Last modified: May 24, 2022
- Contact Details
By contacting our general customer services team at: email@example.com
- How We Collect Your Information
We collect your personal information when you interact with us or use our services, such as when you use our Sites to connect with professionals or if you are a professional with your clients. We also look at how visitors use our Sites, to help us improve our services and optimise customer experience.
We collect information:
- when you create an account with us or you change your account settings;
- when you connect with another user;
- when you give us your consent to contact you via email, phone, post, message, push notification, or via our chat function, to send you marketing campaigns, to invite you to participate in surveys about our services, or our partners’ services;
- when you contact us directly via email, phone, post, message or via our chat function; and
- when you browse and use our Sites (before and after you create an account with us).
We also collect information from third party sites, such as advertising and social media platforms and our fraud detection provider. If you link your Social Media or your third-party accounts to us, we will keep a record of your Social Media handle, and the other information that is made available to us according to your Social Media account settings. If your employer signs up for ClientPRO, we may receive your contact details from your employer to enable us to provide our services to you (please see the section 5 “ClientPRO for professionals” below for more details).
- Information We Collect From You
As part of our commitment to the privacy of our customers and visitors to our Sites more generally, we want to be clear about the sorts of information we will collect from you.
We collect the following personal information from you:
- contact information such as name, email address, mailing address, and phone number
- age or date of birth
- user name, account number, and password
- preferences information (the types of emails you would like to receive from us)
- information provided to the professional or client (such a health symptoms, health conditions and medications)
- debit and credit card information
- your device location
We also collect information about your usage of the Sites and information about you from any messages you post to the Sites or when you contact us or provide us with feedback, including via e-mail, letter, phone or chat function. If you contact us by phone, we record the call for training and service improvement purposes, and make notes in relation to your call. We collect technical information from your mobile device or computer, such as its operating system, the device and connection type and the IP address from which you are accessing our Sites.
Furthermore, we also access to your contact list information from the phone for the purpose of allowing users to send invites to download and use the app.
- Use Of Your Information
We will only process the data we collect about you if there is a reason for doing so, and if that reason is permitted under data protection law.
We use your information where we need to in order to provide you with the service you have requested or to enter into a contract. You do not have to provide this information to us, but we may be unable to provide our services to you without the following information:
- communicate your personal information
- communicate to you the personal information of others you are authorized to act on behalf of on the Website or the App
- send you requested service information
- respond to customer service requests
- administer your account
- send you newsletters, voice messages, text messages or email communications
- respond to your questions and concerns
- improve our website, app, and marketing efforts
- conduct internal quality improvement or business analysis
- customize your experience on the website and mobile app, including the display of location-based information that’s relevant to your care and how to find care
- de-identify the information in accordance with HIPAA and/or other applicable law
We also process your data where we have a legitimate interest for doing so – for example personalisation of our service, including processing data to make it easier and faster for you to synchronize orders. We have listed these reasons below:
- to improve the effectiveness and quality of service that our customers can expect from us in the future;
- to tailor content that we or our partners display to you, for example so that we can show you partners which are in your area or make sure you see the advertising which is most relevant to you, based on characteristics determined by us;
- to enable our customer support team to help you with any enquiries or complaints in the most efficient way possible and to provide a positive customer experience;
- to contact you for your views and feedback on our services or our partners’ services and/or products and to notify you if there are any important changes or developments to the Sites or our services, including letting you know that our services are operating in a new area, where you have asked us to do so;
- to send you information by post about our products, services and promotions (if you do not want to receive these, you can let us know by getting in touch (see section 1 “Contact Details”);
- to analyse your activity on the Sites so that we can administer, support, improve and develop our business and for statistical and analytical purposes and to help us to prevent fraud; and
- to detect, investigate, report and seek to prevent fraud or crime.
We also process your data to enforce our contractual terms with you and any other agreement, and for the exercise or defence of legal claims and to protect the rights of ClientPRO, our partners or others (including to prevent fraud).
If you submit comments and feedback regarding the Sites and the services, we may use such comments and feedback on the Sites and in any marketing or advertising materials. We will only identify you for this purpose by your first name and the city in which you live such comments and feedback may be shared with our partners to assess and improve their services.
We will also analyse data about your use of our services from your location data to create profiles relating to you and for you. This means that we may make certain assumptions about what you may be interested in and use this, for example, to send you more tailored marketing communications, to present you with partners that we think you will prefer, or to let you know about special offers or products which we think you may be interested in (including ClientPRO for professionals). This activity is referred to as profiling. You have certain rights in relation to this type of processing. Please see the section 11 “Your Rights” below for more information.
We may also use your information to comply with any legal obligation or regulatory requirement to which we are subject.
- ClientPRO For Professionals
We also process your information to determine whether you may be interested in hearing about our ClientPRO for professionals service and, if your employer signs up for ClientPRO as a professional, to make this service available to you.
If your employer signs up for ClientPRO for professionals, we will contact you to let you know that the ClientPRO for professionals service is available to you. For more information, please contact your employer.
When you use ClientPRO for professionals, we will process your information for the purposes set out in the Use of Your Information section above.
Where you have given your consent or where we have a legitimate interest for doing so (and are permitted to do so by law) we will use your information to let you know about our other products and services that may be of interest to you and we may contact you to do so by email, post, phone or push notification.
We use online advertising to keep you aware of what we’re up to and to help you see and find our services.
You may see our banners and ads when you are on other websites and apps, such as Social Media. We manage this through a variety of digital marketing networks. We also use a range of advertising technologies. The banners and ads you see are based on information we hold about you, or your previous use of ClientPRO or our banners or ads you have previously clicked on. We use your customer’s profile to send you communications that are the most relevant to you. You have certain rights in relation to this type of processing. Please see the section 11 “Your Rights” below for more information.
You can control your marketing preferences by visiting our website or mobile application.
Where you have chosen at a device level to begin or continue receiving push notifications from us, we may send you push notifications relating to the services that you have requested from us and information about our services and offers. You can choose to stop receiving push notifications from us at any time by changing your preferences on your mobile device.
We may still contact you through email where you have opted out of direct marketing with service communications, including, but not limited to, correspondence providing information about service interruption and delivery safety.
- Retention Of Your Information
We will not retain your information for any longer than we think is necessary.
Information that we collect will be retained for as long as needed to fulfil the purposes outlined in the Use of Your Information section above, in line with our legitimate interest or for a period specifically required by applicable regulations or laws, such as retaining the information for regulatory reporting purposes.
When determining the relevant retention periods, we will take into account factors including:
- our contractual obligations and rights in relation to the information involved;
- legal obligation(s) under applicable law to retain data for a certain period of time;
- statute of limitations under applicable law(s);
- our legitimate interests where we have carried out balancing tests (see the section 4 “Use of Your Information”);
- potential disputes; and
- guidelines issued by relevant data protection authorities.
Otherwise, we securely erase your information where we no longer require your information for the purposes collected.
- Disclosure Of Your Information
The information we collect about you will be transferred to and stored on our servers located within the USA. We are very careful and transparent about who else your information is shared with.
We share your information with other Emmati Inc group companies only where necessary for the purposes set out in the Use of Your Information section above. We share your information with third party service providers which provide services on our behalf. The types of third party service providers whom we share your information with include for example:
- Payment providers (including online payment providers and fraud detection providers);
- IT service providers (including cloud providers);
- Customer support partners (including, but not limited to, companies that assist us to provide customer or technical support); and
ClientPRO also shares your information when we promote a programme or offer a service or product in conjunction with a third-party business partner. We will share your information with that partner to assist in marketing or to provide the associated product or service. In most of those cases, the programme or offer will include the name of the third-party business partner, either alone or with ours. An example of such a business partner relationship would be a partner that we partner with for providing our services.
If you submit comments and feedback regarding the Sites, services, and our partners we may share such comments and feedback with our partners.
If our business enters into a joint venture with, purchases or is sold to or merged with another business entity, your information may be disclosed or transferred to the target company, our new business partners or owners or their advisors.
We may also share your information:
- if we are under a duty to disclose or share your information in order to comply with (and/or where we believe we are under a duty to comply with) any legal obligation or regulatory requirement. This includes exchanging information with other companies and other organisations for the purposes of fraud protection and prevention, and with law enforcement for crime prevention;
- in order to enforce our contractual terms with you and any other agreement;
- to protect the rights of ClientPRO, our partners or others, including to prevent fraud; and
- with such third parties as we reasonably consider necessary in order to prevent crime, e.g. the police or for health and safety purposes.
We adopt robust technologies and policies to ensure the personal information we hold about you is suitably protected.
We take steps to protect your information from unauthorised access and against unlawful processing, accidental loss, destruction and damage.
Where you have chosen a password that allows you to access certain parts of the Sites, you are responsible for keeping this password confidential. We advise you not to share your password with anyone.
Unfortunately, the transmission of information via the internet is not completely secure. Although we will take steps to protect your information, we cannot guarantee the security of your data transmitted to the Sites; 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.
- Your Rights
Subject to applicable law, you may have a number of rights concerning the data we hold about you. If you wish to exercise any of these rights, please contact us using the Contact Details set out above.
The right to be informed. You have the right to be provided with clear, transparent and easily understandable information about how we use your information and your rights. This is why we’re providing you with the information in this policy.
The right of access. You have the right to obtain access to your information (if we’re processing it). This will enable you, for example, to check that we’re using your information in accordance with data protection law. If you wish to access the information we hold about you in this way, please get in touch (see Contact Details).
The right to rectification. You are entitled to have your information corrected if it is inaccurate or incomplete. You can request that we rectify any errors in information that we hold by contacting us (see Contact Details).
The right to erasure. This is also known as ‘the right to be forgotten’ and, in simple terms, enables you to request the deletion or removal of certain of the information that we hold about you by contacting us (see Contact Details). This right is not absolute and only applies in certain circumstances.
The right to restrict processing. You have rights to ‘block’ or ‘suppress’ further use of your information in certain circumstances. When processing is restricted, we can still store your information, but will not use it further.
The right to data portability. You have the right to obtain your personal information in an accessible and transferrable format so that you can re-use it for your own purposes across different service providers. This is not an absolute right however and there are exceptions. To learn more please get in touch (see Contact Details).
The right to lodge a complaint. You have the right to lodge a complaint about the way we handle or process your information with a competent data protection authority (see Complaints).
The right to withdraw consent. If you have given your consent to anything we do with your information (i.e. if we rely on consent as a legal basis for processing certain information), you have the right to withdraw that consent at any time. You can do this by contacting us (see Contact Details). Withdrawing consent will not, however, make unlawful our use of your information before you withdraw consent.
The right to object to processing. You have the right to object to certain types of processing, including processing for direct marketing and profiling. You can object by changing your marketing preferences, disabling cookies as set out in the Cookies and Marketing sections above or by getting in touch (see Contact Details).