PRIVACY POLICY

Our contact details

Name: Clearwax Ltd
Address: C/O, The Hear Clinic, 1 Grange Lodge Cottages, Stoughton Grange Rural Centre, Oadby, Leicestershire, LE2 2FB
E-mail: info@clearwax.co.uk
Website: www.clearwax.co.uk

1. The type of personal information we collect

We may currently collect and process the following information:

• your name;
• your date of birth;
• your contact phone numbers (including mobile);
• your email and postal address;
• personal relevant medical and health history;
• your payment details;
• information about your employment and lifestyle;
• details of any prescription supplied to you by your healthcare professional or medical practitioner;
• information that you provide by filling in forms on our website;
• details of your visit to the website and any online transactions you carry out;
• any other information you have chosen to give us.

We mainly collect this information from you when you have chosen to give it to us. But we may also collect it from other sources if it is necessary and legal to do so, including from:

• the NHS or other healthcare providers or institutions;
• people who have your permission to provide information on your behalf (for example, your parents or guardians);
• third-party service providers; and
• government, tax or law-enforcement agencies.

2. How we get the personal information and why we have it

Most of the personal information we process is provided to us directly by you. We process your personal information for the following reasons, to help us provide you with the best possible hearing health care and customer experience. We will only process your personal information if we have a lawful basis (reason) to do so. We rely on the following lawful bases to collect and process your personal information;

Legitimate interests – It is in our genuine interests to process your information for the following purposes to make sure we provide you with a professional hearing service in the most secure and appropriate way:

• For our Clearwax Specialists to perform ear wax removal and additional ear health checks (if applicable) so we can understand your hearing health condition.
• For our Clearwax Specialists to book your ear wax removal appointment.
• For our Clearwax Specialists to confirm your appointment. Some Clearwax Specialists may send you confirmation by email and text message. They may also send you a reminder a short period before the appointment is due.
• For either ourselves or our Clearwax Specialists to contact you about changes to our or their service that could affect or inconvenience you.
• Some Clearwax Specialists may send you future appointment reminders.
• For us or our Clearwax Specialists to send you communications about looking after your hearing health, and information about correcting your hearing.
• To send you direct marketing communications about our products, offers and discounts. You can opt out of these communications at any time.
• To send you surveys and to ask for feedback to help us improve our service and make our service and products more relevant to you. We use information collected through customer surveys, cookies, research, and analysis to help us improve our service.
• To communicate with you about hearing health care information, special offers and discounts that are relevant to you.
• To respond to complaints, queries and any claims made against us.
• To ensure the safety and security of us and our Clearwax Specialists.
• To understand the experience of our customers when being treated by our Clearwax Specialists. This helps us to identify the strengths and weaknesses of our Clearwax Specialists, and can be used to inform a development strategy for improving Clearwax Specialists.

Please note, we or our Clearwax Specialists may communicate with you using the communication preferences you give us. This may include by post, email, text message, phone or on social media.

Contractual obligations – we rely on the responsibilities set out in our contract with you when we process your information in order to keep to any arrangements we have made with you. This may include for the following reasons:

• To manage your online account.
• To process transactions when you buy any of our goods and services.
• To process your credit-card or debit-card information when you are paying for goods and services, or when we are dealing with refunds.
• To provide you with our products and services.
• To meet the obligations we have under our contract with you.

Legal obligations – there may be times when we have a legal reason for needing to share and process your personal information you have given us, including for the following reasons:

• We may need to make your personal information available to other medical and healthcare practitioners, health and social care providers, or the NHS.
• We may need to respond to any complaints or claims we receive from our regulators or other third parties. Our regulators might also ask for information when carrying out their work.
• We may need to share your information with other third parties who have a legal right to access it (for example, the police, our insurers, external auditors, and investigators).
• We may need to share your information with companies who provide us with your updated personal information, such as changes to your contact information or deceased indicators (notice of your death).
• We will need to process your information if you ask us for a copy of the personal information we are holding. This is known as a ‘subject access request’ and is one of the rights you have under the General Data Protection Regulation (GDPR).
• We have to process your personal information to meet our responsibilities as registered and dispensing optometrists and audiologists.
• We may need to share your information to help prevent and detect fraud, and to protect the health and safety of members of the public, our staff and our customers.
• We may have to share your personal information to meet our corporate responsibilities, including during company mergers and when buying or selling assets.
  In line with our rights under relevant data-protection law, there may be times when we will anonymise your personal information. That means any details which could be used to identify you, such as your name, will be removed so that you can no longer be identified. We may use this anonymised information:
• for statistical research, and publication purposes; and
• to develop and improve future treatments, and the accuracy of core health-care technologies (health machines such as ear wax removal devices to help remove ear wax) and related products and medicines.

Consent – we rely on your consent (permission) to process your personal information within the Clearwax Network, and will ask you to provide this:

• You are able to remove your consent at any time. You can do this by contacting info@clearwax.co.uk

We also receive personal information indirectly, from the following sources in the following scenarios:

• Log Data – like many site operators, we collect information that your browser sends whenever you visit our Site (“Log Data”). This Log Data may include information such as your computer’s Internet Protocol (“IP”) address, browser type, browser version, the pages of our Site that you visit, the time and date of your visit, the time spent on those pages and other statistics. In addition, we may use third party services such as Google Analytics that collect, monitor and analyse you actions on the website.
• Cookies – these are files with small amount of data, which may include an anonymous unique identifier. Cookies are sent to your browser from a web site and stored on your computer’s hard drive. Like many sites, we use “cookies” to collect information. You can instruct your browser to refuse all cookies or to indicate when a cookie is being sent. However, if you do not accept cookies, you may not be able to use some portions of our Site.

3. How long do you keep my information for?

Your information is securely stored. We will keep personal information for as long as is reasonably necessary (or as defined under healthcare laws and regulations which apply) to provide products and services, including aftercare services, and to maintain records as needed to satisfy tax and other legal or regulatory requirements, as well as to protect and defend against claims. Once it is determined that there is no longer a legal basis to retain your Personal Data, it may be deleted or anonymised where it can no longer be used to identify you directly or indirectly.

We de-identify (anonymise) your personal data so that it does not directly or indirectly identify you for the following purposes; concerning health for future scientific and historical research purposes, analytics, and statistical purposes to develop and improve new treatments and programs of healthcare, related services, and products.

4. Who do you share personal information with

We may share your personal information with our Clearwax Specialists for any of the reasons we have given in this privacy policy.

Each of our Clearwax Specialists are separate companies run independently by themselves. As such, they each have their own private policy and we advise you contacted them directly for more information on this.

We may share your personal information with other people when it is necessary to do so, including for the following reasons:

• We may use other organisations to help us process personal information, but they are not allowed to use it for any other purposes. We may use the information we are given from other organisations to add to and improve our databases of customer details.
• We may reveal personal information to health authorities, including the NHS or national equivalent organisations.
• We may pass personal information to external agencies and organisations, including the police and other law-enforcement agencies, to prevent and detect fraud (including fraudulent transactions) and criminal activity. These external agencies may check the information we give them against public and private databases and may keep a record of those checks to use in future security checks.
• If a claim is made, or could be made, against us we may pass personal information to our insurers.
• If we sell or buy any business or assets, we may reveal personal information about you to the seller or buyer.
• If we (or our assets) are bought or taken over by another organisation (or there is a reorganisation within our corporate group), personal information we hold about customers will be one of the assets transferred.
• We may pass certain personal information to your employer if you have been referred to us as a corporate ear-care customer.
• We may pass your personal information to others:
  • if we have to by law (including under a court order);
  • to apply our Terms and Conditions of Use of Website (‘Terms of Use’) or the terms of other agreements we have with you; and
  • to protect our rights, property and safety and those of our customers, employees or others.
• We may share an anonymised version of your email address to third-party social media sites, such as Facebook, to enable us to display marketing to you. When we do this, we use a process called ‘hashing’ to protect your details. This is where we scramble the plain text of your email address into a unique and irreversible collection of numbers and letters so that your email address cannot be recognised. When we do this, social media providers are only allowed to use your information to display our marketing to you through their site and not for any of their own purposes. You can update your social media privacy preferences on your own social media accounts.
• We may share an anonymised version of your personal information or clinical test results (or both) to third-party equipment and technology suppliers or research institutions:
  • to provide you with clinical care;
  • to help the suppliers continually improve their products and test equipment (which means we can then provide you with the best care); and
  • for the purposes of clinical research.

5. How do you process my personal information?

Sometimes it may be necessary to share your personal information with our business partners (other organisations), or other Clearwax Specialists. This may mean sharing your information outside of the UK, European Union (EU) and European Economic Area (EEA), including in the USA. Please note, when information is shared outside of the UK, EU and EEA, it may be handled according to local laws.

If we need to share your personal information outside of the UK, EU or EEA, we will make sure that the transfer is in line with data-protection law.

Any contracts with the overseas companies we share personal information with will include standard clauses which are approved by the European Commission for transferring information from the EU. Where necessary, we will put further measures in place to protect your information. These clauses, and any further measures, make sure that your information is protected in the same way as it would be in the UK, EU and EEA.

6. How can I update or change the personal information you hold about me? 

You can update or change your personal information by signing in to your Clearwax account (if you are a registered online customer), or by contacting info@clearwax.co.uk

7. What rights do I have?

You have certain rights under UK data-protection law, including the right to:

• access your personal information (we may charge a fee if we are allowed to do so by law); and
• correct your personal information if it is inaccurate or incomplete.

You also have the right to ask us to delete your personal information and to stop processing it if we have no legal basis to keep storing or processing it. This includes if:

• we no longer need your personal information for the purpose originally collected or processed it for;
• you withdraw your permission;
• you object to us processing your personal information;
• you ask us to stop processing your personal information (although we are entitled to store your personal information, we cannot process it further if you ask us not to);
• we move or transfer your personal information to another organisation; or
• you object to us processing your personal information if we are processing it:
• based on our legitimate interests (our business purposes)
• for direct marketing; or
• for scientific or historical research and statistical purposes.

To exercise of the above rights, please contact Clearwax by emailing info@clearwax.co.uk.

8. What choices do I have?

We may use your personal information to contact you about our products and services.

If you do not want to receive marketing material (including special offers and discounts), you can let us know by emailing info@clearwax.co.uk.

9. How do you protect my personal information?

We use the following security technology and methods to help protect your personal information from unauthorised access and use.

• Encryption, meaning that information is hidden so that it cannot be read without special knowledge (such as a password). This is done with a secret code (a cypher). The hidden information is said to be ‘encrypted’.
• Using a different name for you so we can hide parts of your personal information.
• Controlling access to systems and networks. This allows us to stop people who are not allowed to view your personal information from getting access to it.
• Training our staff so they know how to handle personal information and how and when to report when something goes wrong.
• Regular testing of our technology and ways of working, including keeping up to date on the latest security updates.

We have no control over the contents of other websites or resources or Clearwax Specialists which are linked to our website. We accept no responsibility for them or the privacy practices they use, or for any loss or damage that results from you using those websites or resources.

10. Updating our Privacy Policy

We may update our privacy policy from time to time. Any updates will take effect as soon as they are posted on our website

11. How to complain 

If you have any concerns about our use of your personal information, you can make a complaint to us at info@clearwax.co.uk

You can also complain to the ICO if you are unhappy with how we have used your data.

The ICO’s address:

Information Commissioner’s Office
Wycliffe House
Water Lane
Wilmslow
Cheshire
SK9 5AF
Helpline number: 0303 123 1113
ICO website: https://www.ico.org.uk