Policies
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Dated: 9th September 2024
INTRODUCTION
Welcome to Anne Trans Healthcare Limited’s privacy notice.
Anne Trans Healthcare Limited (Anne) respects your privacy and is committed to protecting your personal data. This privacy notice will inform you as to how we look after your personal data when you visit our website (regardless of where you visit it from) and tell you about your privacy rights and how the law protects you.
Please also use the Glossary to understand the meaning of some of the terms used in this privacy notice.
1. IMPORTANT INFORMATION AND WHO WE ARE
PURPOSE OF THIS PRIVACY NOTICE
This privacy notice aims to give you information on how Anne Trans Healthcare Limited collects and processes your personal data through your use of this website, including any data you may provide through this website when you sign up to our newsletter, purchase a product or service or take part in a competition.
CONTROLLER
Anne Trans Healthcare Limited is the controller and responsible for your personal data (collectively referred to as “Anne”, “we”, “us” or “our” in this privacy notice).
CONTACT DETAILS
We are Anne Trans Healthcare Limited (Company Registration Number 15887376). Our registered address is 71-75 Shelton Street, Covent Garden, London, United Kingdom, WC2H 9JQ United Kingdom.
We are registered as a data controller with the Information Commissioner’s Office (ICO) under registration number ZB732207.
To contact our Data Protection Officer (DPO) email hello@anne.health.
If you have any questions about this privacy notice, including any requests to exercise your legal rights, please contact us at hello@anne.health.
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.
CHANGES TO THE PRIVACY NOTICE AND YOUR DUTY TO INFORM US OF CHANGES
This version was last updated in September 2024 and historic versions can be obtained by contacting us.
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.
THIRD-PARTY LINKS
This 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.
2. THE DATA WE COLLECT ABOUT YOU
Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).
We may collect, use, store and transfer different kinds of personal data about you which we have grouped together follows:
Identity Data includes first name, last name, username or similar identifier, and title.
Contact Data includes billing address, delivery address, email address and telephone numbers.
Transaction Data includes details about payments to and from you and other details of products and services you have purchased from us.
Technical Data 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.
Usage Data includes information about how you use our website, products and services.
Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.
We may also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. 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 Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect 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.
IF YOU FAIL TO PROVIDE PERSONAL DATA
Where we need to collect personal data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with goods or services). In this case, we may have to cancel a product or service you have with us, but we will notify you if this is the case at the time.
PATIENT DATA
This relates to patient data you input into Anne systems in order to use the Anne services as set out in the contract between us.
We confirm that any international transfers of patient data will be carried out in compliance with the UK GDPR and Data Protection Act 2018, including use of the Information Commissioner’s Office’s International Data Transfer Agreement and Addendum, in force 21st March 2022, where required.
Patient data will be retained for the term of the contract between us and deleted in accordance with the terms of this contract upon termination for whatever reason.
3. HOW IS YOUR PERSONAL DATA COLLECTED?
We use different methods to collect data from and about you including through:
Direct interactions. You may give us your Identity and Contact Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
apply for our products or services;
create an account on our website;
subscribe to our service or publications;
request marketing to be sent to you;
enter a competition, promotion or survey; or
give us some feedback.
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, server logs and other similar technologies. Please see our Cookie Policy for further details.
Third parties or publicly available sources. We may receive personal data about you from various third parties and public sources as set out below:
Technical Data from the following parties:
(a) analytics providers such as Google based outside the EU;
Identity and Contact Data from data brokers or aggregators such as Lusha Systems Inc. based outside the EU.
Identity and Contact Data from publicly available sources such as Companies House and the Electoral Register.
4. HOW WE USE YOUR PERSONAL DATA
We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:
Where we need to perform the contract we are about to enter into or have entered into with you.
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.
Where we need to comply with a legal or regulatory obligation.
Generally, we do not rely on consent as a legal basis for processing your personal data other than in relation to sending third party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by Contacting us.
PURPOSES FOR WHICH WE WILL USE YOUR PERSONAL DATA
We have set out below a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.
Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please Contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.
Purpose/Activity
Type of data
Lawful basis for processing including basis of legitimate interest
Data retention period
To register you as a new customer
(a) Identity
(b) Contact
Performance of a contract with you
For the duration of the contract.
To process and deliver your order including:
(a) Manage payments, fees and charges
(b) Collect and recover money owed to us
(a) Identity
(b) Contact
(c) Transaction
(d) Marketing and Communications
(a) Performance of a contract with you
(b) Necessary for our legitimate interests (to recover debts due to us)
Transaction data, in conjunction with identity data, will be held for 6 years from the end of the year in which the transaction was made.
To manage our relationship with you which will include:
(a) Notifying you about changes to our terms or privacy policy
(b) Asking you to leave a review or take a survey
(a) Identity
(b) Contact
(c) Profile
(d) Marketing and Communications
(a) Performance of a contract with you
(b) Necessary to comply with a legal obligation
(c) Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services)
For the duration of the contract.
To enable you to partake in a prize draw, competition or complete a survey
(a) Identity
(b) Contact
(c) Profile
(d) Usage
(e) Marketing and Communications
(a) Performance of a contract with you
(b) Necessary for our legitimate interests (to study how customers use our products/services, to develop them and grow our business)
For the duration of the contract.
To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)
(a) Identity
(b) Contact
(c) Technical
(a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise)
(b) Necessary to comply with a legal obligation
For the duration of the contract.
To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you
(a) Identity
(b) Contact
(c) Profile
(d) Usage
(e) Marketing and Communications
(f) Technical
Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy)
For the duration of the contract.
To use data analytics to improve our website, products/services, marketing, customer relationships and experiences
(a) Technical
(b) Usage
Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy)
For the duration of the contract.
To make suggestions and recommendations to you about goods or services that may be of interest to you
(a) Identity
(b) Contact
(c) Technical
(d) Usage
(e) Profile
Necessary for our legitimate interests (to develop our products/services and grow our business)
For the duration of the contract.
MARKETING
We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising.
PROMOTIONAL OFFERS FROM US
We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you (we call this marketing).
You will receive marketing communications from us if you have requested information from us or purchased services from us or if you provided us with your details when you entered a competition or registered for a promotion and, in each case, you have not opted out of receiving that marketing.
COOKIES
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. For more information about the cookies we use, please see our Cookie Policy.
CHANGE OF PURPOSE
We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please Contact us.
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 do so.
Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
5. DISCLOSURES OF YOUR PERSONAL DATA
We may have to share your personal data with the parties set out below for the purposes set out in the table in paragraph 4 above.
External Third Parties as set out in the Glossary.
Third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy notice.
We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.
6. INTERNATIONAL TRANSFERS
Some of our external third parties are based outside of the UK so their processing of your personal data will involve a transfer of data outside the UK.
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 your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the UK.
Where we use certain service providers, we may use specific contracts approved by the UK, which give personal data the same protection it has in the UK. Any international transfers of your data will be carried out in compliance with the UK GDPR and Data Protection Act 2018, including use of the Information Commissioner’s Office’s International Data Transfer Agreement and Addendum, in force 21st March 2022.
Please Contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the UK.
7. DATA SECURITY
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions, and they are subject to a duty of confidentiality.
We have put in place procedures 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
HOW LONG WILL YOU USE MY PERSONAL DATA FOR?
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.
By law we have to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for six years after they cease being customers for tax and legal purposes. Details of retention periods for different aspects of your personal data are set out in the table in paragraph 4 above.
In certain circumstances you can ask us to delete your data: see Request erasure below for further information.
In some cases, we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.
9. YOUR LEGAL RIGHTS
Under certain circumstances, you have the following rights under data protection laws in relation to your personal data:
Request access to your personal data.
Request correction of your personal data.
Request erasure of your personal data.
Object to processing of your personal data.
Request restriction of processing your personal data.
Request transfer of your personal data.
Right to withdraw consent.
If you wish to exercise any of the rights set out above, please Contact us, setting out the details of your request.
NO FEE USUALLY REQUIRED
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.
WHAT WE MAY NEED FROM YOU
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
TIME LIMIT TO RESPOND
We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
10. GLOSSARY
LAWFUL BASIS
Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by Contacting us
Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.
Comply with a legal or regulatory obligation means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.
THIRD PARTIES
EXTERNAL THIRD PARTIES:
Service providers acting as processors who provide IT and system administration services.
Professional advisers acting as processors or joint controllers including lawyers, bankers, auditors and insurers based in the United Kingdom who provide consultancy, banking, legal, insurance and accounting services.
HM Revenue & Customs, regulators and other authorities acting as processors or joint controllers based in the United Kingdom.
YOUR LEGAL RIGHTS
You have the right to:
Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.
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Anne Trans Healthcare Limited ("AHL", "we", "us", or "our") uses cookies and similar tracking technologies to enhance your experience on our website and to analyze our traffic. This Cookie Policy explains what cookies are, how we use them, and your choices regarding cookies. By using our website, you agree to the use of cookies as described in this policy.
1. What are Cookies?
Cookies are small text files that are placed on your computer or mobile device when you visit a website. They allow the website to recognize your device and store certain information about your preferences or past actions.
2. Types of Cookies We Use
2.1 Essential Cookies These cookies are necessary for the website to function properly. They enable you to navigate our website and use its features, such as accessing secure areas. Without these cookies, certain services you request cannot be provided.
2.2 Performance and Analytics Cookies These cookies collect information about how you use our website, such as which pages you visit and if you experience any errors. The information collected is used to improve how our website works and to understand user interactions. These cookies do not collect information that identifies you personally.
2.3 Functionality Cookies Functionality cookies allow our website to remember choices you make (such as your username, language, or region) and provide enhanced, more personalised features. These cookies can also be used to remember changes you have made to text size, fonts, and other customizable parts of web pages.
2.4 Advertising and Targeting Cookies These cookies are used to deliver advertisements that are relevant to you and your interests. They also limit the number of times you see an advertisement and help measure the effectiveness of advertising campaigns. These cookies remember that you have visited a website and this information may be shared with other organisations, such as advertisers.
3. How We Use Cookies
We use cookies to:
Ensure our website functions correctly
Understand how users interact with our website
Improve the performance and functionality of our website
Provide personalised features and content
Deliver relevant advertising and track its effectiveness
4. Third-Party Cookies
Some cookies on our website are set by third parties, such as analytics providers and advertisers. These third parties may use cookies to collect information about your browsing activities across different websites. We do not control these third-party cookies and their use is subject to the privacy policies of the third parties.
5. Your Choices Regarding Cookies
5.1 Browser Settings Most web browsers allow you to control cookies through their settings. You can set your browser to refuse cookies or delete specific cookies. However, if you disable cookies, some features of our website may not function properly.
5.2 Cookie Consent Tool We provide a cookie consent tool on our website that allows you to manage your cookie preferences. You can use this tool to accept or reject different categories of cookies.
6. Changes to This Cookie Policy
We may update this Cookie Policy from time to time to reflect changes in our practices or for other operational, legal, or regulatory reasons. We will notify you of any changes by posting the new Cookie Policy on our website. You are advised to review this Cookie Policy periodically for any changes.
7. Contact Us
If you have any questions about this Cookie Policy or our use of cookies, please contact us at:
Anne Trans Healthcare Limited
71-75 Shelton Street,
Covent Garden,
London, United Kingdom,
WC2H 9JQ
Email: hello@anne.health
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Anne is committed to providing quality care and support to all our Members. Your feedback, compliments, and complaints are important to us as they help us improve our services and ensure we meet your needs effectively.
Feedback
We welcome and appreciate all feedback from our Members. You can provide feedback via phone, email, or in writing. We will use your feedback to continually enhance our services and better meet your expectations.
Compliments
If you have had a positive experience with Anne, we would love to hear from you. Your compliments motivate us and help us recognise the efforts of our dedicated team members. Please feel free to share your compliments with us through any of the communication channels mentioned above.
Complaints
We take complaints seriously and view them as an opportunity to learn and improve. If you have a complaint about any aspect of our services, please bring it to our attention promptly. You can lodge a complaint via the Member Portal, by email to hello@anne.health, or in writing. We will investigate your complaint thoroughly and strive to address it in a timely and fair manner.
Confidentiality
All feedback, compliments, and complaints will be handled confidentially. We respect your privacy and will only share information on a need-to-know basis to address your concerns effectively.
Timelines
We aim to acknowledge receipt of your feedback, compliments, or complaints within 48 hours Monday to Friday 9am - 5pm. For complaints, we will provide you with updates on the progress of the investigation and the expected resolution timeframe.
Escalation
If you feel that your complaint has not been addressed satisfactorily, you can escalate it to the next level of management within Anne.
We thank you for taking the time to provide us with your feedback, compliments, and complaints. Your input is valuable in helping us maintain high standards of care and support for the transgender communities.