Privacy Policy (effective 01 May 2019)

This Privacy Policy explains how personal information is collected, used, and disclosed by Feet First Specialised Rehabilitation Centre (“we”, “our” or “us”) and rights and choices you have in relation to the personal data we hold and process. This Privacy Policy applies to our clients, customers, suppliers, employees, workers and other third parties (e.g. other professionals such as lawyers, accountants, surveyors, etc.) and visitors to our website (individually, “you”). By instructing us to act on your behalf and by visiting or using our website or providing information about you digitally or otherwise, you are consenting, to the extent permitted by applicable law, to us gathering and processing information about you in accordance with this Privacy Policy, although consent may not be required for all of the elements described in this Privacy Policy. For particular types of information or processing, we may provide you with choices or request your further consent related to the information we collect and how we may process it. This Privacy Policy is separate and in addition to confidentiality obligations we owe to our clients and clients should also refer to our terms of appointment for further details.

Who are we?

Feet First Specialised Rehabilitation Centre is a company established under the laws of the United Arab Emirates and licensed by the Dubai Department of Economic Development.

Whose data do we hold?

We may hold data about the following people:

• Employees and workers
• Customers and clients
• Suppliers and service providers
• Advisers, consultants and other professional experts
• Complainants and enquirers

What data will we collect?

We will only collect information that is relevant to the contract signed with you or information you have provided us with pursuant to an enquiry. In particular we may collect the following information from you which is defined as 'personal data':

• Personal details, including identity data and contact details
• Financial details
• Business activities of the person whose details we are processing

We never collect any personal data from you when you view our website unless you expressly register on our career website.

We never collect information that is referred to as being in a ‘special category’ under the General Data Protection Regulation 2016/679 (“GDPR”).

We also operate a client relationship management email mailing list programme, which we use to inform clients and other contacts about our services. Such marketing messages may contain tracking technologies in order to track subscriber activity relating to engagement, demographics and other data.

If you would like to stop receiving marketing materials from us at any time, please contact info@feet1st.com. You can also change your preferences for receiving our marketing emails and updates from us at any time, and you can unsubscribe by following the instructions specified in our marketing emails or via the websites.

When we collect your personal data

We may collect personal data about you at various stages, such as:

• When you or your organisation seek our services
• When you or your organisation make an enquiry (including, without limitation, in person, over email or over the telephone)
• When you attend a seminar or other event we may organise, or sign up to receive communications from us
• When you or your organisation provide services to us, or otherwise offer to do so

Basis for processing

The basis on which we process your personal data is one or more of the following:

• It is necessary for the performance of our contract with you
• It is necessary for us to comply with a legal obligation
• It is in our legitimate interests to do so
• You have given us your consent (this can be withdrawn at any time on request by sending an email to info@feet1st.com)

How will we use your data?

We may use your information for the following purposes:

• Provision of massage and spa services
• Promotion of our goods and services
• Provision of education and training to customers and clients
• Maintaining accounts and records
• Supporting and managing staff
• Managing and administering your or your organisation’s business relationship with us, including processing payments, accounting, auditing, billing and collection or support services
• Complying with our legal and regulatory obligations (such as record keeping obligations) and for insurance purposes
• Communicating with you through appropriate channels to keep you up to date on the latest developments, announcements, and other information about our services, events and promotions we may organise
• For any purpose related and/or ancillary to any of the above or any other purpose for which your personal data was provided to us

Who will we share your information with?

We may share your personal information outside our company. This may include:

• Third party agents/suppliers or contractors, bound by obligations of confidentiality, in connection with the processing of your personal information for the purposes described in this Policy. This may include, but is not limited to, IT service providers.
• Third parties relevant to the massage and spa services that we provide. This may include, but is not limited to, professional service providers, regulators and government authorities (land departments of relevant emirates).
• To the extent required by law, regulation or court order, for example, if we are under a duty to disclose your personal information in order to comply with any legal obligation.
• Where you authorise us, we may also disclose your information to your family, associates or representatives and we may also disclose your information to debt collection agencies if you do not pay our invoices.

How long will we keep your information for?

We will normally keep your information throughout the period of time that we do work for you and afterwards for such period as we are required to do by law and also by the regulations and insurance requirements that apply to us.

Usually this will be for a period of six years after we conclude the work we have carried out for you, but may be for a longer period in certain specific cases.

Transfers to third countries

We may from time to time transfer your personal data to a country outside the European Union. Normally this will be necessary for the performance of your contract with us. Sometimes we may transfer for other reasons and we will ensure that appropriate safeguards are in place at all times. Such safeguards may include:

• the country to which we send your personal data is approved by the European Commission as providing an adequate level of protection for personal data;
• the recipient has entered into European Commission standard contractual clauses with us; or
• you have explicitly consented to the transfer of your personal data.

Security arrangements

We take appropriate technical and organisational measures to keep your personal data confidential and secure, in accordance with our internal policies and procedures regarding storage of, access to and disclosure of personal data.

We may keep your personal data in our electronic systems, in the systems of our contractors, or in paper files.

What rights do you have?

You have the following rights under the GDPR:

• Right to be informed
• Right of access
• Right to rectification
• Right to erasure
• Right to restriction of processing
• Right to data portability
• Right to object
• Rights concerning automated decision-making and profiling
• You have a right to see the information we hold about you
• To access this you need to provide a request by email to info@feet1st.com, together with proof of identity

We will usually process your request free of charge and within 30 days however we reserve the right to charge a reasonable administration fee and to extend the period of time by a further two months if the request is manifestly unfounded or vexatious and/or is very complex

Right to erasure

• You have a right to ask us to erase your personal data in certain cases
• We will deal with your request free of charge and within 30 days but reserve the right to refuse to erase information that we are required to retain by law or regulation, or that is required to exercise or defend legal claims
• To exercise your right to erasure please contact us by email to info@feet1st.com together with proof of identity

Who can you complain to?

If you are unhappy about how we are using your information or how we have responded to your request, then initially you should contact info@feet1st.com

Changes to our privacy policy

This Privacy Policy was last updated on 1 May 2019. We have the right to update the contents of this Privacy Policy from time to time to reflect any changes in the way in which we process your personal data or to reflect legal requirements as these may change. If we update the Privacy Policy, we will post the revised Privacy Policy on our website. Changes will take effect as soon as the revised version is made available on our website.