General Platform 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.
We are committed to protecting the privacy and security of the personal data of users who visit and interact with our online booking platform (our Platform) and the services made available via our Platform (the Platform Services), being:
- the personal data of medical and healthcare practitioners and other professionals (Service Users) who interact with, and use the Platform Services within their business;
- the personal data of Clients and other individuals (including Representatives) who engage and interact with Service Users via our Platform (End Users); and
- the personal data of users who simply browse the Platform.
This Privacy Notice is addressed to the individuals falling into the categories set out above. We refer to each such individual in this Privacy Notice as you.
1. Important Information
1.1 Supplemental Terms – This Privacy Notice supplements the other notices and terms published on our Platform (including our Platform Subscription Terms, Data Sharing Terms, Platform User Terms , Client Specific Privacy Notice and Cookies Policy (the Terms)) and is not intended to override them.
1.2 Controller – We are the controller of, and are responsible for, your personal data.
1.3 Understanding – To assist you further in understanding this Privacy Notice, we have set out in the Schedule a glossary of terms used in this Privacy Notice, examples of types of personal data we collect, how we use it, the lawful basis for processing such data and further details of your rights.
1.4 Questions – If you have any questions about this 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.
1.5 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.
1.6 Who can use the Platform Services – Our Platform is not intended for children, however if you are a Representative of a minor (any individual under the age of 18) you can use our Platform on their behalf and to make bookings with Professionals for them. If you are aged 16 or 17 and want your own account on our Platform, your Representative must set up and create the account on your behalf and must make all bookings on your behalf, until you reach the age of 18.
1.7 Changes to your personal data – It is important that the data we hold about you is accurate and current, therefore please keep us informed of any changes to your personal data.
1.8 Third-party links – Our Platform may include links to third-party websites, plug-ins and applications. By clicking on these links or enabling connections you may be allowing third parties to collect or share your personal data. We have no control over these third-party websites, plug-ins or applications and are not responsible for their privacy notices, therefore you should read their privacy notices to understand what personal data they collect about you and how they use it.
2. The Personal Data We Collect
2.1 We may collect, use, store and transfer the types of personal data about you listed in Part 1 of the Schedule.
2.2 We also collect, use and share aggregated data. However, if we combine aggregated data with your personal data so that it can directly or indirectly identify you, we treat this as your personal data.
2.3 We collect special categories of personal data. Due to the nature of our Platform, the Platform Services and the Professional Services, we collect special category personal data of Clients. If you are a Client, please see our Client Specific Privacy Notice for further details on how we collect, process and use your health data (which may include special category personal data).
2.4 Failure to provide personal data. If we are required by law or under the terms of a contract we have with you, to collect your personal data and you fail to provide it:
- we may not be able to enter into or perform the contact with you; and/or
- we may have to limit your access to and/or cancel the provision of the Platform Services to you and/or the contract (as applicable).
We will notify you of this at the relevant time.
3. How Personal Data Is Collected
We collect personal data in the following ways:
| Direct Interactions | You may provide personal data when you complete our online enquiry form via our Platform, create an account to access and use all or some of the Platform Services, as part of any booking journey for Professional Services, or interactions with Service Users via our Platform or where you otherwise correspond with us (by post, phone or email). |
| Provision of Services | We collect personal data (including special categories of personal data) of End Users and Clients when a Service User utilises our Platform Services in their business, including where bookings are made via our Platform or the Professional uploads or stores notes and/or records to our Platform. |
| Automated Technology | We automatically collect personal data (technical and usage) when you browse or interact with our Platform, by using cookies, server logs and other similar technologies. We may also receive technical data about you if you visit other websites which use our cookies. Please see our Cookies Policy for further details. |
| Publicly Available Sources | We may collect personal data from publicly available sources such as the Electoral Register and credit reference agencies, based inside the UK. |
| Third Parties | We may receive personal data from (a) third parties who provide an End User's or Client's personal data on their behalf (such as a Representative, Service User or associations who we have a contractual relationship with) (b) End Users when providing emergency contact information (c) analytics providers (d) advertising networks; (e) search information providers; and (f) our suppliers such as website support and maintenance providers. |
4. How We Use Your Personal Data
4.1 We will only use your personal data when the law allows us to. Most commonly, we will use your personal data:
- 4.1.1 where you are a Service User, to perform the contract we are to enter into or have entered into with you for the provision of the Platform Services to you;
- 4.1.2 where you are an End User, to perform the contract we are to enter into or have entered into with you for the provision of the Platform Services to you, which includes the storage of your personal data (which shall include health data) as part of the records created by Service Users or us as part of the provision of the Platform Services;
- 4.1.3 to comply with a legal obligation; or
- 4.1.4 where it is necessary to carry out our legitimate interests (or those of a third party), and your interests and fundamental rights do not override those interests.
4.2 Part 2 of the Schedule sets out the lawful basis we will rely on to process your personal data.
4.3 Please note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using such data.
4.4 Marketing – Service Users (and End Users where we are permitted to do so) will only receive marketing communications from us if:
- 4.4.1 you have engaged with us for the provision of Platform Services; or
- 4.4.2 you have provided your consent to receive marketing communications;
- and you have not opted out of receiving marketing communications, unsubscribed from our mailing list or withdrawn your consent.
4.5 We will not share your personal data with third parties for their marketing purposes.
4.6 How to opt out – You can opt out of email marketing by clicking the unsubscribe button within the particular marketing email. You can also withdraw your consent to receive marketing communications and ask to be removed from our mailing list at any time by contacting us.
4.7 Even if you opt out of receiving marketing communications, we may still use your personal data for other purposes provided we have a lawful basis to do so.
4.8 Change of purpose – We will only use your personal 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 to change the purpose.
4.9 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 use your personal data in this manner.
4.10 We may process your personal data (without your knowledge or consent) where this is required or permitted by law.
5. Disclosures Of Your Personal Data
5.1 We may share your personal data with the Third Parties set out in Part 4 of the Schedule. We require all Third Parties to respect the security of your personal data and to treat it in accordance with the law. Such Third Parties can only process your personal data for specified purposes and in accordance with our instructions.
6. International Transfers
6.1 Some Third Parties may be based outside of the UK, therefore your personal data may be transferred outside of the UK.
6.2 Whenever we transfer your personal data out of the UK, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:
- we will only transfer personal data to countries that have been deemed to provide an adequate level of protection for personal data;
- we use specific contracts which give personal data the same protection it has in the UK with our services providers.
7. Data Security
7.1 We operate appropriate security measures to prevent personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. Access to personal data is restricted to individuals who have a business need to know it, are under confidentiality obligations and can only process it on our instructions.
7.2 We have procedures in place 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.
8. Data Retention
8.1 We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.
8.2 We may update our data retention practices from time to time and you can request details by contacting us. However, we are legally required to keep basic information about our users and customers (including contact, identity, financial and transaction data) for six years after the end of the tax year in which they cease being users, for tax purposes.
8.3 We may also anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes. Anonymised data may be used indefinitely without further notice to you.
9. Your Legal Rights
9.1 Your legal rights in relation to your personal data are set out in full in Part 3 of the Schedule. If you wish to exercise any of these rights, please contact us. We acknowledge that there may be circumstances where a Client is unable to exercise these rights for themselves, and a Representative may be permitted to exercise these rights on their behalf, where to do so is in the best interests of that Client.
9.2 You will not have to pay a fee to exercise any of your rights unless your request is clearly unfounded, repetitive or excessive. In which case, we may charge a reasonable fee for this information or refuse to comply with your request. We may also refuse to comply with a request from a Representative, where we have evidence that complying with such request would not be in the best interests of the Client.
9.3 We may ask you to provide further information to help us confirm your identity. This is a security measure to ensure that personal data is not disclosed to any person who does not have the right to receive it.
9.4 We aim to respond to all legitimate requests within one month. If your request is particularly complex or you have made a number of requests, it may take us longer to respond. In this case, we will notify you and keep you updated.
10. Updates
10.1 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.
