This Policy Policy was last updated: May 24, 2018

FOREWORD

This Site Does Not Provide Medical Advice. The information provided at this website is intended for your general knowledge and educational purposes only and is not intended to be a substitute for professional medical advice or treatment. The information provided at this website is not intended to diagnose, treat, cure, or prevent any disease. Always seek the advice of your physician or other qualified healthcare provider with any questions you may have regarding your health or a medical condition, or to discuss treatment options, including the use of prescription medications. Never disregard or delay seeking medical advice because of something you have read on this website or any other website associated with Evan H. Hirsch, MD. Information provided on this site, and your use of this site, does not create a doctor-patient relationship.

The information provided on this site is not intended to be a substitute for any information contained on the label or in the labeling of products recommended. You should carefully review all product packaging, including instructions for use and precautionary statements, prior to using any product that you have purchased through this or any other website associated with Evan H. Hirsch, MD. Information on this site and statements regarding dietary supplements have not been evaluated by the Food and Drug Administration and are not intended to diagnose, treat, cure, or prevent any disease.


1. INTRODUCTION

This privacy notice provides you with details of how Evan H. Hirsch, MD / Fix Your Fatigue (FYF) collect and process your personal data through your use of our site www.fixyourfatigue.org.

By providing us with your data, you warrant to us that you are over 13 years of age. This site is intended for use by adults only. If you are under age 13, do not use this site and do not send us any personal information including your email. If you would like to contact us, please ask your parent or legal guardian to contact us on your behalf.

Evan H. Hirsch, MD / FYF are the data controller and we are responsible for your personal data (referred to as “we”, “us” or “our” in this privacy notice).

We have appointed a Data Protection Officer who is in charge of privacy related matters for us. If you have any questions about this privacy notice, please contact the Data Protection Officer using the details set out below.

Contact Details

The controller of data for the purposes of the General Data Protection Regulation (GDPR), other data protection laws that apply in member states of the European Union, and all other provision related to the protection of data is:

Full name of legal entity: Evan H. Hirsch, MD dba Fix Your Fatigue

Email address: DPO@fixyourfatigue.org

Postal address:  1037 NE 65th St #81165, Seattle, WA 98115

It is very important that the information we hold about you is accurate and up to date. Please let us know if at any time your personal information changes by emailing us at DPO@FixYourFatigue.org


2.  WHAT DATA DO WE COLLECT ABOUT YOU, FOR WHAT PURPOSE AND ON WHAT GROUND WE PROCESS IT 

Personal data means any information capable of identifying an individual. It does not include anonymized data.

We may process the following categories of personal data about you:

Sensitive Data

We may need to collect the following sensitive data about you in order to deliver health coaching services, educational courses regarding health/wellness, or any other product or service that is dependent on sensitive data.

We take sensitive data very seriously and know the value and vulnerability of this kind of information. Any sensitive data will be explicitly requested and will not be requested unless the delivery/fulfillment of a particular service or product is dependent upon acquiring such information. The sensitive data that may be requested includes, but is not limited to, any or all of these forms of data:

We require your explicit consent for processing sensitive data. When you submit your details, we will either require a handwritten or digital signature along with a date or may send you a further communication asking for you to confirm your consent to this processing.

Where we are required to collect personal data by law, or under the terms of the contract between us and you do not provide us with that data when requested, we may not be able to perform the contract (for example, to deliver goods or services to you). If you don’t provide us with the requested data, we may have to cancel a product or service you have ordered but if we do, we will notify you at the time.

We will only use your personal data for a purpose it was collected for or a reasonably compatible purpose if necessary. For more information on this please email us at DPO@fixyourfatigue.org. In case we need to use your details for an unrelated new purpose we will let you know and explain the legal grounds for processing.

We may process your personal data without your knowledge or consent where this is required or permitted by law.

We do not carry out automated decision making or any type of automated profiling.


3.  HOW WE COLLECT YOUR PERSONAL DATA  

We may collect data about you by you providing the data directly to us (for example by filling in forms on our site or by sending us emails). We may automatically collect certain data from you as you use our website by using cookies and similar technologies. [Please see our cookie policy below in section 11]

We may receive data from third parties such as analytics providers such as Google based outside the EU, advertising networks such as Facebook based outside the EU, such as search information providers such as Google based outside the EU, providers of technical, payment and delivery services, such as data brokers or aggregators.

We may also receive data from publicly available sources such as Companies House and the Electoral Register based inside the EU.


4. MARKETING COMMUNICATIONS  

Our lawful ground of processing your personal data to send you marketing communications is either your consent or our legitimate interests (namely to grow our business).

Under the Privacy and Electronic Communications Regulations, we may send you marketing communications from us if (i) you made a purchase or asked for information from us about our goods or services or (ii) you agreed to receive marketing communications and in each case you have not opted out of receiving such communications since. Under these regulations, if you are a limited company, we may send you marketing emails without your consent. However you can still opt out of receiving marketing emails from us at any time.

Before we share your personal data with any third party for their own marketing purposes we will get your express consent.

You can ask us or third parties to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you OR by emailing us at DPO@fixyourfatigue.org at any time.

If you opt out of receiving marketing communications this opt-out does not apply to personal data provided as a result of other transactions, such as purchases, warranty registrations etc.

5.  DISCLOSURES OF YOUR PERSONAL DATA

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

We require all third parties to whom we transfer your data to respect the security of your personal data and to treat it in accordance with the law. We only allow such third parties to process your personal data for specified purposes and in accordance with our instructions. We do not sell your personal information to any third parties for their personal use.

6.  INTERNATIONAL TRANSFERS

It is likely that a third party service provider that we use may be based outside of the European Economic Area (EEA), which means that their processing of your personal data will involve a transfer of data outside of the EEA.

We are subject to the provisions of the General Data Protection Regulations that protect your personal data. Where we transfer your data to third parties outside of the EEA, we will ensure that certain safeguards are in place to ensure a similar degree of security for your personal data. As such:

If none of the above safeguards is available, we may request your explicit consent to the specific transfer. You will have the right to withdraw this consent at any time.

7.  DATA SECURITY

We have put in place security measures to prevent your personal data from being accidentally lost, used, altered, disclosed, or accessed without authorisation. We also allow access to your personal data only to those employees and partners who have a business need to know such data. They will only process your personal data on our instructions and they must keep it confidential.

We have procedures in place to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach if we are legally required to.

8.  DATA RETENTION  

We will only retain your personal data for as long as necessary to fulfill the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

When deciding what the correct time is to keep the data for we look at its amount, nature and sensitivity, potential risk of harm from unauthorised use or disclosure, the processing purposes, if these can be achieved by other means and legal requirements.

For tax purposes the law requires us to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for six years after they stop being customers.

In some circumstances we may anonymise your personal data for research or statistical purposes in which case we may use this information indefinitely without further notice to you.

9.  YOUR LEGAL RIGHTS

Under data protection laws you have rights in relation to your personal data that include the right to request access, correction, erasure, restriction, transfer, to object to processing, to portability of data and (where the lawful ground of processing is consent) to withdraw consent.

You can see more about these rights at:

https://ico.org.uk/for-organisations/guide-to-the-general-data-protection-regulation-gdpr/individual-rights/

If you wish to exercise any of the rights set out above, please email us at GPO@fixyourfatigue.org.

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 or 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 may 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.

If you are not happy with any aspect of how we collect and use your data, you have the right to complain to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We should be grateful if you would contact us first if you do have a complaint so that we can try to resolve it for you.

10. THIRD-PARTY LINKS  

This website may include links to third-party websites, plug-ins and applications. 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 notice of every website you visit.

Please keep in mind that whenever you voluntarily make your personal information available for viewing by third parties online – for example on message boards, web logs, through email, or in chat areas – that information can be seen, collected and used by others besides us. We cannot be responsible for any unauthorized third-party use of such information.

11. COOKIES

We also may use a standard feature found in browser software called a “cookie” to enhance your experience with the Site. “Cookies” are small pieces of information that are stored by your browser on your computer’s hard drive. Most Web browsers automatically accept cookies, but you can usually change your browser to prevent that. We only use cookies to keep track of the pages you visit on the Site and to tell us whether you have visited the Site previously so that, in order to serve you better, we understand how you and other visitors use the Site.

You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly.

12. CONTACTING US

Questions regarding this Privacy Policy should be directed to DPO@fixyourfatigue.org.