Privacy Policy

Paragon Healthcare Solutions 

Privacy Policy

  1. Introduction 

This Privacy Policy (together with our terms and conditions and any other documents  referred to in it) describes the type of information that we collect from you  (“you/your”) through the use of our services (“Services”), or the use of our website  www.paragonhealthcareacademy.co.uk (“Website”), how that information may be  used or disclosed by us and the safeguards we use to protect it. 

Our Website and Services may contain links to third party websites that are not  covered by this Privacy Policy. We therefore ask you to review the privacy statements  of other websites and applications to understand their information practices. 

We have drafted this Privacy Policy to be as clear and concise as possible. Please read  it carefully to understand our policies regarding your information and how we will  treat it. By using or accessing our Website or the Services, you agree to the collection,  use and disclosure of information in accordance with this Privacy Policy. This Privacy  Policy may change from time to time and your continued use of the Website or the  Services is deemed to be acceptance of such changes, so please check periodically for  updates. 

Please check back regularly to keep informed of updates to this Privacy Policy. Please  read this Privacy Policy carefully and ensure that you understand it. Your acceptance of  our Privacy Policy is deemed to occur upon your first use of our Website. If you do not  accept and agree with this Privacy Policy, you must stop using our Website  immediately. 

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. 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. 

If you have any comments on this Privacy Policy, please email them to  info@paragonhealthcareacademy.co.uk 

  1. Who We Are 

2.1 Here are our details:

– Our Website address is www.paragonhealthcareacademy.co.uk 

– Our company name is Paragon Healthcare Solutions 

– Our trading name is Paragon Healthcare Academy and Paragon Healthcare  Services 

– Our registered address is Strand House, 102 Holywood Road, Belfast, BT4 1NU.  – Our trading address is Strand House, 102 Holywood Road, Belfast, BT4 1NU.  

2.2 We respect your right to privacy and will only process personal information about  you or provided by you in accordance with the Data Protection Legislation which for  the purposes of this Privacy Policy shall mean: (i) the retained EU law version of the  General Data Protection Regulation ((EU) 2016/679) (UK GDPR), (ii) the Data Protection  Act 2018 and any other national implementing laws, regulations and secondary  legislation, as amended or updated from time to time, in the UK and then (ii) any  successor legislation to the UK GDPR or the Data Protection Act 2018 and other  applicable privacy laws. 

  1. What we may collect 

3.1 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). 

3.2 We may collect, use, store and transfer different kinds of personal data about you  which we have grouped together as follows: 

  • Identity Data includes first name, last name, username or similar identifier.  When you email, phone, live chat or otherwise, we may collect information  such as your first name, last name, email address and phone number. 
  • Contact Data includes billing address, invoicing address, email address and  telephone numbers. 
  • Financial Data includes bank account and payment card details. Transaction Data includes details about payments and other details of our  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. 
  • Profile Data includes your username and password, reservations made by  you, your interests, preferences, feedback and survey responses. 
  • Usage Data includes information about how you use our Website and  Services.
  • Marketing and Communications Data includes your preferences in receiving  marketing from us and our third parties and your communication  

preferences. 

  • Interaction Data includes any information that you might provide to any  discussion forums on the Website. 
  • Cookies Data like many websites, we use “cookies” to enhance your  experience and gather information about visitors and visits to our websites.  Please refer to the “Do we use ‘cookies’?” section below for information  about cookies and how we use them and what kind. 
  • Third Parties and Information we receive from other sources. We may  receive information about you if you use any of the other websites we  operate or through the Services we provide. In this case we will have  informed you when we collected that data that it may be shared internally  and combined with data collected on our Website. We are also working  closely with third parties (including, for example, business partners,  suppliers, sub-contractors, advertising networks, analytics providers, and  search information providers) and may receive information about you from  them. 
  • Analytics includes third-party analytics services (such as Google Analytics) to  evaluate your use of the Website, compile reports on activity, collect  demographic data, analyse performance metrics, and collect and evaluate  other information relating to our Website and internet usage. These third  parties use cookies and other technologies to help analyse and provide us  the data. By accessing and using the Website, you consent to the processing  of data about you by these analytics providers in the manner and for the  purposes set out in this Privacy Policy. 

3.3 We 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 Policy. 

3.4 [We do not collect any Special Categories of Personal Data about you (this includes  details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual  orientation, political opinions, trade union membership, information about your health  and genetic and biometric data). Nor do we collect any information about criminal  convictions and offences. 

OR

Where we do collect Special Categories of Personal Data about you (this includes  details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual  orientation, political opinions, trade union membership, information about your health  and genetic and biometric data) and it is necessary to do so for our business, we will  obtain your specific consent, unless we have another lawful basis to do so.

3.5 Under UK GDPR we will ensure that your personal data is processed lawfully, fairly,  and transparently, without adversely affecting your rights. We will only process your  personal data if at least one of the following basis applies [Note only include the basis  that you are relying on]: 

  1. a) You have given consent to the processing of your personal data for one or  more specific purposes; 
  2. b) processing is necessary for the performance of a contract to which you are a  party or in order to take steps at the request of you prior to entering into a  contract; 
  3. c) processing is necessary for compliance with a legal obligation to which we  are subject; 
  4. d) processing is necessary to protect the vital interests of you or of another  natural person; 
  5. e) processing is necessary for the performance of a task carried out in the  public interest or in the exercise of official authority vested in the controller;  and/or 
  6. f) processing is necessary for the purposes of the legitimate interests pursued  by us or by a third party such as our financial payments, except where such  interests are overridden by the fundamental rights and freedoms of the data  subject, in particular where the data subject is a child. 

3.6 If you provide personal information to us about another data subject, you are  responsible for ensuring that you have their consent to provide that data for the uses  set out in this Privacy Policy and for bringing this Privacy Policy to their attention.  

  1. How we may collect and use your data 

4.1 We (or third party data processors, agents and sub-contractors acting on our  behalf) may collect, store and use your personal information by way of different  methods to collect data from and about you including through: 

Direct interactions. You may give us your information by filling in forms via our  Website or by corresponding with us by post, phone, email or otherwise. This includes  personal data you provide when you:

  1. a) present Website content; 
  2. b) use any of our Services; 
  3. c) create an account on our Website; 
  4. d) subscribe to our Services or publications; 
  5. e) request marketing to be sent to you; 
  6. f) enter a competition, promotion or survey; or 
  7. g) give us some feedback. 

4.2 In addition to the above, we may use the information in the following ways: 

  1. a) To personalise your Website experience and to allow us to deliver the type of  content and product offerings in which you are most interested. 
  2. b) To administer a contest, promotion, survey or other site feature. 
  3. c) If you have consented to receive our e-mail newsletter, we may send you  periodic e-mails. If you would no longer like to receive promotional e-mail from  us, please refer to the “How can you opt-out, remove or modify information  you have provided to us?” section below. If you have not opted-in to receive e mail newsletters, you will not receive these e-mails. Visitors who register or  participate in other site features such as marketing programs and ‘members only’ content will be given a choice whether they would like to be on our e-mail  list and receive e-mail communications from us. 
  4. d) Present Website content effectively to you. 
  5. e) Provide information, and services that you request, or (with your consent)  which we think may interest you. 
  6. f) Carry out our contracts with you. 
  7. g) Provide the relevant Services to you 
  8. h) Tell you our charges. 

4.3 If you are already our customer, we will only contact you electronically about  things similar to what was previously sold to you. 

4.4 If you are a new customer, you will only be contacted if you agree to it. 

4.5 We may keep a record of those links which are used the most to enable us to  provide the most helpful information but we agree to keep such information  confidential and you will not be identified from this information.

4.6 In addition, if you don’t want us to use your personal data for any of the other  reasons set out in this section in 4, you can let us know at any time by contacting us at [Email Address], and we will delete your data from our systems. However, you  acknowledge this will limit our ability to provide the best possible [products and] services to you. 

4.7 In some cases, the collection of personal data may be a statutory or contractual  requirement, and we will be limited in the [products and] services we can provide you  if you don’t provide your personal data in these cases. 

4.8 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: 

  1. a) Where we need to perform the contract we are about to enter into or have  entered into with you. 
  2. b) 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. 
  3. c) Where we need to comply with a legal or regulatory obligation, for example  compliance with health and safety, tax or other statutory obligations. 

4.9 Generally we do not rely on consent as a legal basis for processing your personal  data other than in relation to our marketing communications or 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 at [Email Address], and  we will either delete your data from our systems or move your data to our  “unsubscribe list”. However, you acknowledge this will limit our ability to provide the  best possible services to you. 

4.10 As already indicated above, with your permission and/or where permitted by law,  we may also use your data for marketing purposes which may lead to us contacting  you by email and/or telephone with information, news and offers on our Services. We  agree that we will not do anything that we have not agreed to under this Privacy  Policy, and we will not send you any unsolicited marketing or spam. We will take all  reasonable steps to ensure that we fully protect your rights and comply with our  obligations under the UK GDPR and the Privacy and Electronic Communications (EC  Directive) Regulations 2003, as amended. 

  1. Cookies 

5.1 All Cookies used by and on our website are used in accordance with current UK Cookie Law. 

5.2 We use cookies to distinguish users and improve our Website. Please look at our  Cookie Policy [Insert Link] for more cookie information.

  1. Where we store your data and security 

6.1 We may transfer your collected data to storage outside the UK. It may be  processed outside the UK to fulfil your order and to receive our Services and deal with  payment. If we do store or transfer data outside the UK, we will take all reasonable  steps to ensure that your data is treated as safely and securely as it would be within  the UK and under the UK GDPR. Such steps may include, but not be limited to, the use  of legally binding contractual terms between us and any third parties we engage with  and the use of approved Model Contractual Arrangements. Your acceptance of this  Privacy Policy shall be your consent permitting us to store or transfer data outside the  UK if it is necessary for us to do so. 

6.2 Data security is of great importance to us, and to protect your data we have put in  place suitable physical, electronic and managerial procedures to safeguard and secure  data collected through our Website. 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. 

6.3 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. 

6.4 By giving us your personal data, you agree to this arrangement. We will do what we  reasonably can to keep your data secure. 

6.5 Any payments made by you, will be encrypted. 

6.6 We have implemented security measures such as a firewall to protect any data and  maintain a high level of security. 

6.7 Notwithstanding the security measures that we take, it is important to remember  that the transmission of data via the internet may not be completely secure and that  you are advised to take suitable precautions when transmitting to us data via the  internet and you take the risk that any sending of that data turns out to be not secure  despite our efforts. 

6.8 If we give you a password upon registration on our Website, you must keep it  confidential. Please don’t share it. 

6.9 We will keep personal data for as long as is necessary which is usually the life of  our relationship and up to a period of seven years after our relationship have ended.  We may however be required to retain personal data for a longer period of time to  ensure we comply with our legislative and regulatory requirements. We review our  data retention obligations to ensure we are not retaining data for longer than we are  legally obliged to.

  1. Disclosing your information 

7.1 We are allowed to disclose your information in the following cases: 

7.1.1 If we want to sell our business, or our company, we can disclose it to the  potential buyer. 

7.1.2 We can disclose it to other businesses in our group. 

7.1.3 We can disclose it if we have a legal obligation to do so, or in order to  protect other people’s property, safety or rights. 

7.1.4 We can exchange information with others to protect against fraud or credit  risks. 

7.2 Where any of your data is required for such a purpose, we will take all reasonable  steps to ensure that your data will be handled safely, securely, and in accordance with  your rights, our obligations, and the obligations of the third party under UK GDPR and  the law. Any third party that we share data with will not be permitted to use it for any  other purpose than fulfilling their contract with us. 

  1. Your rights 

8.1 When you submit information via our Website, you may be given options to  restrict our use of your data. We aim to give you strong controls on our use of your  data (including the ability to opt-out of receiving emails from us which you may do by  unsubscribing using the links provided above in this Privacy Policy. 

8.2 Under the UK GDPR, you have the right to: 

  • request access to, deletion of or correction of, your personal data held by  us at no cost to you; 
  • request that your personal data be transferred to another person (data  portability); 
  • be informed of what data processing is taking place; 
  • restrict processing; 
  • to object to processing of your personal data; and 
  • complain to a supervisory authority. 

8.3 You also have rights with respect to automated decision-making and profiling as  set out in section 11 below. 

8.4 You have the right to ask us not to process your personal data for marketing  purposes. We will usually inform you (before collecting your data) if we intend to use 

your data for such purposes or if we intend to disclose your information to any third  party for such purposes. 

8.5 To enforce any of the foregoing rights or if you have any other questions about our  Website or this Privacy Policy, please contact us at  

info@paragonhealthcareacademy.co.uk 

  1. Links to other sites 

9.1 Please note that our terms and conditions and our policies will not apply to other  websites that you get to via a link from our Website. 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. 

  1. Changes 

10.1 If we change our Privacy Policy, we will post the changes on this page so please  check this page for our current policy.  

  1. Automated Decision-Making and Profiling 

11.1 In the event that we use personal data for the purposes of automated decision making and those decisions have a legal (or similarly significant effect) on you, you  have the right to challenge to such decisions under UK GDPR, requesting human  intervention, expressing their own point of view, and obtaining an explanation of the  decision from us. 

11.2 The right described in section 11.1 does not apply in the following circumstances: 

  1. a) the decision is necessary for the entry into, or performance of, a contract  between the you and us; 
  2. b) the decision is authorised by law; or 
  3. c) you have given you explicit consent. 

11.3 Where we use your personal data for profiling purposes, the following shall apply: 

  1. a) Clear information explaining the profiling will be provided, including its  significance and the likely consequences; 
  2. b) Appropriate mathematical or statistical procedures will be used;
  3. c) Technical and organisational measures necessary to minimise the risk of  errors and to enable such errors to be easily corrected shall be implemented;  and 
  4. d) All personal data processed for profiling purposes shall be secured in order  to prevent discriminatory effects arising out of profiling. 
  5. Terms and Conditions 

12.1 Please also visit our Terms and Conditions section at  

www,paragonhealthcareacademy.co.uk establishing the use, disclaimers, and  limitations of liability governing the use of our Website. 

  1. Your agreement 

13.1 By using our Website and by way of acknowledgment, you agree to our Privacy  Policy. 

  1. Dispute Resolution 

14.1 We will use our best efforts to negotiate in good faith and settle any dispute that  may arise out of or relate to this Privacy Policy or any breach of it. 

14.2 Any dispute shall not affect our ongoing obligations under this Privacy Policy. 

14.3 This Privacy Policy and any dispute or claim relating to or connected with it  (including non-contractual disputes or claims) shall be governed by and construed in  accordance with the laws of England and Wales and the courts of England and Wales  are the only place where disputes or claims relating to or connected with this Privacy  Policy (including non-contractual disputes or claims) may be decided.

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