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Privacy policy

Last Updated: May 08, 2018

Curative Collective Limited (“Curative”, “we”, “us” or “our”) is committed to protecting and respecting your privacy. Please read this Privacy Policy (the Policy) carefully as it contains important information about how we will use and treat your personal data. By visiting www.curativecollective.com (“Our Site”) and/or our Curative Apps (“Our App(s)”) you are accepting and consenting to the practices described in this policy.

For the purpose of the Data Protection Directive 95/46/EC and Regulation (EU) 2016/679 (the Directive), the data controller is Curative Collective Limited at the registered address 55a Collingwood Close, Twickenham, Middlesex, TW2 7AE, correspondence address 1b Nottingham Court, London, WC2H 9AY.

Introduction

1. This is a notice to inform you of our policy about all information that we record about you. It sets out the conditions under which we may process any information that we collect from you, or that you provide to us. It covers information that could identify you (“personal information”) and information that could not. In the context of the law and this notice, “process” means collect, store, transfer, use or otherwise act on information.

2. We regret that if there are one or more points below with which you are not happy, your only recourse is to leave our website immediately.

3. We take seriously the protection of your privacy and confidentiality. We understand that all visitors to our website are entitled to know that their personal data will not be used for any purpose unintended by them and will not accidentally fall into the hands of a third party.

4. We undertake to preserve the confidentiality of all information you provide to us, and hope that you reciprocate.

5. Our policy complies with UK law accordingly implemented, including that required by the EU General Data Protection Regulation (GDPR).

6. The law requires us to tell you about your rights and our obligations to you in regards to the processing and control of your personal data. We do this now, by requesting that you read the information provided at knowyourprivacyrights.org

7. Except as set out below, we do not share, or sell, or disclose to a third party, any information collected through our website.

The bases on which we process information about you
The law requires us to determine under which of six defined bases we process different categories of your personal information, and to notify you of the basis for each category.
If a basis on which we process your personal information is no longer relevant then we shall immediately stop processing your data.
If the basis changes then if required by law we shall notify you of the change and of any new basis under which we have determined that we can continue to process your information.
Information we process because we have a contractual obligation with you
When you create an account on our website, buy a product or service from us, or otherwise agree to our terms and conditions, a contract is formed between you and us.
In order to carry out our obligations under that contract we must process the information you give us. Some of this information may be personal information.
We may collect and process the following data about you:
• Information you give us. You may give us information about you by filling in forms on Our Site, on our App(s), or by corresponding with us by phone, e-mail or otherwise. This includes information you provide when you register to use Our Site or App(s), subscribe to our service, search Our Site or App(s) for an Independent Therapist, use Our Booking Services, when you report a problem with Our Site or App(s) or contact us for any other reason. This may include your name, date of birth, gender, address of where the Massage Treatment will be provided, e-mail address, phone number and payment card information. It will also include any further information that you provide in relation to your booking, either to us or to your Independent Therapist (and this may include information about your health).

• Information we receive from other sources. Treatment Questionnaire – Prior to your Massage Treatment you will be asked to complete a Treatment Questionnaire in which you will be asked for details of any medical conditions. We will store these on behalf of the Independent Therapists.

• Therapists’ Notes – The Independent Therapists may make notes during the Massage Treatment. These notes will record information that you give the Independent Therapist and the Independent Therapist’s observations, e.g. whether there are any pets at the premises and whether you experienced any discomfort during the Massage Treatment. If any of this information include details of your physical or mental health you will be asked for your explicit consent. We will store these notes and may make them available to other Independent Therapists that you choose to book through our Booking Service.

We may use it in order to:
• verify your identity for security purposes
• sell products to you
• provide you with our services
• provide you with suggestions and advice on products, services and how to obtain the most from using our website
• To remind you of your appointments by email, phone, SMS
• We will share your information with the Independent Therapists to enable them to provide the Massage Treatments effectively and to effectively manage customer relations.

We process this information on the basis there is a contract between us, or that you have requested we use the information before we enter into a legal contract.
We act as agents of the Independent Therapists in providing our Booking Services and in storing any Treatment Questionnaire. By agreeing to the Privacy Policy you agree that we may pass information you provide us on to the Therapist.
Additionally, we may aggregate this information in a general way and use it to provide class information, for example to monitor our performance with respect to a particular service we provide. If we use it for this purpose, you as an individual will not be personally identifiable.
We shall continue to process this information until the contract between us ends or is terminated by either party under the terms of the contract.
Information we process with your consent
Through certain actions when otherwise there is no contractual relationship between us, such as when you browse our website or ask us to provide you more information about our business, including our products and services, you provide your consent to us to process information that may be personal information.
Wherever possible, we aim to obtain your explicit consent to process this information, for example, by asking you to agree to our use of cookies.
Sometimes you might give your consent implicitly, such as when you send us a message by e-mail to which you would reasonably expect us to reply.
Except where you have consented to our use of your information for a specific purpose, we do not use your information in any way that would identify you personally. We may aggregate it in a general way and use it to provide class information, for example to monitor the performance of a particular page on our website.
If you have given us explicit permission to do so, we may from time to time pass your name and contact information to selected associates whom we consider may provide services or products you would find useful.
We continue to process your information on this basis until you withdraw your consent or it can be reasonably assumed that your consent no longer exists.
You may withdraw your consent at any time by access your Curative account and amending your marketing preference or emailing theoffice@curativecollective.com; However, if you do so, you may not be able to use our website or our services further.
Information we process because we have a legal obligation
We are subject to the law like everyone else. Sometimes, we must process your information in order to comply with a statutory obligation.
For example, we may be required to give information to legal authorities if they so request or if they have the proper authorisation such as a search warrant or court order.
This may include your personal information.
Specific uses of information you provide to us
Information provided on the understanding that it will be shared with a third party
Our website allows you to post information with a view to that information being read, copied, downloaded, or used by other people or Therapists.
Examples include:
• reviews of therapists

In posting personal information, it is up to you to satisfy yourself about the privacy level of every person who might use it.
We do store it, and we reserve a right to use it in the future in any way we decide.
Once your information enters the public domain, we have no control over what any individual third party may do with it. We accept no responsibility for their actions at any time.
Provided your request is reasonable and there is no legal basis for us to retain it, then at our discretion we may agree to your request to delete personal information that you have posted. You can make a request by contacting us at theoffice@curativecollective.com.
We will request on your behalf and at your agreement should you wish us to, that the Therapist who has provided you with massage services also deletes all information they hold about you. However, we can not be held responsible for the information they hold about you and that it is deleted. We act only as a booking agent.
Complaints regarding content on our website
If you complain about any of the content on our website, we shall investigate your complaint.
If we feel it is justified or if we believe the law requires us to do so, we shall remove the content while we investigate.
Free speech is a fundamental right, so we have to make a judgment as to whose right will be obstructed: yours, or that of the person who posted the content that offends you.
If we think your complaint is vexatious or without any basis, we shall not correspond with you about it.
Information relating to your method of payment
At the point of payment, you are transferred to a secure page on the website. No payment details are kept on our website or servers. All payment data is fully secure and safe and processed through stripe who is fully PCI compliant.
Sending a message to our support team
When you contact us by e-mail we collect the data you have given to us in order to reply with the information you need.
We record your request and our reply in order to increase the efficiency of our business
We keep personally identifiable information associated with your message, such as your name so as to be able to track our communications with you to provide a high quality service.
Use of information we collect through automated systems when you visit our website
Cookies
Cookies are small text files that are placed on your computer’s hard drive by your web browser when you visit any website. They allow information gathered on one web page to be stored until it is needed for use on another, allowing a website to provide you with a personalised experience and the website owner with statistics about how you use the website so that it can be improved.
Some cookies may last for a defined period of time, such as one day or until you close your browser. Others last indefinitely.
Your web browser should allow you to delete any you choose. It also should allow you to prevent or limit their use.
Our website uses cookies. They are placed by software that operates on our servers, and by software operated by third parties whose services we use.
If you choose not to use cookies or you prevent their use through your browser settings, you will not be able to use all the functionality of our website.
We use cookies in the following ways:
• to keep you signed in our site
• to track how you use our website
• to record whether you have seen specific messages we display on our website

Personal identifiers from your browsing activity

Requests by your web browser to our servers for web pages and other content on our website are recorded.
We record information such as your geographical location, your Internet service provider and your IP address. We also record information about the software you are using to browse our website, such as the type of computer or device and the screen resolution. We may also collect information about your device. This may include information on the type of mobile device that you are using and its unique device identifier (for example, the IMEI number, the device’s mobile phone number, the MAC address of the device’s wireless network interface or push ID), the mobile operating system that you are using and mobile network information.
We use this information in aggregate to assess the popularity of the webpages on our website and how we perform in providing content to you.
If combined with other information we know about you from previous visits, the data possibly could be used to identify you personally, even if you are not signed in to our website.
Our use of re-marketing
Re-marketing involves placing a cookie on your computer when you browse our website in order to be able to serve to you an advert for our products or services when you visit some other website.
We may use a third party to provide us with re-marketing services from time to time. If so, then if you have consented to our use of cookies, you may see advertisements for our products and services on other websites.
Disclosure and sharing of your information
Information we may provide to third parties
We may disclose your personal information to third parties:
• In the event that we sell or buy any business or assets, in which case we may disclose your personal data to the prospective seller or buyer of such business or assets.
• If Curative or substantially all of its assets are acquired by a third party, in which case personal data held by it about its customers will be one of the transferred assets.
• If we are under a duty to disclose or share your personal data in order to comply with any legal obligation.
• To enforce or apply our terms of use (available at www.curativecollective.com/Ts&Cs and other agreements.
• To protect the rights, property, or safety of Curative, the Independent Therapists or others.
• To law enforcement agencies and regulators in connection with their investigations.
• This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction.

Information we obtain from third parties
Although we do not disclose your personal information to any third party (except as set out in this notice), we sometimes receive data that is indirectly made up from your personal information from third parties whose services we use.
No such information is personally identifiable to you.
Third party advertising on our website
Third parties may advertise on our website. In doing so, those parties, their agents or other companies working for them may use technology that automatically collects information about you when their advertisement is displayed on our website.
They may also use other technology such as cookies or JavaScript to personalise the content of, and to measure the performance of their adverts.
We do not have control over these technologies or the data that these parties obtain. Accordingly, this privacy notice does not cover the information practices of these third parties.
Credit reference
To assist in combating fraud, we may share information with credit reference agencies, so far as it relates to clients or customers who instruct their credit card issuer to cancel payment to us without having first provided an acceptable reason to us and given us the opportunity to refund their money.
Data may be processed outside the European Union
Our website is hosted in the United Kingdom
We may also use outsourced services in countries outside the European Union from time to time in other aspects of our business.
Accordingly data obtained within the UK or any other country could be processed outside the European Union.
Access to your own information
Access to your personal information
• At any time you may review or update personally identifiable information that we hold about you, by signing in to your account on our website.
• To obtain a copy of any information that is not provided on our website you may send us a request at theoffice@curativecollective.com.
• After receiving the request, we will tell you when we expect to provide you with the information, and whether we require any fee for providing it to you.

Removal of your information

If you wish us to remove personally identifiable information from our website, you may contact us at theoffice@curativecollective.com.
This may limit the service we can provide to you.
Verification of your information
When we receive any request to access, edit or delete personal identifiable information we shall first take reasonable steps to verify your identity before granting you access or otherwise taking any action. This is important to safeguard your information.
Other matters
Use of site by children
• We do not sell products or provide services for purchase by children, nor do we market to children.
• If you are under 18, you may use our website only with consent from a parent or guardian

Encryption of data sent between us

We use Secure Sockets Layer (SSL) certificates to verify our identity to your browser and to encrypt any data you give us.
Whenever information is transferred between us, you can check that it is done so using SSL by looking for a closed padlock symbol or other trust mark in your browser’s URL bar or toolbar.
We use appropriate technical and organisational safeguards to protect your data. However you should be aware that the transmission of information via the internet is not completely secure. Any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access.
How you can complain
• If you are not happy with our privacy policy or if have any complaint then you should tell us by email. Our address is theoffice@curativecollective.com.
• If a dispute is not settled then we hope you will agree to attempt to resolve it by engaging in good faith with us in a process of mediation or arbitration.
• If you are in any way dissatisfied about how we process your personal information, you have a right to lodge a complaint with the Information Commissioner’s Office. This can be done at https://ico.org.uk/concerns/

Retention period for personal data
Except as otherwise mentioned in this privacy notice, we keep your personal information only for as long as required by us:
• to provide you with the services you have requested;
• to comply with other law, including for the period demanded by our tax authorities;
• to support a claim or defence in court.

Compliance with the law

Our privacy policy has been compiled so as to comply with the law of every country or legal jurisdiction in which we aim to do business. If you think it fails to satisfy the law of your jurisdiction, we should like to hear from you.
However, ultimately it is your choice as to whether you wish to use our website.
Links To Other Websites
If you follow any links to any websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies. Please check these policies before you submit any personal data to these websites.

Review of this privacy policy
We may update this privacy notice from time to time as necessary. The terms that apply to you are those posted here on our website on the day you use our website. We advise you to print a copy for your records.
If you have any question regarding our privacy policy, please contact us.
Contact
Questions, comments and requests regarding this privacy policy are welcomed and should be addressed to theoffice@curativecollective.com, or Curative Collective Limited, 1b Nottingham Court, London, WC2H 9AY.
For Independent Therapists And Therapists Wishing To Join The Online Platform
Over and above what we say to Customers and visitors about privacy (as set out above) we will use, process and disclose your personal data in accordance with the DPA.
Your personal data will include:
• your facial image/photo
• name
• address and contact details
• location, using GPS technology
• bank details
• details of your training, qualifications and experience
• results of all checks undertaken, including identity checks, background checks, document image checks and criminal record cheques
• insurance details
• eligibility to work in the UK
• car ownership
• language skills
• feedback on your services or details of any complaints of clients
• any other personal data that we may collect from you or otherwise receive from third parties
• details of criminal convictions

Should you become one of our Independent Therapists you will be required to notify us promptly of any changes to your personal data.
Our Uses and Disclosures of the Personal Data may include:
• Responding to any queries you may have
• Contacting you in respect of your registration to join the online platform
• Inviting you to our on-boarding day (where you will be asked to demonstrate your skills)
• Undertaking identity, background, document image and criminal records checks
• Introducing you (with the use of your image) via our website(s) or Our App(s), or offline to members of the public who are seeking therapeutic massage services from professional self-employed massage therapists
• Managing our relationship with you, including the making of payments
• Complying with and enforcing any agreement between you and us
• Analysis and research
• Assisting you to make the most of our services
• Dealing with any complaints or investigations
• Complying with statutory and other legal requirements
• Processing in our legitimate interests otherwise as reasonably notified to you
• Marketing
• Assisting you to benefit from the service
• Disclosure so far as is reasonably necessary externally for the above purposes
• Disclosures for the purposes of undertaking identity, background, document image and criminal records checks
• We may monitor your use of our technology, systems and Customer personal data for the purposes of record keeping, to establish facts, to establish compliance with regulatory and self-regulatory procedures, to prevent, detect or investigate: crime; wrongdoing; the unauthorised use of our proprietary technology and/or Customer personal data; non-compliance with any agreement between us and you or any of our practices and procedures

We may transfer your personal data outside the European Economic Area in order to carry on our business.

Independent Therapists will comply with the DPA, our privacy policy and other policies and procedures notified to them by us from time to time.

In respect of any Customer personal data, including data collected whilst making notes of the Massage Treatments or accessed whilst viewing such notes through our technology Independent Therapists will:

• use such personal data only in so far as is necessary for the purpose of carrying out Massage Treatments on Customers and for no other purpose (including, without limitation, their own marketing purposes)
• not disclose such personal data unless specifically authorised by us to do so
• comply promptly with our instructions in respect of such personal data
• not disclose such personal data to any third party other than on our written instructions or as required by law
• not allow such personal data to be transferred out of the European Economic Area
• promptly assist us with requests in respect of such personal data
• when making notes during the Massage Treatments, ensure that any such personal data included therein is accurately recorded and promptly amended if inaccurate
• immediately forward to us any communications from Customers, regulatory bodies and other third parties concerning such personal data and not respond to or act on such communications without our prior agreement
• on request provide to us such personal data in the format reasonably specified
• not retain any (or any copies of Customer personal data) on completion of the Massage Treatment other than for the purpose of submission of notes to us. After such submission, the Independent Therapist shall securely destroy such notes
• will keep, transport and dispose of any Customer personal data securely to prevent unauthorised disclosure, access, loss, destruction or damage to such personal data.

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