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FollowApp Website Privacy Notice_v2.0 - USA.docx
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PUBLIC USE

FollowApp Care Limited

Website Privacy Notice


Document Control

OWNER

Tim Hanks

APPROVER

David Holmes

CLASSIFICATION

Public Use

DATE OF ISSUE

11.01.2024

ISSUE

v2.0

REASON FOR ISSUE/UPDATE

Annual review and update

LAST REVIEW/UPDATE

January 2024

NEXT REVIEW

January 2025

DISTRIBUTION

External

VERSION

AUTHOR

SUMMARY OF CHANGES

DATE

0.1

Evalian Limited

First issue (Draft)

21.01.2020

1.0

Evalian Limited

Final version

21.01.2020

2.0

Evalian Limited

Annual review and update

11.01.2024

Document Release:

This document remains the property of FollowApp Care Limited. Release to regulatory authorities is permitted as required. Release to other organisations or individuals may only be authorised by Company Directors.


FollowApp Care Limited

Privacy Notice

Application Registration & Website Users in USA

Last Updated: 11th January 2024

Who we are and what we do

We are FollowApp Care Limited (“FollowApp”, “we”, “us”, “our”). We are a limited company registered in England and Wales, registration number 09356705, with our registered office at 19 Wimpole Street, London, United Kingdom, W1G 8GE. We are registered with the UK supervisory authority, the Information Commissioner’s Office (“ICO”), in relation to our processing of Personally Identifiable Information (“PII”) as a Controller under registration number ZA160682.

We are a business-to-business provider of an automated patient engagement management system to assist dental practices to deliver personalised patient centred care.

We are committed to the protection of the PII we process in line with the data protection principles set out in the relevant data protection laws. These Data Protection Laws include the UK General Data Protection Regulation, the EU General Data Protection Regulation (2016/679), the Data Protection Act 2018 and any other applicable data protection laws in force in the countries in which we operate.

PII means any information from which someone can be identified either directly or indirectly. For example, you can be identified by your name or job role, or an online identifier such as a username or IP address.

Purpose of this privacy notice

The purpose of this Privacy Notice (this “Notice”) is to explain what PII we collect and how it is processed. This Notice also explains your rights, so please read it carefully. If you have any questions, you can contact us using the information provided below in the ‘How to contact us’ section. 

Who this Notice applies to

This Notice applies to you if:

Personally Identifiable Information we collect

The type of PII we collect will depend on our relationship with you, but may include your:

The above list is not exhaustive and may change.

How we collect it

We collect most of the PII directly from you in person, by telephone, text, email, via our website or App. However, we may also collect your PII from:

Purposes for which we use Personally Identifiable Information and the legal bases

We will only use your PII when the law allows. Most commonly, in the following circumstances:

Purpose

Lawful Bases for Processing

To provide our services. This includes to create and update accounts and administer the Application.

Necessary for the performance of our contract to provide dental services.

To provide customer support.

It is in our legitimate interest to respond to enquiries made via our website, by email, through our social channels or any other means.

Improving our application and website and the overall visitor and user website experience.

It is our legitimate interest to allow analytics and search engine providers to help improve and optimise our website.

Improving our application and website and the overall visitor and user website experience.

We use cookies on our website with your consent. Cookies can be managed using your browser settings.

Provide third parties with statistical information about our users (but this information will not be used to identify any individual user and will be anonymised in accordance with applicable law.

It is in our legitimate interest to provide third parties with statistical information to improve the experience and care of users.

Prevention and detection of crime, including money laundering, fraud, or other crimes.

We have a legal obligation to report any such activity to the relevant authorities and regulators.

Send general administrative (non-marketing) commercial communication.

It is our legitimate interest to inform users of administrative changes and updates to our service.

Receive news, events, information or to sign up to an event, webinar or podcast.

We rely on your consent to send you marketing, information regarding news and events, or to sign you up to an event or webinar. This consent may be withdrawn at any time by emailing info@followapp.care or by contacting us by telephone or via our social media platforms.

Analyse and track users of our website for reporting and analytical purposes.

It is our legitimate interest to monitor our website usage in order to continually improve the user experience.

Where PII is processed because it is necessary for the performance of a contract to which you are a party, we will be unable to provide our services without the required information.

Sharing your Personally Identifiable Information

We may share your PII with trusted third parties who provide us with services relevant to our provision of services to you. This includes our providers of medical services (External Services), professional advisers, IT service providers, cloud software provider and other suppliers and sub-contractors.

If the third party needs access to any of your PII to carry out any of the activities described above, we will ensure your PII is handled safely, securely and in accordance with your rights, our obligations and the third party or our client obligations under the law. We will do this by entering into a Data Processing Agreement with them. This will ensure that the third-party company will only process your PII in accordance with our strict instructions and will not use it for their own purposes.

In some limited circumstances, we may be legally required to share certain PII, if we are involved in legal proceedings or complying with legal obligations, a court order, or the instructions of a government authority. Our lawful basis in these circumstances is legal obligation or legitimate interests, depending on the situation.

How long we keep your data

We will retain your PII for as long as is necessary to provide you with our services and for a reasonable period thereafter to enable us to meet our contractual and legal obligations and to deal with complaints and claims.

At the end of the retention period, your PII will be securely deleted or anonymised, for example by aggregation with other data, so that it can be used in a non-identifiable way for statistical analysis and business planning.

Security of your information

We will take reasonable technical and organisational precautions to prevent the loss, misuse or alteration of your personal information. We will store all the personal information you provide on our secure (password and firewall protected) servers.

While we use SSL encryption to protect data in transit, transmission of information over the internet is inherently insecure, and we cannot guarantee the security of data sent over the internet.

You are responsible for keeping your password and other login details confidential. We will not ask you for your password (except when you log in to the Application). If you lose your password or give it out, your personal information may be compromised. If that happens, please use the “Forgot Password” button on the Application’s login page to change your password immediately. We cannot be held responsible for your failure to keep your password secure and failure to do so may violate the terms in our ‘Legal Information’ section.

Protection for Children

This Site is not intended for users under the age of 13, and we have no intention of collecting PII from children. If a parent or guardian learns that a child has provided us with PII, that child's parent or guardian should contact us and send a request marked "Privacy – Urgent" if they would like the information submitted by the child deleted from our database. We will use all reasonable efforts to delete such information from our database.

International Transfers

FollowApp is a UK-headquartered, global business and to respond properly to your enquiry it is possible that we will share your data with our group companies, including those in countries outside the UK where the data protection laws are not equivalent to those in the UK. We will take appropriate steps to ensure the PII processed outside the UK has an essentially equivalent level of protection to that guaranteed in the UK. We will do this by ensuring that:

United States of America

Our website and databases are maintained in the United States of America.  By using our services you freely and specifically give us your consent to export your PII to the USA and to store and use it in the USA as specified in this policy.

Your Rights

Individuals whose PII we hold, and process have the following rights:

If you wish to exercise your rights, please contact us at info@followapp.care.

You will not have to pay a fee to access your PII (or to exercise any of the other rights). However, we may charge a reasonable fee if your request for access is clearly unfounded or excessive. Alternatively, we may refuse to comply with the request in such circumstances.

If you wish to make a complaint, you can write to the Privacy Officer at the address provided below. We will respond to your complaint within one month.

How to contact us and our Data Protection Officer

If you wish to contact us in relation to this Notice or if you wish to exercise any of your rights, please contact us as follows:

FollowApp Care Limited

19 Wimpole Street

London

W1G 8GE

Email: info@followapp.care

We have also appointed a Data Protection Officer (“DPO”), Evalian Limited, who can be contacted at dpo@evalian.co.uk.

Changes to this Notice

We may update this Notice from time to time. When changes are made, we will amend the ‘last updated’ date at the top of this Notice. We will also notify you of the changes where required by applicable law to do so.