Privacy Policy
Fairnurse Limited (“we”, “our”, “us” or “Fairnurse”) is committed to protecting the privacy of all users of our website fairnurse.com, or mobile applications (together, the “Sites”). Please read the following privacy policy that explains how we use and protect your information.
How to get in touch
If you have any queries or requests concerning this privacy policy or how we handle your data more generally, please get in touch with us using the following details. By contacting our general customer services team at: hello@fairnurse.com or by contacting our Data Protection Officer: dpo@fairnurse.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 request or book the Services of a Partner Nurse. 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 request or book services with us and during the requesting or booking process (including for payment);
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 platforms and our fraud detection provider.
Information we collect from you
Information you give us. This is information about you that you give us by filling in forms on the Apps or by corresponding with us by phone, e-mail or otherwise. It includes information you provide when you register to use the Apps or report a problem with the Apps. If you are accessing and using the Apps as a Partner Nurse, this may include your name, email address, postal address, availability dates, photograph, profile description, contact details, previous employment experience, qualifications, copies of any ‘right to work’ documentation which shows your ongoing entitlement to work in the UK (such as passport, visa documentation, national ID and/or resident’s permit), date of birth, details of your next of kin (including name, relationship and contact details), bank account details, and any details that you may provide by filling out any forms.
If you are accessing and using the Apps as a Dental Practice (the “client”), this may include your name, practice name, practice address, email address, job title and other business contact details of your staffing managers as well as the following information relating to any Partner Nurse whom you engage: (i) rates of pay, (ii) shifts worked, (iii) skills set, (iv) employer feedback and ratings, (v) interaction with shifts, (vi) unique identifiers, (vii) ERN number.
Information we collect about you. With regard to each of your visits to the Apps we will automatically collect the following information: technical information, including the Internet protocol (IP) address used to connect your device to the Internet, your login information, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform; information about your visit, including the dates and times you use the App, opportunities you view or search for page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-over’s), methods used to browse away from the page, and any phone number used to call our customer service number; and
Information we receive from other sources. This is information we receive about you from any third party source. If you are an employer, we may collect further information about you from credit reporting agencies. We may combine this data with the other information we have collected about you via the Apps. We will notify you when we receive information about you from them and the purposes for which we intend to use that data.
How we use the 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 will have a lawful basis for processing your information: If we need to process your information in order to provide you with the service you have requested or to enter into a contract; we have your consent; we have a justifiable reason for processing your data; or we are under a legal obligation to do so.
Where we need to in order to provide you with the service you have requested or to enter into a contract, we use your information:
To enable us to provide you with access to the relevant parts of the Sites;
To supply the Services you have requested;
To enable us to collect payment from you; and to contact you where necessary concerning our services, such as to resolve issues you may have with your booking.
We also process your data where we have a justifiable reason for doing so – for example personalisation of our service, including processing data to make it easier and faster for you to request a partner nurse. We have listed these reasons below:
To improve the effectiveness and quality of service that our clients can expect from us in the future;
To tailor content that we or our third party practice or client or advertising partners display to you, for example so that we can show you Partner Nurses 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 client support team to help you with any enquiries or complaints in the most efficient way possible;
To contact you for your views and feedback on our services 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 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;
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 Fairnurse, Nurse Partners, clients or others (including to prevent fraud); and
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. 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 services that we think you will prefer, or to let you know about special offers or products which we think you may be interested in. This activity is referred to as profiling. You have certain rights in relation to this type of processing. Please see ‘Your Rights’ section below for more information.
Where we rely on legitimate interest as a basis for processing your personal information, we carry out a ‘balancing test’ to ensure that our processing is necessary and that your fundamental rights of privacy are not outweighed by our legitimate interests. You can find out more information about these balancing tests by contacting us using the details above.
Where we are under a legal obligation to do so we may use your information to: create a record of your request or booking (s); comply with any legal obligation or regulatory requirement to which we are subject.
Cookies
We use cookies to distinguish you from other users of the Apps. This helps us to provide you with a good experience when you browse the Apps and also allows us to improve the Apps. A cookie is a small text file that can be placed on your device when using the Apps. Two kinds of cookies are used on the Apps – session cookies and persistent cookies.
Session cookies are used to remember selections made when you use the Apps. Session cookies are deleted automatically when you leave the Apps or close your browser.
Persistent cookies are used to identify you when you return to the Apps and/or to remember specific information about your preferences. These cookies also help us understand browsing behaviour within the Apps, which can help us develop the Apps in a way we believe will be most relevant to your interests. Persistent cookies are stored on your device and are not deleted when the browser is closed – these cookies must be ‘manually’ deleted if you want to remove them.
To learn more about cookies, please visit www.allaboutcookies.org or www.youronlinechoices.eu.
First and third party cookies
We set cookies (first party cookies) on web pages, however, where we require additional information or services, we also allow other companies to host cookies on our web pages (third-party cookies). These partner companies have been carefully selected by us and are required to meet contractual obligations they have with us.
How we use cookies
1. Strictly Necessary cookies – these cookies are used for technical reasons and are necessary to enable the Apps to operate efficiently so that you can navigate the Apps with ease and use specific features. These include, for example, cookies that enable you to log into secure areas of the Apps and cookies that help us to debug any errors. If these cookies are blocked or disabled, some of the Apps’ functions will not be available to you and you may not be able to use our service.
2. Performance Cookies – these cookies are used to obtain statistics about the number of users of the Apps and how such users interact with the Apps. These cookies collect information that is aggregated and therefore cannot be used to identify an individual’s identity. Such information allows us to continuously improve the Apps to provide users with a better online experience (such as enabling users to find what they are looking for more easily).
3. Functionality cookies – these cookies are used to improve the functionality of the Apps and make it easier to use. They help us to identify you as a repeat user of the Apps and help us remember your preferences, which saves you time by making the user experience easier.
4. Analytical cookies – these cookies gather information about your habits when using the Apps (including the pages you have visited). We may combine such information with other personal data that we have collected about you (for example your user profile) to enhance the Apps and make them more tailored to you.) These cookies may be placed on the Apps by carefully selected third parties on our behalf (with our permission) in order to help us collect statistical data about users of the Apps and conduct market research. We may share information that we collected through cookies, in aggregated form, with carefully selected third parties for the purposes set out above, unless you disable or block cookies as set out below.
How do I control cookie settings on my computer?
Please be aware that if you decide to disable or block cookies, parts of the Apps may not function correctly, or at all, and we may not be able to offer our services to you. Should you choose however to disable or block our cookies on your device you will need to do this through your browser. Click on the ‘Help’ menu on your particular browser to learn how to manage your cookie preferences. Alternatively, you can visit www.aboutcookies.org or www.youronlinechoices.eu for comprehensive information on how to manage cookies.
Direct Marketing
Where you have given your consent or where we have a justifiable reason 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 or phone.
Disclosure/Retention of 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 my 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 section on ‘How we use your personal information’ above); (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.
Where we store your personal data
The information we collect about you will be transferred to and stored on our servers located within the EU. We are very careful and transparent about whom else your information is shared with. Sharing your information internally, we share your information with other Fairnurse group companies only where necessary for the purposes set out in section ‘Sharing your information with third parties’.
We share your information with third party service providers. The types of third party service providers whom we share your information with includes:
Payment providers (including online payment providers and fraud detection providers): for the purposes of providing services to us, for example when they process information such as credit card payments for us, provide support services to you or carry out fraud checks for us;
IT service providers (including cloud providers): for the purposes of data storage and analysis;
Nurse partners: that you have placed your request or booking with so that they can fulfil the service, resolve issues, or improve their services;
Customer support partners: who will help us to resolve any issues you may have with our services;
Marketing and advertising partners: so that they can ensure that you see advertising which is more relevant to you and send you email marketing on our behalf. Fairnurse will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this privacy policy when it is transferred to third parties. 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;
In order to enforce our contractual terms with you and any other agreement;
To protect the rights of Fairnurse, Nurse Partners, clients, or others, including preventing fraud; and with such third parties as we reasonably consider necessary in order to prevent crime, e.g. the police. International transfers of data
In some cases the personal data we collect from you might be processed outside the European Economic Area (“EEA”), such as the United States, the Philippines and the countries in which Fairnurse operates (which are set out on www.Fairnurse.co.uk). These countries may not have the same protections for your personal data as the EEA has. However, we are obliged to ensure that the personal data that is processed by us and our suppliers outside of the EEA is protected in the same ways as it would be if it was processed within the EEA. There are therefore certain safeguards in place when your data is processed outside of the EEA. We ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:
Your personal data is transferred to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission;
We use the EU approved Standard Contractual Clauses; and where your personal data is transferred to third party providers based in the US, data may be transferred to them if they have self-certified under the Privacy Shield framework in relation to the type of data being transferred, which requires them to provide similar protection to personal data shared between the EU and the US.
Please contact us using the contact details above if you want further information on the countries to which personal data may be transferred and the specific mechanism used by us when transferring your personal data out of the EEA.
Security
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
Under data protection 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 our Data Protection Officer using the contact details set out above. For additional information on your rights please contact your data protection authority and see below.
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).
The right to restrict processing. You have rights to ‘block’ or ‘suppress’ further use of your information. 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 a general 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 the national data protection authority.
The right to withdraw consent. If you have given your consent to anything we do with your information (i.e. we rely on consent as a legal basis for processing your 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 while consent had been apparent.
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 or disabling cookies as set out in Cookies above.
Changes to our Privacy Policy
Any changes to our privacy policy will be posted to the Sites and, where appropriate, we will notify you of the changes for example by email or push notification.
How to make a complaint
Should you have cause to complain about how we handle your personal data, please contact us in the first instance. We will do our best to resolve your concern. Alternatively, you may prefer to submit a complaint directly to the Information Commissioner’s Office (ICO). For further details on how to complain to the ICO, please follow the links below: https://ico.org.uk/concerns/ or https://ico.org.uk/global/contact-us/.