Introduction
Our website address is: https://icebreaker.fi/.
I will be clear and transparent about the information I am collecting and what I will do with that information.
This Policy sets out the following:
- What personal data I collect and process about you in connection with your relationship;
- Where I obtain the data from;
- What I do with that data;
- How I store the data;
- Who I transfer/disclose that data to;
- How I deal with your data protection rights;
- And how I comply with the data protection rules.
- All personal data is collected and processed in accordance with Maltese and EU data protection laws.
What personal data I collect
Personal data means any information relating to you which allows me to identify you, such as your name and contact details.
I may collect personal data from you when you book a session or when you contact me.
Specifically, I may collect the following categories of information:
- Name, e-mail address, telephone number and details;
What I use your personal data for, why and for how long
Your data may be used for the following purposes:
- Providing services you require;
- Contacting you in the event of an appointment change or cancellation;
- Customer Services communications: I use your data to manage your relationship with me as my patient and to improve my services and enhance your experience with me;
- Provide tailored services: I use your data to provide information I believe is of interest to you, prior to, during, and after your sessions with me and to personalise the services I offer to you;
I may also process your personal data for one or more of the following:
- To comply with a legal obligation;
- You have consented to me using your personal data;
- To protect your vital interests or those of another person (e.g. in case of a medical emergency);
It is in my legitimate interests in operating (e.g. for administrative purposes).
I will not retain your data for longer than is necessary to fulfill the purpose it is being processed for. To determine the appropriate retention period, I consider the amount, nature and sensitivity of the personal data, the purposes for which I process it and whether I can achieve those purposes through other means.
I must also consider periods for which I might need to retain personal data in order to meet my legal obligations or to deal with complaints, queries and to protect my legal rights in the event of a claim being made.
When I no longer need your personal data, I will securely delete or destroy it. I will also consider if and how I can minimise over time the personal data that I use, and if I can anonymise your personal data so that it can no longer be associated with you or identify you, in which case I may use that information without further notice to you.
Security of your personal data
I follow strict security procedures in the storage and disclosure of your personal data, and to protect it against accidental loss, destruction or damage.
I may disclose your information to a third party for the purposes set out in this Privacy Policy (see below). I require all third parties to have appropriate technical and operational security measures in place to protect your personal data, in line with Maltese and EU law on data protection rules.
Sharing your personal data
Your personal data may be shared with the following third parties for the purpose described in this Privacy Policy:
- Clinics, pharmacies, holistic centers and hospitals in Malta for the purpose of booking and hosting our sessions;
- Social media: You may be able to access third party social media services through my website or before visiting my website. As a result your information will be shared with your social media provider. Please refer to the privacy policy of these third-party social media providers to find out more about these practices.
Your Data Protection rights
Under certain circumstances, by law you have the right to:
- Request information about whether I hold personal information about you, and, if so, what that information is and why I am holding/using it.
- Request access to your personal information (commonly known as a “data subject access request”). This enables you to receive a copy of the personal information I hold about you and to check that I am lawfully processing it.
- Request correction of the personal information that I hold about you. This enables you to have any incomplete or inaccurate information I hold about you corrected.
- Request erasure of your personal information. This enables you to ask me to delete or remove personal information where there is no good reason for me continuing to process it. You also have the right to ask me to delete or remove your personal information where you have exercised your right to object to processing (see below).
- Object to processing of your personal information where I am relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground. You also have the right to object where I am processing your personal information for direct marketing purposes.
- Object to automated decision-making including profiling, that is not to be subject of any automated decision-making by me using your personal information or profiling of you.
- Request the restriction of processing of your personal information. This enables you to ask me to suspend the processing of personal information about you, for example if you want me to establish its accuracy or the reason for processing it.
- Request transfer of your personal information in an electronic and structured form to you or to another party (commonly known as a right to “data portability”). This enables you to take your data from me in an electronically usable format and to be able to transfer your data to another party in an electronically usable format.
- Withdraw consent. In the limited circumstances where you may have provided your consent to the collection, processing and transfer of your personal information for a specific purpose, you have the right to withdraw your consent for that specific processing at any time. Once I have received notification that you have withdrawn your consent, I will no longer process your information for the purpose or purposes you originally agreed to, unless I have another legitimate basis for doing so in law.
If you want to exercise any of these rights, then please submit a completed request form available at this form.
You will not have to pay a fee to access your personal information (or to exercise any of the other rights).
I may need to request specific information from you to help me confirm your identity and ensure your right to access the information (or to exercise any of your other rights). This is another appropriate security measure to ensure that personal information is not disclosed to any person who has no right to receive it.
Changes to my Privacy Policy
My Privacy Policy may change from time to time and any changes to the statement will be communicated to you by way of an e-mail or a notice on my website.
Rights on Personal Data Form
If you want to delete your data use the form here.