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Privacy

Xytal Health Management Ltd understands that your privacy is important to you and that you care about how your personal data is used. We respect and value the privacy of everyone who uses our company services and all who visits our website, www.xytal.com (“Our Site”) and will only collect and use personal data in ways that are described here, and in a way that is consistent with our obligations and your rights under the law.

Please read this Privacy Policy carefully and ensure that you understand it.

Definitions and Interpretation

In this Policy the following terms shall have the following meanings:

“Account” “Cookie” “Cookie Law”

means an account required to access and/or use certain areas and features of our Site;

means a small text file placed on your computer or device by our Site when you visit certain parts of our Site and/or when you use certain features of our Site. Details of the Cookies used by our Site are set out in Part 14, below; and

 means the relevant parts of the Privacy and Electronic Communications (EC Directive) Regulations 2003;


Information About Us

Our Site is owned and operated by Xytal Health Management Ltd, a limited company registered in England under company number 04946997.

Registered address: Xytal Health Management Ltd, The Vineyard Little Norton, Norton Sub Hamdon, Stoke-Sub-Hamdon, Somerset, TA14 6TE.

The Company’s responsible staff members for ensuring data protection compliance are Xytal Back Office staff members and can be contacted by email at dataprotection@xytal.com, by telephone on 0113 834 5015 or by post at Xytal Health Management, The Vineyard Little Norton, Norton Sub Hamdon, Stoke-Sub-Hamdon, Somerset, TA14 6TE.

What Does This Policy Cover?

This Privacy Policy applies to all aspects of Our company including Our Site. Our Site may contain links to other websites. Please note that we have no control over how your data is collected, stored, or used by other websites and we advise you to check the privacy policies of any such websites before providing any data to them.

What Is Personal Data?

Personal data is defined by the UK GDPR and the Data Protection Act 2018 (collectively, “the Data Protection Legislation”) as ‘any information relating to an identifiable person who can be directly or indirectly identified in particular by reference to an identifier’.

Personal data is, in simpler terms, any information about you that enables you to be identified. Personal data covers obvious information such as your name and contact details, but it also covers less obvious information such as identification numbers, electronic location data, and other online identifiers.

What Are My Rights?

  • Under the Data Protection Legislation, you have the following rights, which we will always work to uphold:
  • The right to be informed about our collection and use of your personal data. This Privacy Policy should tell you everything you need to know, but you can always contact us to find out more or to ask any questions using the details in Part 15.
  • The right to access the personal data we hold about you. Part 13 will tell you how to do this.
  • The right to have your personal data rectified if any of your personal data held by us is inaccurate or incomplete. Please contact us using the details in Part 15 to find out more.
  • The right to be forgotten, i.e. the right to ask us to delete or otherwise dispose of any of your personal data that we hold. Please contact us using the details in Part 15 to find out more.
  • The right to restrict (i.e. prevent) the processing of your personal data.
  • The right to object to us using your personal data for a particular purpose or purposes.
  • The right to withdraw consent. This means that, if we are relying on your consent as the legal basis for using your personal data, you are free to withdraw that consent at any time.
  • The right to data portability. This means that, if you have provided personal data to us directly, we are using it with your consent or for the performance of a contract, and that data is processed using automated means, you can ask us for a copy of that personal data to re-use with another service or business in many cases.
  • Rights relating to automated decision making and profiling. Xytal do not use automated decision making. Xytal do use analytical cookies on our website – please refer to the Cookie Policy for further details.
  • For more information about our use of your personal data or exercising your rights as outlined above, please contact us using the details provided in Part 15.
  • It is important that your personal data is kept accurate and up-to-date. If any of the personal data we hold about you changes, please keep us informed as long as we have that data.
  • Further information about your rights can also be obtained from the Information Commissioner’s Office or your local Citizens Advice Bureau.
  • If you have any cause for complaint about our use of your personal data, you have the right to lodge a complaint with the Information Commissioner’s Office. We would welcome the opportunity to resolve your concerns ourselves, however, so please contact us first, using the details in Part 15.

What Data Do You Collect and How?

As a customer of ‘Our Company’ we may collect the following data during the course of delivering our services and this could be collected electronically/physically via company forms and email or by telephone:

  • Contact details, such as title, full name, contact details and contact details history.
  • Records of contact with the company such as the online contact form.
  • Products and services the customer holds with the company , as well as have been interested in and have held.
  • The usage of the company’s products, services.
  • Marketing and analysing data for the customer, including history of those communications, and information about products or services the company may think that the customer would be interested in, analysing data to help target offers to the data subject that the company think are of interest or relevance to the data subject. Offers may include the company’s other improvement services and any of the company’s other products and services.
  • Information the company obtained from third parties; this may include the data subjects contact details in order to carry out an associated contract.
  • Insights about the data subject and our customers gained from analysis or profiling of customers.

Website

Depending upon your use of Our Site, we may collect and hold some or all of the personal and non-personal data set out in the table below, using the methods also set out in the table. Please also see Part 14 for more information about our use of Cookies and similar technologies and our Cookie Policy and what information our cookies collect. We do not collect any ‘special category’ or ‘sensitive’ personal data and personal data relating to children or data relating to criminal convictions and/or offences.

Data Collected via Website (please also refer to Cookie Policy for information our cookies collect) How We Collect the Data
Identity Information including full name, title Website Contact Form
Website Subject Access Request Form
Analytical cookies (see Cookie Policy for more information)
Contact information including address, email address and telephone number. Website Contact Form
Website Subject Access Request Form


How Do You Use My Personal Data?

Under the Data Protection Legislation, we must always have a lawful basis for using personal data. The table in Section 8 of this document describes how we use your personal data, and our lawful basis for doing so:

With your permission and/or where permitted by law, we may also use your personal data for marketing purposes, which may include contacting you by email or telephone with information, news, and offers our services. You will not be sent any unlawful marketing or spam. We will always work to fully protect your rights and comply with our obligations under the Data Protection Legislation and the Privacy and Electronic Communications (EC Directive) Regulations 2003, and you will always have the opportunity to opt-out. We will always obtain your express opt-in consent before sharing your personal data with third parties for marketing purposes and you will be able to opt-out at any time.

Xytal Health Management Ltd do not use third party cookies on Our Site. Please refer to Part 14 for more information on controlling cookies. Please also refer to our Cookie Policy.

Xytal do not use automated decision making. Xytal do use analytical cookies on our website – please refer to the Cookie Policy for further details.

We will only use your personal data for the purpose(s) for which it was originally collected unless we reasonably believe that another purpose is compatible with that or those original purpose(s) and need to use your personal data for that purpose. If we do use your personal data in this way and you wish us to explain how the new purpose is compatible with the original, please contact us using the details in Part 15.

If we need to use your personal data for a purpose that is unrelated to, or incompatible with, the purpose(s) for which it was originally collected, we will inform you and explain the legal basis which allows us to do so.

In some circumstances, where permitted or required by law, we may process your personal data without your knowledge or consent. This will only be done within the bounds of the Data Protection Legislation and your legal rights.

How Long Will You Keep My Personal Data?

We will not keep your personal data for any longer than is necessary in light of the reason(s) for which it was first collected. Your personal data will therefore be kept for the following periods (or, where there is no fixed period, the following factors will be used to determine how long it is kept):

Business Function Type of Data Purpose of Processing Categories of individuals How Long we Keep It Our Lawful Basis (UK GDPR)
Communications – Contact details
[Communicating with you.] 		Identity Information including name and title. Contact information including address, email and telephone number. Business information including business name, job title, profession. Public Consultations Potential/ Existing Customers 10 years Article 6(1)(c) - legal obligation
Communications – Contact details
[Communicating with you.] 		Identity Information including name and title. Contact information including address, email and telephone number. Website Potential/ Existing Customers 6 years Article 6(1)(c) - legal obligation
Communications [Personalising and tailoring [our services]
[Personalising and tailoring your experience on Our Site]		 Identity Information including name and title. Contact information including address, email and telephone number. Website – Analytical Cookies (see Cookie Policy) Potential/ Existing Customers (See Cookie Policy) Article 6(1)(c) - legal obligation
Finance – Contact Details, [Communicating with you]
Bank Details [Managing payments for our services] 		Identity Information including name and title. Contact information including address, email and telephone number. Business information including business name, job title, profession. Payment information including data collected, card details, bank account numbers. Invoicing Existing Customers 7 Years post contract Article 6(1)(c) - legal obligation
Finance – Contact Details, [Communicating with you]
Bank Details [Managing payments for our services] 		Identity Information including name and title. Contact information including address, email and telephone number. Business information including business name, job title, profession. Payment information including data collected, card details, bank account numbers. Accounts Existing Customers 7 Years Article 6(1)(c) - legal obligation
Legal, Complaints & FOI Requests – Contact Details [Communicating with you] Identity Information including name and title. Contact information including address, email and telephone number. Business information including business name, job title, profession. Complaints Potential/Existing Customers 10 years Article 6(1)(c) - legal obligation
Legal, Complaints & FOI Requests – Contact Details [Communicating with you] [Supplying you with information] Identity Information including name and title. Contact information including address, email and telephone number. Business information including business name, job title, profession. FOI requests Potential/ Existing Customers 3 years Article 6(1)(c) - legal obligation
Legal, Complaints & FOI Requests – Contact Details [Communicating with you] [Supplying you with information] Identity Information including name and title. Contact information including address, email and telephone number. Business information including business name, job title, profession. FOI requests where there has been a subsequent appeal Potential/ Existing Customers 6 years Article 6(1)(c) - legal obligation
Identity Information including name and title. Contact information including address, email and telephone number. Business information including business name, job title, profession. Industrial relations including tribunal case records/ Litigation records/ Potential/ Existing Customers 10 years Article 6(1)(c) - legal obligation
Legal, Complaints & FOI Requests – Contact Details [Communicating with you] [Supplying you with information] Identity Information including name and title. Contact information including address, email and telephone number. Business information including business name, job title, profession. Subject Access Requests (SAR) and disclosure correspondence Potential/ Existing Customers 3 years Article 6(1)(c) - legal obligation
Legal, Complaints & FOI Requests – Contact Details [Communicating with you] [Supplying you with information] Identity Information including name and title. Contact information including address, email and telephone number. Business information including business name, job title, profession. Subject access requests where there has been a subsequent appeal Potential/ Existing Customers 6 years Article 6(1)(c) - legal obligation
Sales – Contact details [Communicating with you] [Supplying Our Services to you.] Identity Information including name and title. Contact information including address, email and telephone number. Business information including business name, job title, profession. To fulfil a contract Potential/ Existing Customers End of customer relationship Article 6(1)(c) - legal obligation
Sales – Contact details [Communicating with you] Identity Information including name and title. Contact information including address, email and telephone number. Business information including business name, job title, profession. Direct Marketing Potential Customers End of customer relationship Article 6(1)(c) - legal obligation
Sales – Contact details and Purchase History [Communicating with you] [Supplying Our Services to you.] Identity Information including name and title. Contact information including address, email and telephone number. Business information including business name, job title, profession. Profile information including purchase history. Direct marketing Existing Customers End of customer relationship Article 6(1)(c) - legal obligation


How and Where Do You Store or Transfer My Personal Data?

The company stores personal data on company servers, physical records, 3rd party servers and company and contractor devices based in the UK. Data stored in the UK will be fully protected under the Data Protection Legislation.

The Company also stores personal data in the United Kingdom and European Union. Data stored in the UK will be fully protected under the Data Protection Legislation. The EEA consists of all EU member states, plus Norway, Iceland, and Liechtenstein. This means that your personal data will be fully protected under the EU GDPR and/or to equivalent standards by law. Transfers of personal data to the EEA from the UK are permitted without additional safeguards. We will take steps in order to ensure that your personal data is treated just as safely and securely as it would be within the UK and under the Data Protection Legislation.

The security of your personal data is essential to us, and to protect your data, we take a number of important measures, including the following:

  • limiting access to your personal data to those employees, agents, contractors, and other third parties with a legitimate need to know and ensuring that they are subject to duties of confidentiality;
  • procedures for dealing with data breaches (the accidental or unlawful destruction, loss, alteration, unauthorised disclosure of, or access to, your personal data) including notifying you and/or the Information Commissioner’s Office where we are legally required to do so;

Do You Share My Personal Data?

We will not share any of your personal data with any third parties for any purposes, subject to the following exceptions.

In some limited circumstances, we may be legally required to share certain personal data, which might include yours, if we are involved in legal proceedings or complying with legal obligations, a court order, or the instructions of a government authority.

We may share your personal data with other companies in our consortia for the purpose of delivering services.

If any of your personal data is shared with a third party, as described above, we will take steps to ensure that your personal data is handled safely, securely, and in accordance with your rights, Our obligations, and the third party’s obligations under the law.

How Can I Control My Personal Data?

If you wish to opt out from receiving emails or correspondence from Xytal Health Management Ltd please email your request to dataprotection@xytal.com

Can I Withhold Information?

Please refer to Section 4 and Section 5 of our Cookie Policy, for details on what information cookies on Our Site collect and ‘consent and control information’. Your acceptance of Our Cookie Policy is deemed to occur when you press the Accept button on Our Cookie popup. If you do not agree to Our Cookie Policy, please stop using Our Site immediately.

How Can I Access My Personal Data?

If you want to know what personal data we have about you, you can ask us for details of that personal data and for a copy of it (where any such personal data is held). This is known as a “subject access request”.

All subject access requests should be made in writing and sent to the email: dataprotection@xytal.com or the postal address shown on the website To make this as easy as possible for you, a Subject Access Request Form is available for you to download and use on the website. You do not have to use this form, but it is the easiest way to tell us everything we need to know to respond to your request as quickly as possible.

There is not normally any charge for a subject access request. If your request is ‘manifestly unfounded or excessive’ (for example, if you make repetitive requests) a fee may be charged to cover our administrative costs in responding.

We will respond to your subject access request one month of receiving it. Normally, we aim to provide a complete response, including a copy of your personal data within that time. In some cases, however, particularly if your request is more complex, more time may be required up to a maximum of two months from the date we receive your request. You will be kept fully informed of our progress.

HowDo You Use Cookies?

Please refer to our Cookie Policy.

How Do I Contact You?

The Company’s responsible staff members for ensuring data protection compliance are Xytal Back Office staff members. The Xytal ‘Back Office’ staff members are responsible for administering this Policy and for developing and implementing any applicable related policies, procedures, and/or guidelines.

To contact us about anything to do with your personal data and data protection, including to make a subject access request, please use the following details:

Email address: dataprotection@xytal.com

Telephone number: 0113 834 5015

Postal Address: Xytal Health Management Ltd, The Vineyard Little Norton, Norton Sub Hamdon, Stoke-Sub-Hamdon, Somerset, TA14 6TE.

Changes to this Privacy Policy

We may change this Privacy Notice from time to time. This may be necessary, for example, if the law changes, or if we change our business in a way that affects personal data protection.

Any changes will be immediately posted on Our Site and you will be deemed to have accepted the terms of the Privacy Policy on your first use of Our Site following the alterations. We recommend that you check this page regularly to keep up-to-date. This Privacy Policy was last updated on 20th July 2021.

This policy has been approved & authorised by:

Name: Richard More

Position: Chief Executive

Date 20.07.2021

Review Date: 20.07.2022