate with a Service User via the Platform;
- 1.3.4 a Service User may create Health Data relating to you prior to, during and following the provision of their Professional Services to you; or
- 1.3.5 a Representative may provide Health Data where a Client is a minor (aged under 18) or has a Representative appointed in respect of them/their welfare and that Representative books an appointment with a Service User for or on behalf of the Client.
1.4 Supplemental Terms – This Client Privacy Notice supplements our General Platform Privacy Notice. Please see our General Platform Privacy Notice for a glossary of terms used in this Client Privacy Notice, and further information on:
- 1.4.1 International Transfers;
- 1.4.2 Data Security;
- 1.4.3 Data Retention;
- 1.4.4 Your Legal Rights; and
- 1.4.5 the lawful basis that we rely on to process data (in addition to the specific examples set out below);
as such information applies to all personal data that we process, and not just Health Data.
1.5 Controller – We are the controller of, and are responsible for, your Health Data. Please note that the Practitioner is also a controller of your Health Data (and other personal data) therefore please also review their privacy policy to understand how they will use your personal data.
1.6 Questions – If you have any questions about this Client Specific Privacy Notice, including any requests to exercise your legal rights, please contact us in writing, either by:
Email: requests@finbogo.com
Post: Finbogo Limited, 2nd Floor, Lynnfield House, Church Street, Cheshire, Altrincham WA14 4DW.
1.7 Complaints – You have the right to make a complaint at any time to the Information Commissioner's Office (ICO) (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.
1.8 Changes to Health Data – It is important that the Health Data we hold about you is accurate and current, therefore please keep us informed of any changes to your Health Data.
2. How We Use Your Health Data
2.1 We will only use your Health Data when the law allows us to. Part 1 of the Schedule to our General Privacy Notice sets out the lawful basis that we rely upon to process your personal data. We have set out below specific details of the processing activities we undertake with your Health Data and the lawful basis and specific exemptions that we rely upon to undertake such activities.
| Purpose/Activity | Type of data | Lawful basis for processing |
|---|---|---|
| To facilitate bookings with Service Users for the delivery of treatments and to provide such Service User with the information they have requested you, as the Client or the Representative, provide to them either prior to, or as part of the booking and treatment process with that Service User. | Contact data, identity data and Health Data. | To perform our contract with you/your Representative for access and use of our Platform Services – in particular to allow you or your Representative to make a booking with a Service User for a specified treatment (contact and identity data); Your explicit consent or your Representative's explicit consent to the processing of your Health Data for this purpose. |
| To create a health record in respect of you. A copy of your health record will be stored and can be accessed by you within your account as part of our Platform Services. | Health Data including records of your treatments, prognosis, diagnosis and treatment plans. | Your explicit consent or your Representative's explicit consent to the processing of your Health Data for this purpose. |
| To liaise with and notify you of the services of third-party service providers. | Health Data, contact data and identity data. | Your explicit consent or your Representative's explicit consent to the processing of your Health Data for this purpose and your consent or your Representative's consent to us sharing such Health Data with the particular third party service provider, where you or your Representative have indicated that you or they would like to be informed of clinical trials, developments or other treatment plans that may be relevant to your health conditions. |
| Storing Health Data in our general database. | Health Data | Health Data will be stored in our general database to enable scientific research to be undertaken on such Health Data, or for statistical data to be produced from such Health Data. |
2.2 Please note that we may process Health Data for more than one lawful ground depending on the specific purpose for which we are using Health Data.
2.3 Change of purpose – We will only use Health Data for the purpose that we originally collected it for, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose or we have a lawful basis and specific exemption to change the purpose.
2.4 If we need to use your Health Data for an unrelated purpose, we will notify you and explain the legal basis which allows us to use your Health Data in this manner.
2.5 We may process your Health Data (without your knowledge or consent) where this is required or permitted by law.
2.6 We may process anonymised Health Data and statistical data for research and analytical purposes. Such data once anonymised will no longer be categorised as personal data where we cannot identify you from such anonymised data. We will keep such anonymised records, statistical data and analysis for as long as we deem there to be a practical use for our business of such data.
3. Disclosure Of Your Health Data
3.1 We may share Health Data with the following third parties:
| Third Party | Purpose / Description |
|---|---|
| Service Users | When you book an appointment with a Service User via the Platform Services, we will share your contact data, identity data, and any Health Data you provide when completing the booking request with that Service User (in their capacity as a controller of such personal data). Any Health Data relating to you that a Service User creates and/or stores within the Platform (as part of the Platform Services) relating to any treatments that you have booked or received will be shared by that Service User with us (in our capacity as controller of such personal data). We will also provide access to such Health Data within your account as you specifically request through our preference settings that we make available to Service Users. |
| Clinical Trial Providers | Where you have consented or requested for us to do so, we may initiate contact with or permit contact to be made by clinical trial providers. We will facilitate the sharing of Health Data with such clinical trial provider via the Platform Services (in their capacity as a controller of such personal data). |
| Representative | Where a Client is under the age of 18 and their Representative has booked an appointment with a Service User for or on their behalf, we will share Health Data with that Representative. Where the Client is over the age of 18 but unable to provide their consent and has a Representative appointed to act on their behalf, we will share Health Data with that Representative. |
| Pharmaceutical Companies | For research purposes only. |
3.2 We require all third parties to respect the security of your data and to treat it in accordance with the law. Such third parties can only process your data for specified purposes and in accordance with our instructions.
4. Updates
4.1 We may change this Privacy Notice from time to time by updating this page. Please check it regularly to ensure you are aware of any changes.
This Privacy Notice was created in August 2024.
