Welcome to the Salaso Health product privacy notice.
Salaso respects your privacy and is committed to protecting your personal data. This privacy notice will inform you as to how we look after your personal data when you visit our Salaso Health website (regardless of where you visit it from) and tell you about your privacy rights and how the law protects you.
This privacy notice is provided in a layered format so you can click through to the specific areas set out below. Please also use the Glossary to understand the meaning of some of the terms used in this privacy notice.
Table of Contents
1. IMPORTANT INFORMATION AND WHO WE ARE
PURPOSE OF THIS PRIVACY NOTICE
This privacy notice aims to give you information on how Salaso collects and processes your personal data through your use of this website, including any data you may provide through our Salaso Health platform (the “Service”) when you sign up to use it following a referral by a Health Care Provider (“HCP”) or if you are using the Service as a HCP.
It is important that you read this privacy notice together with any other privacy notice or fair processing notice we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy notice supplements the other notices and is not intended to override them.
If you are a patient, the HCP who referred you to use our Service is the data controller and responsible for your personal data provided by you when registering to use the Service and when you are using the Service. Salaso is the data processor in such circumstances. There may be limited instances where you contact us directly or where we ask you to complete surveys that we use for research purposes where Salaso may be the data controller. If you are a HCP then we are the data controller and responsible for your personal data provided by you when registering to use the Service but we will be a data processor of any patient data processed through the patients use of the Service.
We have an appointed Data Protection Officer who is responsible for overseeing questions in relation to this privacy notice. If you have any questions about this privacy notice, including any requests to exercise your legal rights, please contact our Data Protection Officer using the details set out below.
Our full details are:
Full name of legal entity: Salaso Health Solutions Limited
Postal address: Tom Crean Business Centre, Kerry Technology Park, Tralee, Co. Kerry, Ireland
Data Protection Officer (DPO)
Email address: firstname.lastname@example.org
You have the right to make a complaint at any time to the Data Protection Commissioner (DPC), the Irish supervisory authority for data protection issues (www.dataprotection.ie). We would, however, appreciate the chance to deal with your concerns before you approach the DPC, so please contact us in the first instance.
CHANGES TO THE PRIVACY NOTICE AND YOUR DUTY TO INFORM US OF CHANGES
This version was last updated on (date to be inserted once approved) and previous versions can be obtained by contacting us.
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.
This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy notice of every website you visit.
2. THE DATA WE COLLECT ABOUT YOU
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).
We may collect, use, store and transfer different kinds of personal data about you which we have grouped together follows:
Identity Data includes first name, maiden name, last name, username or similar identifier, marital status, title, date of birth and gender.
- Contact Data includes billing address, delivery address, email address and telephone numbers.
- Financial Data includes bank account and payment card details of HCPs.
- Transaction Data includes details about payments to and from you and other details of products and services you have purchased from us or services of ours that you have accessed. In some instances, transaction data may include personal data relating to your health that you provide during the course of your use of the Service or indeed may be added to the Service by the HCP in the course of prescribing you the exercises or activities.
- 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, purchases or orders made by you, your interests, preferences, feedback and survey responses.
- Usage Data includes information about how you use our website, products and services.
- Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.
We will inform you at the time of collecting other information from you whether you must provide the information to use the Service or whether the provision of information requested by us is optional. We will inform you at the time of collecting information from you whether the information that you provide to us will be accessible to other users of the Service or by third parties so that you can decide whether to provide the information to us.
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 notice.
We do not seek to 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) but these categories of data may be shared by you directly with your HCP while you use the Service or indeed may be added to the Service by the HCP in the course of prescribing you exercises or activities and therefore we are considered a data processor of such personal data. We do not record your telehealth calls with your HCP. Your HCP may prescribe certain activities or exercises for you (e.g. a stretch or exercise for a part of your body) which you can access via the Service and which may mean that certain health data is processed by us. In order to process personal data in relation to you, especially health data, we rely on the consent you provided to your HCP. When we process your personal data on the basis of your consent, you are free to withdraw that consent at any time. You can withdraw your consent by contacting us using the contact details at the bottom of this notice. Please note that if you withdraw your consent we may not be able to continue providing you with the Service. We do not collect any information about criminal convictions and offences.
IF YOU FAIL TO PROVIDE PERSONAL DATA
Where we need to collect personal data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with access to the Service). In this case, we may have to deny or limit your access to the Services but we will notify you if this is the case at the time.
3. HOW IS YOUR PERSONAL DATA COLLECTED?
We use different methods to collect data from and about you including through:
- Direct interactions. You may give us your Identity Data, Contact Data and Financial Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you may provide when you:
- create an account on our website;
- subscribe to our service or publications;
- interact with a HCP using the Service
- request marketing to be sent to you; and/or
- give us some feedback or complete a survey.
- Third parties or publicly available sources. We may receive personal data about you from various third parties as set out below:
- Technical Data from the following parties:
(a) analytics providers such as Google based outside the EU; and
(b) our sub processors listed in appendix 1 that may be based inside and outside the EU.
- Contact, Financial and Transaction Data from providers of technical, payment and delivery services such as Stripe based inside the EU.
4. HOW WE USE YOUR PERSONAL DATA
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:
- Where we need to perform the contract we are about to enter into or have entered into with you or on foot of a contract between us and the HCP.
- 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.
- Where we need to comply with a legal or regulatory obligation.
- Where you have provided consent to your HCP to the use of the Service.
Generally we do not rely on consent as a legal basis for processing your personal data other than in relation to the processing of special categories of personal data such as data relating to your health that you may volunteer to your HCP or that they may provide to you as part of their services.
PURPOSES FOR WHICH WE WILL USE YOUR PERSONAL DATA
We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.
Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please Contact us (hyperlink to email@example.com to be inserted) if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.
|Purpose/Activity||Type of data||Lawful basis for processing including basis of legitimate interest|
|To register you as a new customer|
|Performance of a contract with you and your HCP|
To process and deliver the Service for HCPs including:
(a) Manage payments, fees and charges
(b) Collect and recover money owed to us
(e) Marketing and Communications
(b) Necessary for our legitimate interests (to recover debts due to us if you are a HCP)
|Providing the Salaso Health Service including telehealth to enable the HCP to contact you, the patient and provide healthcare advice to you using the Service|
To manage our relationship with you which will include:
(b) Asking you to leave a review or take a survey
(d) Marketing and Communications
(a) Performance of a contract with you and your HCP
(b) Necessary to comply with a legal obligation
(c) Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services)
|To enable you to partake in a prize draw, competition or complete a survey|
(e) Marketing and Communications
(a) Performance of a contract with you and HCPs
(b) Necessary for our legitimate interests (to study how customers use our products/services, to develop them and grow our business)
|To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)|
(a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise)
(b) Necessary to comply with a legal obligation
|To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you|
(e) Marketing and Communications
|Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy)|
|To use data analytics to improve our website, products/services, marketing, customer relationships and experiences|
|Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy)|
|To make suggestions and recommendations to you about goods or services that may be of interest to you|
|Necessary for our legitimate interests (to develop our products/services and grow our business)|
CHANGE OF PURPOSE
We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please Contact us (hyperlink to firstname.lastname@example.org to be inserted).
If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
5. DISCLOSURES OF YOUR PERSONAL DATA
We may have to share your personal data with the parties set out below for the purposes set out in the table in paragraph 4 above.
- Internal Third Parties as set out in the Glossary.
- External Third Parties as set out in the Glossary.
- Specific third parties listed in the table in Appendix 1.
- Third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy notice.
We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.
6. INTERNATIONAL TRANSFERS
Some of our external third parties are based outside the European Economic Area (EEA) so their processing of your personal data may involve a transfer of data outside the EEA. The current location of processing relating to these third parties is set out in Appendix 1.
Whenever we transfer your personal data out of the EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:
- We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission.
- Where we use certain service providers, we may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe.
- We use localized servers where possible to store your personal data which minimises data transfers out of the EU.
Please Contact us (hyperlink to email@example.com to be inserted) if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.
7. DATA SECURITY
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. 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.
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.
8. DATA RETENTION
HOW LONG WILL YOU USE MY PERSONAL DATA FOR?
We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, contractual, accounting, or reporting requirements.
To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.
Details of retention periods for different aspects of your personal data are available in our retention policy which you can request from us by Contacting us. (hyperlink to firstname.lastname@example.org to be inserted).
In some circumstances you can ask us to delete your data: see Request erasure below for further information.
In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.
9. YOUR LEGAL RIGHTS
Under certain circumstances, you have rights under data protection laws in relation to your personal data. Please click on the links below to find out more about these rights:
- Request access to your personal data.
- Request correction of your personal data.
- Request erasure of your personal data.
- Object to processing of your personal data.
- Request restriction of processing your personal data.
- Request transfer of your personal data.
- Right to withdraw consent.
If you wish to exercise any of the rights set out above, please Contact us (hyperlink to email@example.com to be inserted).
NO FEE USUALLY REQUIRED
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.
WHAT WE MAY NEED FROM YOU
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
TIME LIMIT TO RESPOND
We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
Consent means a clear affirmative act establishing a freely given, specific, informed and unambiguous indication of your agreement to the processing of personal data, such as by a written statement but including by electronic means, or an oral statement. A HCP is required to seek your consent for the use of the Services.
Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by Contacting us (hyperlink to firstname.lastname@example.org to be inserted).
Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.
Comply with a legal or regulatory obligation means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.
INTERNAL THIRD PARTIES
Salaso Health Solutions (USA) Limited is a subsidiary
EXTERNAL THIRD PARTIES
- Service providers acting as processors] based in different parts of the world who provide IT, payment and system administration services as further detailed in appendix 1.
- Professional advisers acting as processors or joint controllers including lawyers, bankers, auditors and insurers based in Ireland who provide consultancy, banking, legal, insurance and accounting services.
- The Revenue Commissioners, regulators and other authorities acting as processors or joint controllers based in Ireland who require reporting of processing activities in certain circumstances.
YOUR LEGAL RIGHTS
You have the right to:
Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.
(Company name, location etc.)
(Type of service(s) provided by the sub-processor)
(Geographic location where
processing takes place)
Amazon Web Services (AWS)
Dublin region – eu-west-1
Infrastructure as a Service, storage and processing of content e.g. EC2 instances, S3 and RDS ,
Date of Birth
Any other data uploaded by the healthcare provider.
|CMS & video hosting platform for distribution of video content. Aggregated data is used for analytics .|
Unique IDs such as IP addresses,user IDs or Device Ids.
System information such as device, browser, and operating system type and version, screen resolution and preferred language.
Referring domain, destination domain and destination path
Video-viewing activity, such as player loads, number of views, viewed minutes, percent of content viewed, new Viewers, unique Viewers, attention span, top domains, geography, traffic sources, search terms and other similar information. This information is aggregated and de-identified (meaning it is not connected to an individual Viewer)
Other personal information of a natural person that may be included in videos or other data uploaded to Brightcove Services.
|EU and US|
|Twilio Ireland Limited||Sending of SMS reminders.||Data subjects telephone numbers.||Dublin,|
One Market Street,
San Francisco 94105
|Customer Support Portal for Enterprise Level Customer Organisations.|
Organisational details, contact details
WebRTC Platform software, hosted within Salaso AWS
account provided as a software library.
|Anonymised usage data is sent to frozen mountain servers.||Dublin – Hosted within Salaso’s AWS account.|
1440 St. Catherine Street West
|Questionnaire platform||Some logs may contain details about requests including IP addresses, browser information, these logs are automatically purged after a maximum of 30 days.||France|