Last updated: 5th January 2021

www.remedyclinic.ie (‘Website’) is provided by Remserv Limited & Remedy Psychotherapy Ltd. (“Remedy Clinic”/”we”/We). In doing so, we may be in a position to receive and process personal information relating to you. As the controller of this information, we are providing this Privacy Notice (‘Notice’) to explain our approach to personal information.

We intend only to process personal information fairly and transparently as required by data protection law including the General Data Protection Regulation (GDPR) Directive (EU) 2016/680, the Data Protection Acts 1988 and 2003. In particular, before obtaining information from you (including through use of cookies) we intend to alert you to this Notice, let you know how we intend to process the information (including through use of cookies) and (unless processing is necessary for at least one of the 5 reasons outlined in clause 2 below) we will only process the information if you consent to that processing. The GDPR also defines certain ‘special categories’ of personal information that’s considered more sensitive. These categories require a higher level of protection, as explained below.

Of course, you may browse parts of this Website without providing any information about yourself and without accepting cookies. In that case, it is unlikely we will possess and process any information relating to you.

We will start this Notice by setting out the conditions we must satisfy before processing your data. However, you may wish to start with this table at clause 4, which summarises what we intend to collect, or this table at clause 8.4, which summarises our use of cookies. The Notice also explains some of the security measures we take to protect your personal information, and tells you certain things we will or won’t do. You should read this Notice in conjunction with the Member Agreement.

 Sometimes, when you take a new service or product from us, or discuss taking a new service or product but decide against it, we might wish to provide you with further information about similar services or products by email or other written electronic communication. In that situation, we will always give you the opportunity to refuse to receive that further information and you can change your mind at any point (opt-out) by contacting our Data Protection Officer (DPO) as set in clause 1.4. We will endeavour to remind you of your right to opt-out on each occasion that we provide such information.

1. Identity and contact details

1.1 Registered number: 580766 & 703704

1.2 Registered office: Office 10, Block 3, New Ashbourne Town Centre, Ashbourne, A84 E085

1.3 Business Address: 29 Westland Square, Pease Street, Dublin 2

1.4 Email: info@remedyclinic.ie

1.5 Our Data Protection Officer (DPO), Director Richard McDonagh, would welcome communication from you regarding any matter relating to data protection, and can be contacted by email at info@remedyclinic.ie or by post at the addresses shown above at 1.2 or 1.3 above.

2. When we are allowed to collect and process information from you

We will only collect personal information relating to you if one of the following conditions have been satisfied:

2.1 As a Data Controller

In order to avail of services and / or return contact from Remedy Clinic or providers in remedy clinic, a Client /  Client Organisation / Client organisation employee must register their interest or be registered by referral via our website forms and / or our 3rd party appointment and scheduling platform. This will require the Client /  Client Organisation / Client organisation employee to provide  information to complete a registration process and become a registered Client / Client Organisation / Client organisation Employee (known as a “Client”).  Remedy Clinic will ensure the safety of any information provided.

2.2 As a Data Processor

2.2.1 Where third party data is transmitted by Service Providers as a result of registration on the website by registered users

2.3 You have clearly told us that you are content for us to collect that information for the certain purpose or purposes that we will have specified.

2.4 The processing is necessary for the services requested to be rendered.

2.5 The processing is necessary so that we can comply with the law.

2.6 The processing is necessary to protect someone’s life.

2.7 The processing is necessary for performance of a task that’s in the public interest.

2.8 The processing is necessary for our or another’s legitimate interest – but in this case, we will balance those interests against your interests.

2.9 The processing is necessary to terminate a Service Contract  and remove personal information in relation to the following.

2.9.1 Client Organisation –

-personal information (to include sensitive personal information) will be deleted or anonymised at the expiration of 12 months from.

2.9.1.1 where no service contract has been concluded

2.9.1.2 where no service contract has issued to any registered Provider

2.9.2 Termination –

Personal information in relation to any Client / Client Organisation or its employees will be deleted on termination and an application has been made only in circumstances where no breach  has occurred which is or maybe the subject matter of legal proceedings.

3. How to consent

3.1 At the point of collecting the information, we will endeavour to explain how we intend to use the information and which of these purposes apply. If we rely on consent, we will provide you with the opportunity to tell us that you are happy to provide the information.

3.2 If at any point in time you change your mind and decide that you do not consent, please let us know and we will endeavour to stop processing your information in the specified manner, or we will delete your data if there is no continuing reason for possessing it.

3.3 If you do not consent to a particular bit of processing, we will endeavour to ensure that the Website and our service continue to operate without the need for that information.

4. Information we expect to collect from you

4.1 We envisage asking for the following types of information from you:

Information type Purpose and related details Justification
1.        Name and contact details

2. Brief Summary of why you are contacting the service, this is elective.

 

 

3.        Payment Details

 1.        We ask for this to verify your identity when you contact us

 

 

2. You can enter personal information into a text box on our forms or 3rd party platoforms that detail reasons for contacting this service.

 

 

3.        We ask you for this to take prepayment for services provided by providers in Remedy Clinic

This data may be transferred to the US, and the receiving entity is registered with the EU-US Privacy Shield

  

 

 

 

2. So we can get you connected with the correct service / best service for your needs.

 

 

 

 

It’s necessary for the performance of a contract with you

4.2 In order to register, a Client may be required to confirm sensitive personal information to include details of why they are contacting the service, and credit / debit card details

4.3 From third parties to whom you have provided information with your consent to pass it on to other organisations or persons – when we receive such information we will let you know as soon as is reasonably practicable.

4.4 If you refuse to provide information requested, then if that information is necessary for a service we provide to you we may be unable to continue providing that service.

4.5 At the time of collecting information, by whichever method is used, we will endeavour to alert you and inform you about our purposes and legal basis for processing that information, as well as whether we intend to share the information with anyone else or send it outside of the European Economic Area. If at any point you think we’ve invited you to provide information without explaining why, feel free to object and ask for our reasons.

5 Using personal information of Clients

Where a Client or an Organisation furnishes information to us or is engaged in our service:

5.1 Data protection, privacy and security are important to us, and we shall only use any personal information, howsoever, providing to us for specified purposes and shall not keep such personal information longer than is necessary to fulfil these purposes. The following are examples of such purposes. We have also indicated below which GDPR justification applies, however it will depend on the circumstances of each case. At the time of collecting we will provide further information, and you may always ask for further information from us.

5.1.1 To help us to identify the Client. This will normally be necessary for the performance our contract.

5.1.2 To help us to identify accounts, services and/or products which the Client Organisation or Client may avail of from us or selected partners from time to time. We may do this by automatic means using a scoring system, which uses the personal information that has been provided and/or any information we hold about a Client Organisation or Client and personal information from third party agencies (including credit reference agencies). We will only use your information for this purpose if you agree to it.

5.1.3 To help us to administer and to contact the Client and Client Organisation about improved administration of any accounts, services and products we have provided before, do provide now or will or may provide in the future. This will often be necessary, but sometimes the improvements will not be necessary in which case we will ask whether you agree.

5.1.4 To allow us to carry out marketing analysis and customer profiling (including with transactional information), conduct research, including creating statistical and testing information. This will sometimes require that you consent, but will sometimes be exempt as market research.

5.1.5 To help to prevent and detect fraud or loss. This will only be done in certain circumstances when we consider it necessary or the law requires it.

5.1.6 To allow us to contact the Client and Client Organisation by written electronic means (such as email, text or multimedia messages) about products and services offered by us where:

5.1.6.1 these products are similar to those you have already purchased from us,

5.1.6.2 you were given the opportunity to opt out of being contacted by us at the time your personal information was originally collected by us and at the time of our subsequent communications with you, and

5.1.6.3 you have not opted out of us contacting you.

5.1.6.4 To allow us to contact you in any way (including mail, email, telephone, visit, text or multimedia messages) about products and services offered by us and selected partners where you have expressly consented to us doing so.

5.1.6.5 We may monitor and record communications with you (including records of services rendered, phone conversations and emails) for quality assurance and compliance.

5.1.6.6 Before doing that, we will always tell you of our intentions and of the specific purpose in making the recording. Sometimes such recordings will be necessary to comply with the law. Alternatively, sometimes the recording will be necessary for our legitimate interest, but in that case we will only record the call if our interest outweighs yours. This will depend on all the circumstances, in particular the importance of the information and whether we can obtain the information another way that’s less intrusive.

5.1.6.7 If we think the recording would be useful for us but that it is not necessary we will ask whether you consent to the recording, and will provide an option for you to tell us that you consent. In those situations, if you don’t consent, the call will either automatically end or will not be recorded.

5.1.6.8 When it is required by law, we will check your details with fraud prevention agencies. If you provide false or inaccurate information and we suspect fraud, we intend to record this.

5.2 We will not disclose personal information relating to a Client to any third party except in accordance with this Notice, and in particular in these circumstances:

5.2.1 They will be processing the data on our behalf as a data processor (where we will be the data controller). In that situation, we will always have a contract with the data processor as set out in the GDPR. This contract provides significant restrictions as to how the data processor operates so that you can be confident the data of the Client is protected to the same degree as provided in this Notice.

5.2.2 Sometimes it might be necessary to share data with another data controller. Before doing that we will always tell the Client. Note that if we receive information about the Client from a third party, then as soon as reasonably practicable afterwards we will let you know; that’s required by the GDPR.

5.2.3 Alternatively, sometimes we might consider it to be in the interest of the Client to send information to a third party. If that’s the case, we will always ask for the Consent of the Client before sending.

5.3 Where the Client give us personal information on behalf of someone else (to include a family member), the Client confirms that the Client has provided them with the information set out in this Notice and that the Client have not objected to such use of their personal information.

5.4 In connection with any transaction which we enter into with the Client Organisation:

5.4.1 If you provide false or inaccurate information to us and we suspect fraud, we will record this and may share it with other people and organisations. We, and other credit and insurance organisations, may also use technology to detect and prevent fraud.

5.4.2 We may need to transmit the payment and delivery information provided by you during the order process for the purpose of obtaining authorisation from your bank.

5.5 We may allow other people and organisations to use personal information we hold about the Client in the following circumstances:

5.5.1 If we, or substantially all of our assets, are acquired or are in the process of being acquired by a third party, in which case personal information held by us, about our customers, will be one of the transferred assets.

5.5.2 If we have been legitimately asked to provide information for legal or regulatory purposes or as part of legal proceedings or prospective legal proceedings.

5.5.3 We may employ companies and individuals to perform functions on our behalf and we may disclose your personal information to these parties for the purposes set out above, for example, for fulfilling orders, delivering packages, sending postal mail and email, removing repetitive information from customer lists, analysing data, providing marketing assistance, providing search results and links (including paid listings and links), processing credit and debit card payments and providing customer service. Those parties will be bound by strict contractual provisions with us and will only have access to personal information needed to perform their functions, and they may not use it for any other purpose. Further, they must process the personal information in accordance with this Notice and as permitted by the GDPR. From time to time, these other people and organisations to whom we may pass your personal information may be outside the European Economic Area. We will take all steps reasonably necessary to ensure that your personal information is treated securely and in accordance with this Notice and the GDPR.

6 Protecting information

6.1 We have strict security measures to protect personal information or sensitive corporate information

6.2 We work to protect the security of all personal information or sensitive corporate information during transmission by using appropriate technology to encrypt information any information howsoever transmitted.

6.3 We reveal only the last five digits of your credit card numbers when confirming an order by a Client. Of course, we transmit the entire credit card number to the appropriate credit card company during order processing.

6.4 We maintain physical, electronic and procedural safeguards in connection with the collection, storage and disclosure of personally identifiable customer information. Our security procedures mean that we may occasionally request proof of identity before we disclose personal information to you.

6.5 It is important for any real or natural person to protect against unauthorised access to your password and to any computer. Be sure to sign off when you finish using a shared computer.

7 The internet – Contact by the Client Organisation

7.1 If the Client Organisation communicates with us using the internet, we may occasionally email it about our services and products. When you first give provide us with corporate information through the Website, we will normally give it the opportunity to say whether it would prefer that we don’t contact it by email. Contact Preferances can be updated at any time.

7.2 Please remember that communications over the internet, such as emails and webmails (messages sent through a website), are not secure unless they have been encrypted. Therefore, your Company’s communications may go through a number of countries before they are delivered – this is the nature of the internet. We cannot accept responsibility for any unauthorised access or loss of personal information that is beyond our control.

8 Cookies and other internet tracking technology

8.1 When we provide services, we want to make them easy, useful and reliable. This sometimes involves placing small amounts of information on the Client’s computer, which is sent back to us at a later time. These are called ‘cookies’. These cookies are listed in the table at clause 8.4. Some websites don’t use cookies but use related technology for gaining information about website Members such as JavaScript, web beacons (also known as action tags or single-pixel gifs), and other technologies to measure the effectiveness of their ads and to personalise advertising content. Multiple cookies may be found in a single file depending on which browser you use.

8.2 Where applicable, this section of the Notice also relates to that technology but the term ‘cookie’ is used throughout.

8.3 Some of these cookies are essential to services you’ve requested from us, whereas others are used to improve services for you, for example through:

8.3.1 Allowing navigation between pages efficiently

8.3.2 Enabling a service to recognise a computer so it does not have to give the same information during one task

8.3.3 Recognising the Client has already provide relevant login details so there is no need to enter it for every web page requested

8.3.4 Measuring how many people are using services, so the services can be made easier to use and that there is enough capacity to ensure they are fast

8.4 To learn more about cookies, you may wish to visit:

8.5 This Website & our 3rd party provider uses, or allows use of, the following cookies:

Cookie name Description Category Purpose Expires
www.powerdiary.com language, user-language First Party To determine user language Never
.powerdiary.com OptanonAlertBoxClosed, OptanonConsent First Party To record input form information Never
powerdiary.com stg_externalReferrer, stg_last_interaction, stg_debug, stg_returning_visitor, stg_traffic_source_priority

_uetvid, _ga, _gat_UA-, _gclxxxx, _gid
First Party Performance cookies, can be disabled by user. If opted out.
Google Analytics

 

 These cookies are used to collect information about how Clients navigate and use the Website. We will then use this information to improve the Website and the whole Remedy Clinic Online Platform. 2 To track website usage data.
Stripe the recurring billing solution which will manage all payments to and from Client Organisations to our account. 2 To facilitate online payments Never

8.6 The distinctions referred to in the above table are as follows:

8.6.1 First party versus third party cookies – we set first party cookies ourselves; third party cookies are set by other entities via our Website.

8.6.2 Identifying information removed – just because we’ve done this, there will still be personal information if the relevant information can be reassembled

8.6.3 We have also split the categories into Categories 1-4 below so the Client can identify where consent is and is not needed and why

Category 1 cookies do not require the Member’s consent, though one must still tell them about the cookies. Categories 2-4 do require their specific and informed consent.

Category 1 Essential These cookies are essential in order to navitage around the website and use its features, such as accessing secure areas of the website. Without these cookies, services requested, like shopping baskets or e-billing, cannot be provided.

We include in this category cookies that are used only for electronic communication.

 

Note that cookies for which another person is the controller will never be necessary for a service requested by a Client Organisation. On the other hand, if you’ve asked another person to send a cookie on your behalf for an essential feature of your website, that would be category 1.
Category 2 Performance These cookies collect information about how visitors use a website, for instance which pages visitors go to most often, and if they get error messages from web pages. This information is only used to improve how a website works.
Category 3 Functionality

 

 These cookies allow the website to remember choices made (such as your Member name, language or the region you are in) and provide enhanced, more personal features. For instance, a website may be able to provide local weather reports or traffic news by storing in a cookie the region in which a user is currently located. These cookies can also be used to remember changes made to text size, fonts and other parts of web pages that can personally customised. They may also be used to provide services requested such as a live chat session.
Category 4 Targeting and advertising These cookies are used to deliver adverts more relevant to the user. They are also used to limit the number of times a user can see an advertisement as well as help measure the effectiveness of the advertising campaign. They are usually placed by advertising networks with the website operator’s permission. They remember that who has visited a website and this information is shared with other organisations such as advertisers. Quite often targeting or advertising cookies will be linked to site functionality provided by the other organisation.

8.7 As with any other information we may collect from the Client Organisation, we will work to protect the security of your information during transmission by using by using appropriate technology to encrypt information inputted.

8.8 The Website may include third-party advertising and links to third-party websites. We do not provide any personally identifiable customer personal information to these third-party advertisers or third-party websites except where express consent is provided in accordance with this privacy notice, however as to cookies please see above clause Cookies and other internet tracking technology.

8.9 We exclude all liability for loss that you may incur when interacting with this third-party advertising or using these third-party websites unless you’ve consented in accordance with this privacy notice.

9 Further information

9.1 If either a Client Organisation or Client would like any more information or either user has any comments about this Notice, please write to our Data Protection Officer as detailed in clause 1.4.

9.2 Please note that we may have to amend this Notice on occasion, for example if we change the cookies that we use. If we do that, we will publish the amended version on the Website. In that situation we will endeavour to alert either user to the change, but it is also either user’s responsibility to check regularly to determine whether this Notice has changed.

9.3 A Client can ask us for a copy of this Notice by writing to the above address or by emailing us at. info@remedyclinic.ie. This Notice applies to personal information we hold about individuals. It does not apply to information we hold about companies and other organisations.

9.4 If a Client would like access to the personal information that we hold about the Client, please email us at info@remedyclinic.ie or writing to us at the address noted above. There may be a nominal charge of up to €6.35 to cover administrative costs. ThevClient can also ask us to send the personal information we hold about the Client to another controller but such a request may also require an updated Authority.

9.5 We aim to keep the personal information we hold about an Client or sensitive corporate information about a Client Organisation accurate and up to date. If we are advised that we are holding any inaccurate or incomplete personal or corporate information about you, we will promptly amend, complete or delete it accordingly. Please email us at info@remedyclinic.ie or write to us at the address above to update your personal or corporate information. A Client has the right to complain to the Data Protection Commissioner if we don’t do this.

9.6 A Client can ask us to delete the personal information that we hold about you if we relied on your consent in holding that information or if it is no longer necessary. A Client can also restrict or object to our processing of personal information in certain circumstances by emailing us info@remedyclinic.ie or writing to us at the address noted above.

9.7 We will tell a Client if there is a breach, or a likely breach, of your data protection rights

Cookie notice

This Website makes use of cookies. These cookies, which are listed below, are not strictly required for a service requested from us, though we think they have the potential to enhance your experience:

Whether you are a Client Organisation or an individual Client, please indicate which of these cookies you are happy to receive from this Website. You may withdraw your consent at any time, through either the Website or your web browser (which can also be used to delete currently stored cookies).

For more information about the cookies we use and our approach to the processing of personal information, please read our privacy notice at: www.remedyclinic.ie