Privacy Policy

If you do not agree with the terms and conditions described herein, you should not use our Website or services.

This is the privacy policy for www.irisspeaks.com (Website). The Website is operated by Iris Speaks Limited (“we”, “us” and “our”). For the purposes of the Data Protection Act 1998, we are the data controller.

We are committed to protecting your privacy online. We appreciate that you do not want the personal information you provide to us distributed indiscriminately and here we explain the basis on which any personal information we collect from you, or that you provide to us, will be processed by us and what controls you have.

Please read the following carefully to understand our practices regarding your personal information and how it will be treated. By using the Website, you consent to the collection and use of your personal information in accordance with this privacy policy.

We reserve the right to change this privacy policy from time to time by changing it on the Website and providing you with notification that we have done so. This privacy policy was last updated on 1st August 2017.General

1. INFORMATION WE MAY COLLECT ABOUT YOU

Submitted Information:

1.1 We may collect and process the following information about you:

(a) information (such as your name, email address, postal address and telephone number, other contact details and biographical information such as your date of birth) that you provide by completing forms on the Website, including if you register as a user of the Website, subscribe to any service, upload or submit any material via the Website, or request any information via the Website;

(b) information submitted in connection with an account sign-in facility, such as your password and log-in details;

(c) details of any transactions made by you through the Website;

(d) anonymous stored sessions data and relevant notes and Iris Speaks Therapists feedback;

(e) communications you send to us, for example to report a problem or to submit queries, concerns or comments regarding the Website or its content;

(f) information from surveys that we may, from time to time, run on the Website for research purposes, if you choose to respond to them;

(g) details of your visits to the Website, the resources you access and any data you download;

(h) information about you and your speech and language history and other medical information which you might discuss with a Therapist as part of your use of the services made available through the Website.

You are under no obligation to provide any such information. However, if you should choose to withhold requested information, we may not be able to provide you with certain services.

Additional Information:

1.2 When you visit the Website, we may automatically collect additional information about you, such as the type of internet browser you use, the Website from which you have come to the Website and your IP address (the unique address which identifies your computer on the internet) which is automatically recognised by our web server. You cannot be identified from this information and it is only used to assist us in providing an effective service on the Website and to collect broad demographic information for aggregate use. Iris Speaks monitors the use of its Website for statistical purposes only and to improve the services provided to users.

2. USES MADE OF YOUR INFORMATION

2.1 We will use the information you provide to:

(a) enable us to provide you with the services and information offered through the Website and those which you request;

(b) share it with relevant internal staff/team members and to aid in the future development of relevant services in the healthcare field;

(c) administer your account with us;

(d) verify and carry out financial transactions in relation to payments you make online;

(e) audit the downloading of data from the Website;

(f) get a better understanding of how people use the Website;

(g) improve the layout and/or content of the pages of the Website and customise them for users;

(h) identify visitors to the Website;

(i) carry out research on our users’ demographics; and

(j) send you information we think you may find useful or which you have requested from us, including marketing information about our products and services or those of carefully selected third parties.

2.2 If you do not want us to use your information for marketing purposes, we will give you the opportunity to opt-out of receiving any such marketing communications at the point where you provide us with your contact details and in each subsequent marketing communication that we send to you.

2.3 Please note that if you opt out from receiving marketing communications, we may still contact you about service-related issues, such as where we make any changes to the website, any associated terms and conditions or this policy.

Security and Fraud Prevention:

2.4 We may also use your personal information to ensure the security of your use of the   Website, your user account and our business, as well as for the purposes of preventing or detecting fraud or abuses of our services.

3 PURPOSES OF PROCESSING YOUR PERSONAL INFORMATION

3.1 We process your personal information in order to operate, maintain and provide you with the Services (including any additional services you may have requested), as well as to provide customer service and support. We will always indicate where the provision of certain information is voluntary and you will be able to withdraw your consent or exercise your rights in relation to this information at any time as described under this privacy policy.

3.2 This means that the legal basis for us processing your personal information as described above will typically be one of the following:

(a) because it is necessary to fulfil a contract that we have in place with you;

(b) for our or our third parties’ legitimate business interests;

(c) your consent; or

(d) where the processing is necessary for compliance with our legal obligations.

3.3 We will only process personal information which is considered sensitive where we have obtained your explicit consent for the purposes of providing our services to you. Examples of sensitive personal information include information relating to your medical history, genetic data, and ethnic origin, religious or philosophical beliefs, sex life, sexual orientation or criminal convictions.

4 COOKIES AND SIMILAR TECHNOLOGIES

4.1 The Website also uses cookies or similar technology to collect information about your access to the Website.

4.2 Cookies are pieces of information that include a unique reference code that a website transfers to your device to store and sometimes track information about you. A number of cookies we use last only for the duration of your web session and expire when you close your browser. Other cookies are used to remember you when you return to the Website and will last for longer.

4.3 All cookies used on our Website are set by us.

4.4 Most computer and some mobile web browsers automatically accept cookies but, if you prefer, you can change your browser to prevent that or to notify you each time a cookie is sent. You can also learn more about cookies by visiting www.allaboutcookies.org which includes additional useful information on cookies and how to block cookies using different types of browser. Please note however, that by blocking or deleting cookies you may not be able to take full advantage of the Website.

4.5 Our cookies will be used for:

Essential session management:

(a) creating a specific log-in session for a visitor to the Website in order that the Website remembers that a visitor is logged in and that their page requests are delivered in an effective, secure and consistent manner;

(b) recognising when a visitor to the Website has visited before allowing us to identify the number of unique visitors we receive to the Website and make sure we have enough capacity for the number of users that we get;

(c) recognising when a visitor to the Website is a registered member; and

(d) we may also log information from your computer including the existence of cookies, your IP address and information about your browser program in order to allow us to diagnose problems and administer and track your usage of our services.

Functionality:

(e) allowing you to navigate the Website more quickly and easily; and

(f) customising elements of the promotional layout and/or content of the pages of the Website for example by storing preferences and country codes and providing users with content relevant to those preferences and their country.

Performance and measurement:

(g) collecting statistical information about how our visitors use the Website so that we can improve the Website and learn which parts are most popular to visitors.

Targeting:

(h) delivering adverts more relevant to you and your interests;

(i) limiting the number of times you see an advertisement as well as help measure the effectiveness of the advertising campaigns; and collecting information about your browsing habits in order to make advertising relevant to you and your interests.

5 INFORMATION SHARING

5.1 We may disclose aggregate statistics about visitors to the Website, users and sales in order to describe our services to prospective partners, investors, advertisers, sponsors, potential buyers and other reputable third parties and for other lawful purposes, but these statistics will include no personally identifiable information.

5.2 In the event that we undergo re-organisation or we or any of our assets are sold to a1.1 third party, you agree that any personal information we hold about you may be transferred to that re-organised entity or third party.

5.3 We may disclose your personal information: (a) if required to do so by law; or (b) if we believe that such action is necessary to prevent fraud or cyber-crime; or (c) to enforce any part of the Terms and other agreements; or (d) to investigate potential breaches; or (e) to protect the Website or the rights, property or personal safety of any person.

6 CONFIDENTIALITY AND CLIENT DATA

6.1 All information collected and supplied to Iris Speaks will be treated as confidential.

6.2 All records are retained in a secure area and are confidentially stored in accordance with the NHS code of practice on records management, which may from time-to-time change, a copy of which can be found here.

6.3 Iris Speaks maintains records of the notes made by therapists during their sessions as well as video recordings of the consultation for clinical governance purposes, in accordance with data processing requirements. These records and any personally identifiable information you give to us will be treated as strictly confidential and will not be disclosed without your express permission except under special circumstances, for example in complying with a legal obligation.

7 EXTERNAL LINKS

7.1 The Website may, from time to time, contain links to external third party-owned websites. We are not responsible for the privacy policies or the content of such websites. Your use of these sites will be governed by the third party’s terms and conditions and privacy policies (if any). It is your responsibility to read and comply with these third party terms and policies.

8 PAYMENT PROCESSING

8.1 Payments made on the Website are made through our payment solutions provider Stripe at www.stripe.com, 3180 18th Street, Suite 100, San Francisco, CA 94110, USA. You will be providing credit or debit card information directly to Stripe which operates a secure server to process payment details, encrypting your credit/debit card information and authorising payment. Information which you supply to Stripe is not within our control and is subject to Stripe’s own privacy policy and terms and conditions available at https://stripe.com/gb/terms.

9 SECURITY AND PASSWORDS

9.1 We place great importance on the security of all personally identifiable information associated with our users. We have security measures in place to attempt to protect against the loss, misuse and alteration of personal information under our control. For example, our security and privacy policies are periodically reviewed and enhanced as necessary and only authorised personnel have access to personal information. Whilst we cannot ensure or guarantee that loss, misuse or alteration of information will never occur, we use all reasonable efforts to prevent it. We cannot guarantee the security of information you submit via the Website whilst it is in transit over the internet and any such submission is at your own risk.

9.2 Iris Speaks runs in a HTTPS secure mode (similar to online banking platform) and encrypts all video and text information shared during your consultation. There are clear procedures in place to ensure paper and computer systems and databases are protected against unauthorised disclosure, use, loss and damage. Nevertheless, electronic transmissions are never completely private or secure and there is a risk, therefore, that any electronic communications sent may be intercepted and potentially read by others. You should, therefore, ensure that any computer or telephone you use to access your online patient record is suitably protected from potential interception.

9.3 It is advisable to close your browser when you have finished your user session to help ensure others do not access your personal information if you use a shared computer or a computer in a public place.

9.4 You must keep your password and any other authentication information confidential. You must not disclose it to anyone else. If you know or suspect that anyone other than you knows your password or any other authentication information, you must promptly notify us using the contact details below.

10 STORAGE OF INFORMATION

10.1 Information that you submit via the Website is sent to and stored on secure servers located in the United Kingdom. This is necessary in order to process the information.

10.2 We take steps to ensure that the personal information that you provide is retained for only as long as it is necessary for the purpose for which it was collected. We apply criteria to determine the appropriate retention period for different categories of personal information you provide us with. For example, we will keep information necessary to protect us in a legal claim, such as information relating to a contract, for the lifetime of the contract and up to seven years after. After this period it will be deleted or in some cases anonymised. Where we have collected the personal information based on your consent and we have no other lawful basis to continue with that processing, if you subsequently withdraw your consent then we will delete your personal information.

10.3 The  information that we collect may be transferred to, and stored at, a destination outside the European Economic Area (the “EEA”) in countries, which have less strict, or no data protection laws, when compared to those in Europe. It may also be processed by staff operating outside the EEA who work for us or for one of our suppliers, for example in the provision of support services. By submitting your personal information, you consent to this transfer, storing or processing of your personal information.

10.4 Whenever we transfer your information outside of the EEA, we will take all steps reasonably necessary to ensure that adequate safeguards are in place to protect your personal information and to make sure your information is treated securely and in accordance with this privacy policy. If you are located in the EEA, you may contact us for a copy of the safeguards which we have put in place to protect your personal information and privacy rights in these circumstances.

11 YOUR RIGHTS

11.1 Data Protection Legislation in the European Union and the UK gives you certain rights in relation to your personal information. These include: the right to object to and / or withdraw consent to the processing of your personal information, the right to access to your personal information, and the ability to erase, restrict or receive a machine-readable copy of your personal information.

11.2 We will handle any request to exercise your rights in accordance with applicable law. If you wish to exercise any of these rights please refer to the “Contacting Us” section of this Privacy Policy.

12 CONTACTING US

12.1 Please submit any questions, concerns or comments you have about this privacy policy or any requests concerning your personal data by email to zoe@ec2-52-56-137-185.eu-west-2.compute.amazonaws.com or by telephone on 0800 011 9535 between the hours of 9am to 5pm, Monday to Friday or write to us at:

Iris Speaks

707 The Crescent

2 Seager Place

London

SE8 4HQ