Privacy Policy

Last updated: November 13 , 2024

1. Introduction

This Privacy Policy describes Our policies and procedures on the collection and use Your information when you use our website at www.therakind.com and/or any of Therakind’s other services or products or when you communicate or interact with us in any other way (our services). It also explains what rights are available to you under applicable privacy laws, in particular the UK Data Protection Act 2018 (DPA) and the General Data Protection Regulation (GDPR).

For the purposes of the DPA and GDPR, we, Therakind Limited, are the Data Controller. We can be contacted at 314 Regents Park Road, Third Floor, London, N3 2JX .

In this Privacy Policy:

you refers to any individual with whom we interact (other than our employees);
we, us and our refer to Therakind Limited;
personal data means any information relating to an identified or identifiable individual; and
process means any operation performed on personal data such as collecting, recording, storing, altering, using, disclosing, erasing or destroying it.

Related expressions are defined in accordance with the above.

2. Personal data we collect about you

The personal data we collect about you depends on our relationship with you and the particular services we provide to you or you provide to us.

Typically, we collect and process the following personal data about you:

your name and contact information, including email address, address and telephone number and company details;
information to check and verify your identity;
billing and transaction information;
your professional interests;
your contact history;
information about how you use our services;
your responses to our communications

We collect and use this personal data for the purposes described in section 4 below.

3. How your personal data is collected

We collect most of the above information from you. However, we may also collect information:

from publicly accessible sources;
from third parties;
automatically via our services and systems: see the section on Cookies below.

4. Purposes and Legal Basis of Processing

We only process your Personal Data where we have a legal basis to do so, namely where:

you have given consent in which case we will ask for it separately and you can withdraw it at any time (consent);
to comply with our legal and regulatory obligations (legal obligation);
to fulfil a contract with you or take steps at your request before entering into a contract (contract); or
for our legitimate interests or those of a third party (legitimate interest).

A legitimate interest is when we have a business reason to use your personal data, so long as this is not overridden by your own rights and interests.

The table below explains the purposes for which we use your personal data for and the legal basis in each case. Where the basis is legitimate interest, that interest is that the processing is helpful for our business and/or of societal benefit and is proportionate.

Purpose	Legal Basis
To provide and maintain our services, including monitoring your use of them.	Legitimate interest.
To contact you in relation to our services, your services or products or those of your employer.	Legitimate interest.
To provide you with news, offers and general information about services and events we offer that are similar to those that you have already purchased or enquired about unless you have opted not to receive such information.	Legitimate interest.
To provide you with services or fulfil contracts with you or your employer.	Contract.
Preventing and detecting fraud.	Legitimate interest.
Conducting identity checks and other activities necessary to comply with legal and regulatory obligations that apply to our business, e.g. under health and safety law.	Depending on the circumstances: - Legal obligation - Legitimate interest

To enforce legal rights or defend or take legal proceedings.	Depending on the circumstances: - Legal obligation - Legitimate interest
	· legitimate interest.
Gathering and providing information required by or relating to audits, enquiries or investigations by regulatory bodies.	Depending on the circumstances: - Legal obligation - Legitimate interest
Ensuring internal business policies are complied with, eg policies covering security and internet use.	Legitimate interest
Operational reasons, such as improving efficiency, training and quality control	Legitimate interest.
Ensuring the confidentiality of commercially sensitive information.	Depending on the circumstances: - Legal obligation - Legitimate interest
Protecting the security of systems and data used to provide services, preventing unauthorised access and changes to our systems.	Depending on the circumstances: - Legal obligation - Legitimate interest
Updating business records.	Depending on the circumstances: - Legal obligation - Contract - Legitimate interest
Statutory returns	Legal obligation.
Ensuring safe working practices, staff administration and assessments.	Depending on the circumstances: - Legal obligation - Legitimate interest
Marketing our services.	Depending on the circumstances: - Legitimate interest - Consent
Credit reference checks.	Legitimate interest.
External audits and quality checks.	Depending on the circumstances: - Legal obligation - Legitimate interest
In connection with a significant corporate transaction or restructuring, including a merger, acquisition or asset sale.	Legitimate interest.
Statistical analysis to help us manage our business, e.g. identifying usage trends, determining the effectiveness of our marketing and to evaluate and improve our services and your experience.	Legitimate interest.

5. Who we share your personal data with

We routinely share personal data with:

third parties we use to help deliver our services to you, e.g. providers of our finance system, IT service providers including cloud service providers such as data storage platforms, shared service centres and financial institutions in connection with invoicing and payments;
other third parties we use to help promote our business, e.g. marketing agencies;
our banks; and
other companies and organisations in our group.

We only allow those organisations to handle your personal data if we are satisfied they take appropriate measures to protect your personal data. We ensure all outsourcing providers operate under service agreements that are consistent with our legal obligations.

We or the third parties mentioned above may occasionally also share personal data with:

our and their external auditors;
our and their professional advisors (such as lawyers and other advisors
law enforcement agencies, courts, tribunals and regulatory bodies
other parties that have or may acquire control or ownership of our business (and our or their professional advisers) in connection with a significant corporate transaction or restructuring, including a merger, acquisition or asset sale.

If you would like more information about who we share our data with and why, please contact us (see ‘Contact us’ below).

6. International Transfer of your personal data

We primarily process your personal data in the UK.

If we ever transfer your personal data outside the UK and EEA, we take all steps reasonably necessary to ensure that your personal data is subject to appropriate safeguards, such as relying on a recognised legal adequacy mechanism or the adoption of approved standard contractual clauses that ensure adequate safeguards as required by DPA and/or GDPR, such as the IDTA and Addendum (see https://ico.org.uk/for-organisations/guide-to-data-protection/guide-to-the-general-data-protection-regulation-gdpr/international-data-transfer-agreement-and-guidance/). Further details of such safeguards are available on request.

7. For how long do we keep your personal data?

We will keep your personal data only for so long as is necessary for the purposes of our processing or for any legally required period.

Broadly, this is for as long as we have an active relationship with you or your employer and for as long as necessary afterwards:

to respond to any questions, complaints or claims made by you or on your behalf;
to keep records required by law; and
to enforce or defend our rights against any possible legal action for the applicable limitation period, which is typically six years after the cause of action arose.

Because the purposes and types of personal data that we process vary, different retention periods apply. The criteria we use for determining this are based on the continued need for us to retain the information based on the legal basis and purpose for which we use it.

8 Cookies

We use Cookies and similar tracking technologies to track the activity on Our services and store certain information. Tracking technologies used are beacons, tags, and scripts to collect and track information and to improve and analyze Our services.

The technologies we use include:

Cookies or Browser Cookies. A cookie is a small file placed on your device. 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 parts of our services. Unless you have adjusted Your browser setting so that it will refuse Cookies, our services may use Cookies.
Flash Cookies. Certain features of our services may use local stored objects (or Flash Cookies) to collect and store information about Your preferences or Your activity on our services. Flash Cookies are not managed by the same browser settings as those used for Browser Cookies. For more information on how You can delete Flash Cookies, please read "Where can I change the settings for disabling, or deleting local shared objects?" available at https://helpx.adobe.com/flash-player/kb/disable-local-shared-objects-flash.html#main_Where_can_I_change_the_settings_for_disabling__or_deleting_local_shared_objects_
Web Beacons. Certain sections of our services and our emails may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit the Company, for example, to count users who have visited those pages or opened an email and for other related website statistics (for example, recording the popularity of a certain section and verifying system and server integrity).

Cookies can be "Persistent" or "Session" Cookies. Persistent Cookies remain on Your personal computer or mobile device when You go offline, while Session Cookies are deleted as soon as You close Your web browser. You can learn more about cookies here: Cookies by TermsFeed Generator.

We use both Session and Persistent Cookies for the purposes set out below:

Necessary / Essential Cookies
Type: Session Cookies
Administered by: Us
Purpose: These Cookies are essential to provide You with services available through the Website and to enable You to use some of its features. They help to authenticate users and prevent fraudulent use of user accounts. Without these Cookies, the services that You have asked for cannot be provided, and We only use these Cookies to provide You with those services.
Cookies Policy / Notice Acceptance Cookies
Type: Persistent Cookies
Administered by: Us
Purpose: These Cookies identify if users have accepted the use of cookies on the Website.
Functionality Cookies
Type: Persistent Cookies
Administered by: Us
Purpose: These Cookies allow us to remember choices You make when You use the Website, such as remembering your login details or language preference. The purpose of these Cookies is to provide You with a more personal experience and to avoid You having to re-enter your preferences every time You use the Website.
Tracking and Performance Cookies
Type: Persistent Cookies
Administered by: Third-Parties
Purpose: These Cookies are used to track information about traffic to the Website and how users use the Website. The information gathered via these Cookies may directly or indirectly identify you as an individual visitor. This is because the information collected is typically linked to a pseudonymous identifier associated with the device you use to access the Website. We may also use these Cookies to test new pages, features or new functionality of the Website to see how our users react to them.

[For more information about the cookies we use and your choices regarding cookies, please visit our Cookies Policy].

8. Your rights

You have the following rights in relation to your personal data which we process, which you can exercise free of charge:

undefined	the right to be provided with a copy.
Rectification	the right to require us to correct any inaccuracies.
Erasure	the right to require us to delete it in certain situations.
Restriction	the right to require us to restrict processing of your personal data in certain situations, e.g. if you contest its accuracy.
To object	the right to object at any time to your personal data being processed for direct marketing and, in certain other situations, to our continued processing of it.
To withdraw consent	where we rely on your consent to process your personal data, you have a right to withdraw that consent at any although this will not affect the lawfulness of our prior processing.
To complain	to lodge a complaint with the UK Information Commissioner or the relevant authority in your jurisdiction if you are not in the UK.

9 Keeping your personal data secure

We have implemented appropriate technical and organisational measures to keep your personal data confidential and secure from unauthorised access, use and disclosure. We limit access to your personal data to those who have a genuine business need to access it. Those processing your personal data will do so only in an authorised manner and are subject to a duty of confidentiality.

We require our business partners, suppliers and other third parties to implement appropriate security measures to protect personal data from unauthorised access, use and disclosure.

We also have procedures to deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected data security breach where we are required to do so.

10 How to complain

Please contact us if you have any queries or concerns about our use of your personal data (see below ‘Contact us’). We hope we will be able to resolve any issues you may have.

11 Changes to this Privacy Policy

We may update Our Privacy Policy from time to time. We will notify You of any changes by posting the new Privacy Policy on this page.

We will let You know via email and/or a prominent notice on Our services, prior to the change becoming effective and update the "Last updated" date at the top of this Privacy Policy.

You are advised to review this Privacy Policy periodically for any changes. Changes to this Privacy Policy are effective when they are posted on this page.

12 Links to Other Websites

Our services may contain links to other websites that are not operated by Us. If You click on a third party link, You will be directed to that third party's site. We strongly advise You to review the Privacy Policy of every site You visit.

We have no control over and assume no responsibility for the content, privacy policies or practices of any third party sites or services.

13 Contact Us

If you have any questions about this Privacy Policy or the personal data we hold about you, to exercise a right under data protection law or to make a complaint, you can contact us by email at admin@therakind.com.