Privacy Policy
In this document references to “we”, “us” and “our” are to Anna Konovalova (Anna Key). References to “our Website” or “the Website” are to www.keypointacupuncture.com
As part of the new GDPR regulations we have updated our privacy policy.
However in short, the data we collect is for the purposes of your treatment and for communication directly with for treatment or booking purposes. You are free to ask at any time for all data to be destroyed or dealt with however you wish.
Disclaimer
Information contained on www.keypointacupuncture.com is intended to be informative and express the viewpoints of Chinese Medicine and western medicine, it is not intended to be medical advice and does not substitute advice given by other healthcare professionals.I believe in an integrative and complementary approach to health and advises all patients to discuss any health concerns with their doctor. Any patient opinions on this website are opinions and do not represent testimonials. Any opinions expressed on this website are not necessarily my opinions. Nothing on this website should be considered a cure for any ‘incurable’ disease. If you have any concerns or questions about any of the content on this website then please contact us.
Terms of Website Use
Please read these terms of use carefully before you start to use the site. By using our site, you indicate that you accept these terms of use and that you agree to abide by them. If you do not agree to these terms of use, please refrain from using our site.
Reliance On Information Posted And Disclaimer
The materials contained on our site are provided for general information purposes only and do not claim to be or constitute legal or other professional advice and shall not be relied upon as such.
We do not accept any responsibility for any loss which may arise from accessing or reliance on the information on this site and to the fullest extent permitted by English law, we exclude all liability for loss or damages direct or indirect arising from use of this site.
Accessing Our Site
Access to our site is permitted on a temporary basis, and we reserve the right to withdraw or amend the service we provide on our site without notice (see below). We will not be liable if for any reason our site is unavailable at any time or for any period.
Using Our Site
You should be 18 or older to use our site. Minors under 18 years of age and at least 13 years of age are permitted to use our services only if they have the appropriate permission and direct supervision by a parent or legal guardian. Children under age 13 are not permitted to use our services. You are responsible for any and all activity conducted by a minor on this site.
Intellectual Property Rights
We are the owner or the licensee of all intellectual property rights in our site, and in the material published on it. Those works are protected by copyright laws and treaties around the world. All such rights are reserved.
You may print off one copy, and may download extracts, of any page(s) from our site for your personal reference and you may draw the attention of others within your organisation to material posted on our site.
You must not modify the paper or digital copies of any materials you have printed off or downloaded in any way, and you must not use any illustrations, photographs, video or audio sequences or any graphics separately from any accompanying text.
Our status (and that of any identified contributors) as the authors of material on our site must always be acknowledged.
You must not use any part of the materials on our site for commercial purposes without obtaining a licence to do so from us or our licensors.
If you print off, copy or download any part of our site in breach of these terms of use, your right to use our site will cease immediately and you must, at our option, return or destroy any copies of the materials you have made.
Our Site Changes Regularly
We aim to update our site regularly, and may change the content at any time. If the need arises, we may suspend access to our site, or close it indefinitely. Any of the material on our site may be out of date at any given time, and we are under no obligation to update such material.
Our Liability
The material displayed on our site is provided without any guarantees, conditions or warranties as to its accuracy. To the extent permitted by law, we, and third parties connected to us hereby expressly exclude:
All conditions, warranties and other terms which might otherwise be implied by statute, common law or the law of equity.
Any liability for any direct, indirect or consequential loss or damage incurred by any user in connection with our site or in connection with the use, inability to use, or results of the use of our site, any websites linked to it and any materials posted on it, including, without limitation any liability for:
loss of income or revenue;
loss of business;
loss of profits or contracts;
loss of anticipated savings;
loss of data;
loss of goodwill;
wasted management or office time; and
for any other loss or damage of any kind, however arising and whether caused by tort (including negligence), breach of contract or otherwise, even if foreseeable, provided that this condition shall not prevent claims for loss of or damage to your tangible property or any other claims for direct financial loss that are not excluded by any of the categories set out above.
This does not affect our liability for death or personal injury arising from our negligence, nor our liability for fraudulent misrepresentation or misrepresentation as to a fundamental matter, nor any other liability which cannot be excluded or limited under applicable law.
Information About You And Your Visits To Our Site
We process information about you in accordance with our privacy policy (see below). By using our site, you consent to such processing and you warrant that all data provided by you is accurate.
Viruses, Hacking, And Other Offences
You must not misuse our site by knowingly introducing viruses, trojans, worms, logic bombs or other material which is malicious or technologically harmful. You must not attempt to gain unauthorised access to our site, the server on which our site is stored or any server, computer or database connected to our site. You must not attack our site via a denial-of-service attack or a distributed denial-of service attack.
By breaching this provision, you would commit a criminal offence under the Computer Misuse Act 1990. We will report any such breach to the relevant law enforcement authorities and we will cooperate with those authorities by disclosing your identity to them. In the event of such a breach, your right to use our site will cease immediately.
We will not be liable for any loss or damage caused by a distributed denial-of-service attack, viruses or other technologically harmful material that may infect your computer equipment, computer programs, data or other proprietary material due to your use of our site or to your downloading of any material posted on it, or on any website linked to it.
Links From Our Site
Where our site contains links to other sites and resources provided by third parties, these links are provided for your information only. We have no control over the contents of those sites or resources, and accept no responsibility for them or for any loss or damage that may arise from your use of them. When accessing a site via our website we advise you to check their terms of use and privacy policies to ensure compliance and determine how they may use your information.
Jurisdiction And Applicable Law
The English courts will have non-exclusive jurisdiction over any claim arising from, or related to, a visit to our site.
These terms of use and any dispute or claim arising out of or in connection with them or their subject matter or formation (including non-contractual disputes or claims) shall be governed by and construed in accordance with the law of England and Wales.
Variations
We may revise these terms of use at any time by amending this page. You are expected to check this page from time to time to take notice of any changes we made, as they are binding on you. Some of the provisions contained in these terms of use may also be superseded by provisions or notices published elsewhere on our site.
Your Concerns
If you have any concerns about material which appears on our site, please contact us.
Thank you for visiting our site.
Privacy & Cookie Policy
This privacy policy sets out how we use and protect any information that you give us when you use this website. By accepting our Terms of Use (see below), you are confirming that you have read and understand this policy including how and why we use your information. If you don’t want us to collect or process your personal information in the ways described in this policy, you shouldn’t use our website or services.
Our Terms of Use require all users to be at least 18 years of age. Minors under 18 years of age and at least 13 years of age are permitted to use our services only if they have the appropriate permission and direct supervision by a parent or legal guardian. Children under age 13 are not permitted to use our services. You are responsible for any and all activity conducted by a minor on this site.
We are committed to ensuring that your privacy is protected. Should we ask you to provide certain information by which you can be identified when using this website, then you can be assured that it will only be used in accordance with this privacy statement.
We may change this policy from time to time by updating this page. You should check this page from time to time to ensure that you are happy with any changes.
We respect your privacy: We will not sell your information. We may use it to target advertising across the websites affiliated with our third-party cookie provider and on social media.
What We Collect
We use data analytics to ensure site functionality and improve our services. We use a third party service (Google Analytics) to collect standard internet log information and details of visitor behaviour patterns when you visit our website. We do this to find out things such as the number of visitors to the various parts of the site. This information is only processed in a way which does not identify anyone. We do not link the information we store within the analytics software to any personally identifiable information that you submit on our website.
We may collect information about your use of the services for advertising, analytics, to serve content and to protect the services, including your IP address, browser information, device information and location information. We may obtain location information via your IP address. We may use and store information about your location to provide features and to improve and customise the services, for example, to change the currency displayed on the website. If you have consented to share your precise device location details but would no longer like to continue sharing that information with us, you may revoke your consent to the sharing of that information through the settings on your browser and / or mobile device. Certain non-precise location services, such as for security and localised policies based on your IP address or submitted address, are critical for the site to function. We will only share your geo-location details with third parties (like our mapping, payments, or, to the extent applicable, advertising providers) in order to provide you with the services.
You do not need to register with us in order to use our website. We may receive or obtain information, such as an email address or IP address, about a person who is not a registered member (non-member) in connection with certain website features, such as sending us an email enquiry. Non-member information is used only for the purposes disclosed when it was submitted to us or to facilitate an action authorised by the non-member.
What We Do With The Information We Gather
We require this information to understand your needs and provide you with a better service, and in particular for the following reasons:
To answer any queries or requests you may have, and carry out our obligations arising from any contracts entered into between you and us.
To identify you when you make contact with us.
For statistical or survey purposes and market analysis to improve our services.
To ensure that content from our services is presented in the most effective manner for you and for your device.
To administer our services.
We may also record and monitor communications between you and us to ensure quality assurance and compliance.
Security
We are committed to ensuring that your information is secure. In order to prevent unauthorised access or disclosure, we have put in place suitable physical, electronic and managerial procedures to safeguard and secure the information we collect online.
Messages From Keypoint Acupuncture
On occasion, we may need to contact you. Primarily, these messages are delivered by email and every new web enquiry is required to provide a valid email address to receive messages. We may also contact you by telephone to provide member support or for query-related purposes if you request that we call you.
You must always opt-in to receive marketing messages from us. When you subscribe to our newsletter, you receive notice of and agree to receive marketing emails and messages from us. If you subscribe for our newsletters or otherwise agree to receive marketing from us, we may send you email alerts for new sales event launches, products, features, enhancements, special offers, upgrade opportunities, events of interest, and one-off marketing promotions. Such alerts may include marketing information about us, our subsidiaries or selected business partners. You can unsubscribe at any time from marketing emails through the opt-out link included in marketing emails or by contacting us. From time to time, we may also use your information to contact you for market research purposes. We may contact you by email, phone or mail. We may use the information to customise the website according to your interests.
How We Use Cookies
A cookie is a small file which asks permission to be placed on your computer’s hard drive. Once you agree, the file is added and the cookie helps analyse web traffic or lets you know when you visit a particular site. Cookies allow web applications to respond to you as an individual. The web application can tailor its operations to your needs, likes and dislikes by gathering and remembering information about your preferences.
We use “session cookies” to obtain statistical data about our users’ browsing actions and patterns. These are saved to the browser only and disappear when the browser is closed. We use “permanent cookies” to remember if you have visited us before; these will stay on your computer after you leave our website. We use “traffic log cookies” to identify which pages are being used. This helps us analyse data about web page traffic and improve our website in order to tailor it to customer needs. We only use this information for statistical analysis purposes and then the data is removed from the system.
Overall, cookies help us provide you with a better website, by enabling us to monitor which pages you find useful and which you do not. A cookie in no way gives us access to your computer or any information about you, other than the data you choose to share with us.
You can choose to accept or decline cookies. Most web browsers automatically accept cookies, but you can usually modify your browser setting to decline cookies if you prefer. This may prevent you from taking full advantage of the website.
Our Third Party Marketing And Profiling Cookies
We use marketing cookies from our trusted third party company (Google) to create user-related profiles (Similar Audiences and Affinity Audiences) that meet the preferences shown during the visit on our website. While you navigate on our website these cookies are useful for showing you services, products and content which are similar to those you have viewed. These cookies allow you to be provided with our commercial offering across devices on other websites affiliated with Google (retargeting) and to people (Similar Audiences and Affinity Audiences) whose interests match your profile based on your preferences and navigation shown during your visit on our website and expressed in the settings of your Google profile.
How You Can Disable Cookies And Manage Your Preferences:
Our Cookies
The majority of browsers are configured to accept, control or potentially disable cookies through the settings. We nevertheless remind you that disabling traffic cookies may affect the functioning of the website and and / or limit the service we offer and / or limit our ability to personalise the website functioning according to your preferences. Below is the procedure to follow to manage cookies from the following browsers:
Third Party Cookies
For information about how you can opt out of Google’s use of cookies please visit:
To opt-out of cookies installed on your browser by other companies please visit the Network Advertising Initiative opt out page.
To learn more about profiling cookies, please click here.
Links To Other Websites
Our website may contain links to other websites of interest. However, once you have used these links to leave our site, you should note that we do not have any control over that other website. Therefore, we cannot be responsible for the protection and privacy of any information which you provide whilst visiting such sites and such sites are not governed by this privacy statement. You should exercise caution and look at the privacy statement applicable to the website in question.
Controlling Your Personal Information
You may choose to restrict the collection or use of your personal information in the following ways:
whenever you are asked to fill in a form on the website, look for the box that you can click to indicate that you consent to the information being used by anybody for direct marketing purposes.
if you have previously agreed to us using your personal information for direct marketing purposes, you may change your mind at any time by contacting us or clicking on the unsubscribe link at the bottom of every marketing email sent.
We will not sell, distribute or lease your personal information to third parties unless we have your permission or are required by law to do so. We may use your personal information to send you promotional information about third parties which we think you may find interesting if you tell us that you wish this to happen.
You may request details of personal information which we hold about you under the General Data Protection Regulation Act 2018. If you would like a copy of the information held on you please contact us
If you believe that any information we are holding on you is incorrect or incomplete, or if you would like your information deleted, please email us as soon as possible at keypointacupuncture@gmail.com. We will promptly correct any information found to be incorrect or delete all the information we hold on you within 28 days of being notified. There is no fee for this, however where the request is manifestly unfounded or excessive, we may charge a small fee for the administrative costs of complying with the request.
We respect your privacy: We will not sell your information. We may use it to target advertising on social media.
How Do We Process Your Personal Data?
We comply with our obligations under the GDPR by keeping personal data up to date; by storing and destroying it securely; by not collecting or retaining excessive amounts of data; by protecting personal data from loss, misuse, unauthorised access and disclosure and by ensuring that appropriate technical measures are in place to protect personal data. We use your personal data for the purposes set out below.
Sections 1 – 15 apply to our patients, prospective patients, former patients and visitors to our clinic
We use your name, address, telephone number and email address to make and rearrange appointments. We are unable to send or receive encrypted emails so you should be aware that any emails we send or receive may not be protected in transit. We will also monitor any emails sent to us, including file attachments, for viruses or malicious software. Please be aware that you have a responsibility to ensure that any email you send us is within the bounds of the law.
We keep a permanent attendance register which records all appointments for patients attending our clinic to keep a record of when you were treated for tax purposes and to secure potential evidence in the event of a criminal prosecution, civil litigation, insurance claim or complaint to my regulatory body, the Acupuncture society.
We may use your date of birth to help identify patients with the same name to avoid mistakes being made as to safe and appropriate treatment, for identification purposes if referring a patient to another health practitioner, and for identification purposes if writing to a registered medical practitioner so that they correctly identify the patient.
We use your presenting complaint and symptoms reported by you for the purposes of making a full traditional diagnosis, formulating treatment strategy and treatment planning.
We use any relevant medical, family history and information of the patient form you have told us for making a full traditional diagnosis, formulating treatment strategy and treatment planning.
We use your GP’s name and address in the event that we need to contact your GP including in an emergency and because it is a mandatory requirement in the British Acupuncture Code of Professional Conduct. This is done with additional requested consent
We use our clinical findings about your health and wellbeing for making a full traditional diagnosis, and formulating treatment strategy and treatment planning.
We keep a record of and refer to that record of any treatment given and details of progress of your case, including reviews of treatment planning to enable us to: review the full traditional diagnosis, treatment strategy and planning; and to secure evidence in the event of criminal proceedings, civil litigation, an insurance claim or complaint.
We record and use any information and advice that we have given, especially when referring patients to any other health professional, to help you to receive the most appropriate treatment and to secure evidence in the event of criminal proceedings, civil litigation, an insurance claim or complaint.
We record any decisions made in conjunction with you to help you to receive the most appropriate treatment and to secure evidence in the event of criminal proceedings, civil litigation, an insurance claim or complaint.
We keep accident records for any patients, visitors or staff who are involved in accidents at our clinic in accordance with UK Health and Safety legislation including the Reporting of Injuries, Diseases and Dangerous Occurrences Regulations (RIDDOR) to comply with the law and to secure evidence in the event of criminal proceedings, civil litigation, an insurance claim or complaint.
In the event of an adverse incident occurring to any of our patients we report the matter to the Acupuncture society and the our insurance company to enable the insurance company to deal with any potential claims and to help the Acupuncture society to develop its safe practice guidelines, as well as providing research data and information for the Acupuncture society’s insurers and other interested parties.
Where relevant we maintain records of the patient’s consent to treatment, or the consent of their next-of-kin in order to be able to prove that the patient (and/or parent/guardian/next of kin) has given informed consent to treatment to secure evidence in the event of a civil claim, criminal prosecution, insurance claim or complaint.
Section 14 applies to those who complain about our services
When we receive a complaint from a person we make up a file containing the details of the complaint. This normally contains the identity of the complainant and any other individuals involved in the complaint.
We will only use the personal information we collect to process the complaint and to check on the level of service we provide. We usually have to disclose the complainant’s identity to whoever the complaint is about. If a complainant doesn’t want information identifying him or her to be disclosed, we will try to respect that. However, it may not be possible to handle a complaint on an anonymous basis. We may need to provide personal information collected and processed in relation to complaints to the British Acupuncture Council or our insurance company.
We will keep personal information contained in complaint files in line with our retention policy. This means that information relating to a complaint will be retained for two years from closure. It will be retained in a secure environment and access to it will be restricted according to the ‘need to know’ principle.
Similarly, where enquiries are submitted to us we will only use the information supplied to us to deal with the enquiry and any subsequent issues and to check on the level of service we provide.
Sharing your personal data
Your personal data will be treated as strictly confidential, and will be shared:
with named third parties with your explicit consent (written or said);
with the relevant authority such as the police or a court, if necessary for compliance with a legal obligation to which we are subject e.g. a court order;
with your doctor or the police if necessary to protect yours or another person’s life;
with the police or a local authority for the purpose of safeguarding a children or vulnerable adults; or
with my regulatory body, the British Acupuncture Council, or my insurance company in the event of a complaint or insurance claim being brought against me; or
my solicitor in the event of any investigation or legal proceedings being brought against me.
For further details about the situations when information about you might be shared please see the Information Commissioner’s website at https://ico.org.uk/for-the-public/personal-information/sharing-my-info/
How Long Do We Keep Your Personal Data?
We keep your personal data for no longer than reasonably necessary.
We keep patient records for a period of 7 years in accordance with the Acupuncture society Code of Professional Conduct https://www.acupuncturesociety.org.uk/2018oldbk/code-of-ethics/#record-keeping
We keep employee records for a period of 7 years for full tax purposes.
At any time you may request that changes are made to your contact details.
Your Rights And Your Personal Data
Unless subject to an exemption under the GDPR, you have certain rights with respect to your personal data as set out below.
The right to request a copy of your personal data which we hold about you.
The right to request that we correct any personal data if it is found to be inaccurate or out of date.
The right to request your personal data is erased where it is no longer necessary for us to retain such data.
The right to withdraw your consent to the processing at any time. This right does not apply where we are processing information using a lawful purpose other than consent.
The right to request that we provide you with your personal data and where possible, to transmit that data directly to another data controller, (known as the right to data portability), (where applicable) [This right only applies where the processing is based on consent or is necessary for the performance of a contract with you and in either case the we are processing the data by automated means].
The right, where there is a dispute in relation to the accuracy or processing of your personal data, to request a restriction is placed on further processing.
The right to object to the processing of personal data, (where applicable) [This right only applies where processing is based on legitimate interests (or the performance of a task in the public interest/exercise of official authority); direct marketing and processing for the purposes of scientific/historical research and statistics].
The right to be informed if your data is lost. We shall also inform the Information Commissioner’s Office in accordance with the time limits in the GDPR.
The right to lodge a complaint with the Information Commissioner’s Office.
For further details about these rights please see the Information Commissioner’s website at https://ico.org.uk/for-the-public/is-my-information-being-handled-correctly/
Further Processing
If we wish to use your personal data for a new purpose, not covered by this Privacy Notice, then we will provide you with a new notice explaining this new use prior to commencing the processing and setting out the relevant purposes and processing conditions. Where and whenever necessary, we will seek your prior consent to the new processing.
Contact Details
To exercise all relevant rights, queries of complaints please in the first instance contact us at keypointacupuncture@gmail.com
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Kind regards,
Anna