Privacy Policy

Soma By Lila customer privacy notice

This privacy notice tells you what to expect us to do with your personal information.

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Contact details

info@somabylila.com

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What information we collect, use, and why

We collect or use the following information to provide patient care, services, pharmaceutical products and other goods:

• Name, address and contact details

• Date of birth

• Health information (including medical conditions, allergies, medical requirements and medical history)

• Information about care needs (including disabilities, home conditions, medication and dietary requirements and general care provisions)

• Test results (including psychological evaluations, scans, bloods, x-rays, tissue tests and genetic tests)

• Dietary history, food records, glucose monitoring records, consultation notes and treatment plans

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We also collect the following special category information to provide patient care, services, pharmaceutical products and other goods. This information is subject to additional protection due to its sensitive nature:

• Health information

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We collect or use the following personal information to comply with legal requirements:

• Name

• Contact information

• Financial information

• Safeguarding information

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We collect or use the following personal information for dealing with queries, complaints or claims:

• Names and contact details

• Payment details

• Purchase or service history

• Financial transaction information

• Correspondence

• Relevant clinical and health information, consultation notes and dietetic records, where necessary to investigate or respond to a complaint or claim.

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We also collect the following special category information for dealing with queries, complaints or claims. This information is subject to additional protection due to its sensitive nature:

• Health information

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Lawful bases and data protection rights

Under UK data protection law, we must have a “lawful basis” for collecting and using your personal information. There is a list of possible lawful bases in the UK GDPR. You can find out more about lawful bases on the ICO’s website.

Which lawful basis we rely on may affect your data protection rights which are set out in brief below. You can find out more about your data protection rights and the exemptions which may apply on the ICO’s website:

• Your right of access - You have the right to ask us for copies of your personal information. You can request other information such as details about where we get personal information from and who we share personal information with. There are some exemptions which means you may not receive all the information you ask for. Read more about the right of access.

• Your right to rectification - You have the right to ask us to correct or delete personal information you think is inaccurate or incomplete. Read more about the right to rectification.

• Your right to erasure - You have the right to ask us to delete your personal information. Read more about the right to erasure.

• Your right to restriction of processing - You have the right to ask us to limit how we can use your personal information. Read more about the right to restriction of processing.

• Your right to object to processing - You have the right to object to the processing of your personal data. Read more about the right to object to processing.

• Your right to data portability - You have the right to ask that we transfer the personal information you gave us to another organisation, or to you. Read more about the right to data portability.

• Your right to withdraw consent - When we use consent as our lawful basis you have the right to withdraw your consent at any time. Read more about the right to withdraw consent.

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If you make a request, we must respond to you without undue delay and in any event within one month. To make a data protection rights request, please contact us using the contact details at the top of this privacy notice.

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Our Lawful bases for collection and use of your data 

• To provide patient care, services, pharmaceutical products and other goods: Contract – we have to collect or use the information so we can enter into or carry out a contract with you. All of your data protection rights may apply except the right to object.

• To comply with legal requirements: Legal obligation – we have to collect or use your information so we can comply with the law. All of your data protection rights may apply, except the right to erasure, the right to object and the right to data portability.

• For dealing with queries, complaints or claims: Legitimate interests – we’re collecting or using your information because it benefits you, our organisation or someone else, without causing an undue risk of harm to anyone. All of your data protection rights may apply, except the right to portability. Our legitimate interests are: To manage and respond to enquiries and complaints, investigate concerns, resolve disputes, and establish, exercise or defend legal claims relating to our services.

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For more information on our use of legitimate interests as a lawful basis you can contact us using the contact details set out above.

Where we get personal information from

• Directly from you

• Family members or carers

• Other health and care providers

• Referring consultants and private clinics.

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How long we keep information

We keep personal information only for as long as necessary for the purposes for which it was collected and to meet our legal, professional and regulatory obligations.

Adult clinical and dietetic records are generally retained for at least 8 years after the last contact or treatment.

Clinical and dietetic records relating to children are retained until at least the child’s 21st birthday, in line with professional record-keeping guidance.

Financial and accounting records are generally retained for 6 years in accordance with applicable tax and company record-keeping requirements.

Enquiries from people who do not go on to become clients are generally retained for up to 12 months, unless there is a reason to keep them for longer.

Records relating to complaints, disputes or legal claims may be retained for longer where this is necessary to deal with the matter, meet insurance requirements, or establish, exercise or defend legal claims.

At the end of the relevant retention period, personal information will be securely deleted or anonymised where appropriate.

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Who we share information with

Data processors

• Wix.com Ltd (Website hosting, booking and online services provider, Israel) This data processor does the following activities for us: Wix hosts and operates our website and may process personal information submitted through website forms, bookings and other online services on our behalf.

• Stripe Payments Europe, Limited (Payment processing provider, Ireland) This data processor does the following activities for us: Stripe processes online payments on our behalf, including payment and transaction information required to take payments, issue refunds where applicable, prevent fraud and manage payment disputes.

Others we share personal information with 

• Other health providers (eg GPs and consultants)

• Organisations we need to share information with for safeguarding reasons

• Professional advisors

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Duty of confidentiality 

We are subject to a common law duty of confidentiality. However, there are circumstances where we will share relevant health and care information. These are where:

• you’ve provided us with your consent (we have taken it as implied to provide you with care, or you have given it explicitly for other uses);

• we have a legal requirement (including court orders) to collect, share or use the data;

• on a case-by-case basis, the public interest to collect, share and use the data overrides the public interest served by protecting the duty of confidentiality (for example sharing information with the police to support the detection or prevention of serious crime);

• If in England or Wales – the requirements of The Health Service (Control of Patient Information) Regulations 2002 are satisfied; or

• If in Scotland – we have the authority to share provided by the Chief Medical Officer for Scotland, the Chief Executive of NHS Scotland, the Public Benefit and Privacy Panel for Health and Social Care or other similar governance and scrutiny process.

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Sharing information outside the UK

Where necessary, our data processors may share personal information outside of the UK. When doing so, they comply with the UK GDPR, making sure appropriate safeguards are in place.

For further information or to obtain a copy of the appropriate safeguard for any of the transfers below, please contact us using the contact information provided above.

Organisation name: Wix.com Ltd

Category of recipient: Website hosting, booking and online services provider

Country the personal information is sent to: Israel

How the transfer complies with UK data protection law: The country or sector has been assessed as providing adequate protection to data subjects (also known as Adequacy Regulations or UK data bridge)

Organisation name: Stripe Payments Europe, Limited

Category of recipient: Payment processing provider

Country the personal information is sent to: Ireland

How the transfer complies with UK data protection law: The country or sector has been assessed as providing adequate protection to data subjects (also known as Adequacy Regulations or UK data bridge)

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How to complain

If you have any concerns about our use of your personal information, you can make a data protection complaint to us:

Email: info@somabylila.com

If you remain unhappy with how we’ve used your data after raising a complaint with us, you can also complain to the ICO.

The ICO’s address:

Information Commissioner’s Office

Wycliffe House

Water Lane

Wilmslow Cheshire

SK9 5AF

Helpline number: 0303 123 1113

Website: https://www.ico.org.uk/make-a-complaint​​​

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