Privacy & Data Protection Policy

UK Veincentre & Dubai LLC Privacy Policy (“Privacy Policy”)

In compliance with the provisions of the United Arab Emirates “UAE” Federal Decree Law No. 45 of 2021 regarding the Protection of Personal Data (hereinafter the “PDPL”), UK Veincentre FZ-LLC (“UKVC”, “We”, “Us” and “Our”), acting as the Data Controller, are committed to protecting your privacy. Here we explain how and why we process your personal data, the third parties with whom we may share your personal data, what your rights are in the event we hold your personal data, and how you can enforce these rights with us.

In this policy “UKVC”, “We”, “Us” and “Our” means UK Veincentre FZ-LLC, a general surgical clinic incorporated under the laws of Dubai, UAE, holding commercial license number 1350.

UKVC is a “Data Controller” which means we are responsible for determining the purposes for which and the manner in which any personal data is, or is to be, processed. “Personal data” means any information that UKVC processes that relates to identifiable or identified individuals.

1. What information do we collect?

We collect your personal data and use it in different ways depending on your relationship with us, for example if you are a prospective, current or former patient. This can include information we receive from other third parties. Depending on your relationship with us, we may hold the following types of personal data about you:

  • Identity and contact data: for example, identity document, your name, date of birth, postal address, telephone number and e-mail address.
  • Medical data: for example, data relating to medical treatment carried out by us, or health data from relevant third parties e.g. family doctor, previous surgeon.
  • Payment and account data: for example, your bank account details or health insurance information.
  • Location data: for example, your postal or IP address or the location of your primary doctor.
  • Correspondence data: for example, copies of forms, letters and e-mails we send you or you send to us, and notes or call recordings of any telephone conversations.
  • Feedback: for example, we may ask you for feedback on your experiences with us to help us continually improve our services and to help us with marketing.
  • Information we obtain from other sources: for example from crime prevention agencies and other data providers. This can include demographic data and interest-based data.
  • Complaint data: for example, what the complaint was, how we investigated it and how we resolved it.

2. What PURPOSES do we use your personal data for and what is our LEGAL BASIS?

We are required to establish a legal basis to use your personal data. We use your information for the following lawful reasons:

  • To enter into or perform a contract: for example to provide you with a quotation for medical treatment, to start, change or cancel a treatment plan, to answer any queries you may have, action your requests or contact you for follow-up;
  • To comply with a legal obligation: for example the rules set by our regulators (the Dubai Health Authority), to fulfil your data rights under data privacy laws, handle complaints about data privacy, and to comply with other legal and regulatory requirements such as preventing money laundering and other crimes;
  • With your consent: for example if you consent to us contacting you for feedback or for marketing purposes;
  • To protect your interests : in extreme or unusual circumstances, We may need to use your information to protect your life or the lives of others.

3. How and where is your information shared?

Where applicable, we may share your personal data with the following recipients when we have a valid reason to do so:

  • Other health providers, including your primary care doctor and local hospitals;
  • Service providers who help us manage our IT and back office systems, or who provide platforms to us that we then use or make available to you;
  • Marketing fulfilment & customer satisfaction service providers, acting on our behalf in providing marketing communications and capturing feedback on our products and services;
  • Any third party where disclosure is required to comply with a contractual, legal or regulatory requirement;
  • We may disclose aggregate statistics about site visitors and customers in order to describe services to prospective partners, advertisers and other reputable third parties and for other lawful purposes, but these statistics will include no personally identifying information.

4. Sharing personal data

As stated above, and depending on our relationship with you and the services you may receive from us, we may share your personal data with other health providers. This will generally be for the following purposes:

  • To receive medical information or clarification on the data you have provided to us, for example details of previous surgeries, allergies or health conditions;
  • For the purposes of referral, for example in the case that we are unable to provide or continue your treatment, we may recommend a third party health provider;
  • In case of emergency, for example where you need to be transferred to a local hospital.

We will only share the minimum amount of personal data required to achieve these purposes, ensuring that we have a lawful basis to share personal data and that any processing undertaken on our behalf is governed by a suitable data sharing agreement.

From time to time we may approach you regarding using your data for marketing purposes. Any personal testimonials, photographs and patient feedback will be shared or uploaded on our website or social media channels only with your express consent in writing.

5. International data transfers

Under certain circumstances, for example to consult with a colleague or specialist, to manage our contract with you or where required by law or regulation, we may need to transfer your personal data to parties based outside of the UAE. Where we do this, we will ensure that your information is protected in accordance with the applicable data protection requirements applicable in the country.

If the data protection laws of the country that the recipient of your data is based in, are not recognised as providing sufficient protection by the UAE, We will ensure that we have an appropriate basis to transfer the personal data outside the UAE and/or the recipient enters into a formal and enforceable legal agreement that reflects the standards required.

You can ask us for more information about the safeguards we use when sending your personal data overseas by contacting us on the details shown in the “our contact details” section of this Privacy Policy.

6. Retaining personal data

We retain personal data to meet a number of legal and regulatory requirements, as well as our own legitimate business interests.

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 such purposes through other means, and the applicable legal requirements.

7. Security

We place great importance on the security of all personally identifiable information associated with our customers. We have security measures in place to protect against the loss, misuse and alteration of customer data under our control. For example, our security and privacy policies are periodically reviewed and enhanced as necessary and only authorised personnel have access to user information. While we cannot ensure or guarantee that loss, misuse, or alteration of data will not occur, we use our best, reasonably required efforts to prevent this.

8. Your data rights

Data protection law gives you rights relating to your personal data. This section gives you an overview of these rights, how they relate to the information you give us, the circumstances under which a right may not be absolute, and how you can send us a request to enforce one of these rights. Subject to any overriding legal obligations, requirements and/or exemptions, we will endeavour to get back to you as soon as possible. In the event your request is particularly complex, we will notify you and keep you updated:

Right to access

You have a right to request a copy of the personal data that we hold on you, along with meaningful information on how it is used and who we share it with. This right always applies, but there are some instances where we may not be able to provide you with some or all of the information we hold. Where this is the case, we will explain to you the reason and when we can respond to your request, unless the relevant laws or regulations prevent us from doing so.

Right to request data portability

You have the right to receive your personal data which was provided to us for processing, in a structured and machine-readable format. You may also have the right to request transmission of such personal data to another health provider, where technically feasible.

Right to rectification

You have a right to ask us to correct inaccurate or incomplete personal data that we hold about you. We will either confirm to you that this has been done, or if there is a valid reason that this cannot be done, we will let you know the reason.

Right to erasure

You can request that we delete your personal data in certain circumstances, for example if we no longer need the personal data for the purpose(s) for which we collected it. We will either confirm to you that this has been done, or if we are unable to delete it due to a compelling overriding reason or retention is required by any legal or regularly obligations, we will let you know the reason for continuing to hold personal data and the period we are required to hold such personal data.

Right to restrict processing

You can ask us to restrict the processing of your personal data in certain circumstances. If you do so, we will either confirm to you that this has been done, or if we are unable to do so, we will inform you of the reason.

Right to object to automated decision-making

You have the right to object to decisions made about you, using your personal data and undertaken by purely automated means, including profiling. If you do so, we will arrange for someone to assess the automated decision and confirm the outcome of this assessment to you.

Right to object to certain processing, including direct marketing

You can object to certain processing, including to receive direct marketing from us. You can object to receiving direct marketing from us by simply clicking on the unsubscribe link in any email you receive from us or alternatively getting in touch with us though the contact details mentioned hereunder.

Right to withdraw your consent

You have the right to withdraw your consent at any time to the use of your personal data for a particular purpose (where we have asked you for consent to use your information for that particular purpose).

Right to lodge a complaint

If you find that you have reasons to file a complaint against UKVC for our data processing activities, you may contact the UAE Data Office or the Dubai Healthy Authority as appropriate.

If you would like to exercise any of the above rights, you can contact us in writing – please refer to “Contact us” at section 11 to obtain the relevant contact information.

9. Use of cookies

Cookies are pieces of information that a website transfers to your hard drive to store and sometimes track information about you. Most web browsers automatically accept cookies, but if you prefer, you can change your browser to prevent that. However, you may not be able to take full advantage of a website if you do so. Cookies are specific to the server that created them and cannot be accessed by other servers, which means they cannot be used to track your movements around the web. Although they do identify a user’s computer, cookies do not personally identify users. Passwords and credit card information are not stored in cookies.

UKVC does not currently use any cookies on our website for general or public use. Should this change in the future, we will update this policy and ensure that a new pop-up message appears on our website to obtain users’ consent to use cookies.

Registered users and staff who have been provided with a username and password to login to the site will be subject to WordPress cookies. If you are a registered user and object to the use of cookies, please contact us so that we can revoke your username and password. It is not possible to be a registered user/administrator of the site without these cookies.

10. Changes to this Privacy Policy

If we change our Privacy Policy in any way, we will post these changes on this page. You are responsible for periodically visiting the UKVC website and this Privacy Policy to check for any changes.

11. Contact Us

Please e-mail us with any questions, concerns or comments you have about this Privacy Policy to: info@uk-vc.com or write to us at:

UK Veincentre FZ-LLC
Floor 2
Building 72
Dubai healthcare city
Dubai

Website: https://www.uk-veincentre.com
Email: info@uk-vc.com

12. Last updated

21st February 2024