PRIVACY POLICY

1. Purpose of this Privacy Policy

The purpose of this privacy policy is to inform you about how Root Cause collects and processes your personal data through your use of our website and our services. Root Cause takes the privacy of your information very seriously.

Please read this privacy policy carefully.

Our website and our services are not intended for children and we do not knowingly collect data relating to children.

This privacy policy does not extend to any third-party websites, plug-ins and applications that can be accessed from our website. 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 policy of every website you visit.

We keep our privacy policy under regular review. This version was last updated on 14 September 2022. 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.

2. Data Controller

The controller responsible for your personal data is Trichology UK Limited trading as Root Cause Clinical (“Root Cause Clinical”, “we”, “us” or “our” throughout this privacy policy).

Trichology UK Limited  is a company incorporated in Scotland with company number SC606612 and having its registered office at 60 St. Enoch Square, Glasgow, United Kingdom, G1 4AG.

If you have any questions about this privacy policy or our privacy practices, please contact us at info@rootcauseclinical.com.

At any time, you have the right to contact the Information Commissioner's Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We have a registered Data Controller.

3. 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 including:

  • Identity Data (including full name, date of birth, gender and marital status);
  • Contact Data (including address, email address and telephone number);
  • Financial Data (including payment card details);
  • Transaction Data (including details of payments you have made and services you have purchased from us); and

Technical Data (including 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).

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.

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 services you have purchased). In this case, we may have to cancel a service you have with us but we will notify you if this is the case at the time.

4. How we collect Data

We collect data from and about you in different ways including:

  • Direct interactions. You may give us your Identity, Contact, Medical and Financial Data by corresponding with us. This includes personal data you provide when you:
    • apply for our services;
    • create an account or profile on our website;
    • complete a pre-consultation survey; or
    • give us feedback or contact us.
  • Automated technologies or interactions. As you interact with our website, we will automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies and other similar technologies. For more information on cookies, please see our Cookies policy.
  • Third parties or publicly available sources. We may receive personal data about you from third parties including any Practitioners (such as specialist trichologists, scalp surgeon, nutritionist, counsellor, or other specialists who provide professional advice to you in relation to hair loss or scalp health treatment) or researchers or clinicians.

5. 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.
  • 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 obligation.

In broad terms, our “legitimate interests” means running our business. This can include recovering debts due to us, keeping our records updated and other administrative functions, and developing our services and growing our business.

Generally, we do not rely on consent as a legal basis for processing your personal data. The exception is where we process special category information about you (such as Medical Data). If we cannot provide a service to you without processing your Medical Data, we will seek your consent to collect and process Medical Data. You can withdraw your consent to the processing of your Medical Data at any time but please be aware, if you do withdraw your consent, we may no longer be able to provide you with services.

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. For example, we will work in partnership with clinicians and researchers with the aim of learning more about hair loss and scalp health. But we will never disclose your personal information – name, address and email. 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 on info@rootcauseclinical.com.

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.

6. Disclosures of  your Personal Data

We may share your personal data with the parties set out below:

  • Practitioners (including specialist trichologists, scalp surgeon, nutritionist, counsellor or other specialists) acting as joint controllers who provide professional advice to you in relation to hair loss treatment;
  • Service providers acting as processors who provide IT, financial and administrative services;
  • Professional advisers acting as joint controllers including lawyers, bankers, accountants and insurers who provide legal, banking accounting and insurance services;
  • HM Revenue & Customs, regulators and other authorities acting as joint controllers who require reporting of processing activities in certain circumstances; and
  • 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 policy.

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.

7. International Transfers

Many of our external third parties are based outside the UK so their processing of your personal data will involve a transfer of data outside the UK. Whenever we transfer your personal data out of the UK, 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; or
  • Where we use certain service providers, we may use specific contracts approved for use in the UK which give personal data the same protection it has in the UK.

Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the UK.

8. Keeping Data secure

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. If you suspect any misuse or loss or unauthorised access to your Data, please contact us at info@rootcauseclinical.com.

9. Data Retention

We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.

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, regulatory, tax, accounting or other requirements.

In some circumstances we will 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.

10. Your Rights

You have the following rights in relation to your Data:

  • Right to access - you may receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
  • Right to correct – you may 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.
  • Right to erase - you can 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.
  • Right to object – you can object to our use of your Data including where we use it for our legitimate interests. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
  • Right to restrict our use of your Data – you can ask us to suspend the processing of your personal data if you want us to establish the data's accuracy; or where our use of the data is unlawful but you do not want us to erase it; or 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 if you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
  • Right to data portability – you can 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.
  • Right to withdraw consent - you can withdraw your 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 services to you. We will advise you if this is the case at the time you withdraw your consent.

To make enquiries, exercise any of your rights set out above, or withdraw your consent to the processing of your Data (where consent is our legal basis for processing your Data), please contact us at info@rootcauseclinical.com.

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 could refuse to comply with your request in these circumstances.

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.

We try to respond to all legitimate requests within one month. Occasionally it could 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.

For enquiries please contact our Data Controller on info@rootcauseclinical.com.

2022