Privacy Policy 

Updated: June 2024 

1. INTRODUCTION 

Total Billing Solutions Limited (trading as Enhanced Technology) is the data controller and we are responsible for your personal data (referred to as “we”, “us” or “our” in this privacy notice). 

This privacy notice provides you with details of how we collect and process your personal data through your use of our site https://www.enhancedtechnology.co.uk or the interaction with our business for business as usual activity or use of our software products. 

If you need to email us about anything related to this privacy notice, you can email us at support@enhancedtechnology.co.uk or you can write to us at Enhanced Technology, PO Box 522, St Helier, Jersey, JE4 5UF. 

If any of your personal information changes, please email us at the above email address and let us know how it has changed. From time to time we may email you to check that the personal data we hold for you is accurate and up to date. 

2. WHAT PERSONAL DATA WE COLLECT ABOUT YOU  

Depending on the requirement we may collect the following data about you: 

• Your name 

• Your email address or addresses 

• Your address 

• Your phone number or numbers 

• Your date of birth 

• Your business name or names 

• Your financial details 

• Data about how you use our website 

• Technical data such as your IP address, your login data, details about your browser, length of visit to pages on our website, page views and navigation paths, details about the number of times you use our website, time zone settings and other technology on the devices you use to access our website 

• Your marketing and communication preferences 

• Any other information that you directly provide to us whether over the phone, by email or otherwise 

• Photographs of you at events 

• CV and application forms 

• Credit information from third parties 

We may additionally collect the following information if you use one of our products. 

• Patient Identifier  

• Health Event Data  

• User Authentication Data 

• NHS Number  

• Medication, Date and Quantity  

• Consultation Date  

• Event Description  

• Consultation Text  

• Clinical System Reference Number 

• Medical Insurance Provider 

• Supplier Details 

We also collect, use and share aggregated data such as statistical or demographic data which is not personal data as it does not directly (or indirectly) reveal your identity. For example, we may aggregate individuals' Usage Data to calculate the percentage of users accessing a specific website feature in order to analyse general trends in how users are interacting with our website to help improve the website and our service offering. 

3. HOW WE MAY USE YOUR DATA  

We will use your data for us to: 

• Reply to any enquiries you make about our products or services 

• Process financial transactions to enable you to purchase our goods our products or services 

• Send you customer communications about enhancements to products or services you have bought 

• Enable us to perform a contract with you, process orders, respond to enquiries related to the order and deal with complaints 

• Send you marketing communications where we are allowed by law to do so 

• Keep records of orders placed and communications in relation to such orders 

• Comply with any legal obligations we are subject to or as required by a government authority 

• Keep records of communications 

• Provide a product or service to you 

• Personalize your experience on our websites 

• Monitor the use of our website and online services 

• Analyse your use of our website and other online services 

• Administer and protect our business and website 

• Deliver relevant website content and advertisements to you 

• Understand the effectiveness of our advertising 

• Carry out credit checks 

• Bring legal claims against you if you breach a contract or fail to make payment 

• Obtain professional advice 

OUR LAWFUL GROUND OF PROCESSING 

Under the General Data Protection Data Regulations, we are only legally able to process your personal data if we have a lawful ground for doing so. 

Our lawful grounds of processing are: 

• In relation to Customer Data that we have obtained when you placed or are placing an order with us, that we hold for the purpose of fulfilling that contract, informing you about updates to the product or service and keeping records of the contract. The processing is necessary for the performance of a contract to which you are subject and for our legitimate interests in informing you about updates to the product or service, record keeping and to establish, pursue or defend legal claim as responsible business operations. 

• In relation to Prospect Data that we have obtained when you enquired about our products or services (whether that be through our website or otherwise) and that we process in order to reply to your enquiry and keep records of this. The processing is necessary in order to take steps at your request prior to entering into a contract and for our legitimate interests in record keeping and to establish, pursue or defend legal claim. 

• In relation to Prospect Data that we have obtained when you signed up for any of our free resources and that we process in order to send you those free resources, reply to your communications about the resources and to keep relevant records, you have given consent to the processing for the purposes of us sending you the free resource and it is in our legitimate interests to reply to your communications and to keep records for our business. 

• In relation to Marketing Data that we have obtained when you told us your marketing preferences, when you consented to us sending you details of our products and services, for the purposes of us sending you marketing communications, enabling you to partake in our promotions such as competitions, prize draws and free flyers, to deliver relevant website content and advertisements to you and measure or understand the effectiveness of this advertising. The processing is necessary for our legitimate interests which in this case are to study how customers and users use our products/services, to develop them, to grow our business and to decide our marketing strategy. 

• In relation to User Data that we have obtained through cookies on our website or other online services for the purposes of operating our website, ensuring relevant content is provided to you, ensuring the security of our website, maintaining back-ups of our website and/or databases and to enable publication and administration of our website, other online services and business. The processing is necessary for the purposes of our legitimate interests which in this case are to enable us to properly administer our website and our business. 

• In relation to Technical Data (that includes data about your use of our website and services such as your IP address, your login data, details about your browser, length of visit to pages on our website, page views and navigation paths, details about the number of times you use our website, time zone settings and other technology on the devices you use to access our website), we process this data to analyse your use of our website and other services, to administer and protect our business and website, to deliver relevant website content and advertisements to you and to understand the effectiveness of our advertising. Our lawful ground for this processing is our legitimate interests which in this case is to enable us to properly administer our website and our business, to grow our business and to decide our marketing strategy. 

• In relation to your data that we process in order to comply with legal requirements or as required by a government authority, the processing is necessary for compliance with a legal obligation to which we are subject. 

• In relation to keeping records, this processing is either necessary for compliance with a legal obligation that we are subject to or for our legitimate interests in responsible business operations or defending, pursuing or establishing a legal claim. 

• In relation to obtaining professional advice and insurance, this processing is necessary for our legitimate interests in order to protect and grow our business. 

• In relation to our GP Profit Recovery Service we are a Data Processor and your doctor, hospital, practice or trust is the data controller and we are the processor, meaning that our legal basis for processing your information Public interest: It is necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller, in this case, your doctor, hospital, practice or trust. 

We do not collect any information about criminal convictions and offences. 

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

4. HOW WE COLLECT YOUR PERSONAL DATA 

We may collect data about you by you providing the data directly to us. 

We may automatically collect certain data from you as you use our website by using cookies and similar technologies.  

We may collect data about you when using our products or services. 

We may receive data from third parties such as analytics providers such as Google based outside the EU. 

5. 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 only send you email or text marketing communications if (1) 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. 

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. 

You can ask us to stop sending you marketing messages at any time by emailing us support@enhancedtechnology.co.uk  

6. DISCLOSURES OF YOUR PERSONAL DATA 

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

• Service providers who provide IT and system administration services. 

• Professional advisers including lawyers, bankers, accountants, auditors and insurers. 

• Government bodies that require us to report processing activities or otherwise disclose your personal data. 

• Market researchers and fraud prevention agencies. 

• Third parties to whom we transfer, or merge parts of our business or our assets. 

We require all third parties to whom we transfer your data too 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. 

For our GP Profit Recovery service: 

Where we provide our services to doctors, hospitals, practices or trusts, the doctors, hospitals, practices or trusts, as data controller, will share your personal data with us and we will process that data before sharing that personal data back to the doctors, hospitals, practices or trusts. 

We may share your personal data where necessary with the parties set out below: 

• internal third parties such as shareholders, officers, employees, consultants or contractors; 

• external third parties such as the government, regulatory or tax authorities; 

• third parties to whom we may choose to sell, transfer or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this Privacy Policy. 

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions. 

If you follow hyperlinks from our website to another website, please note that we are not responsible for and have no control over their privacy policies and practices. 

7. DATA SECURITY 

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. 

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 fulfil 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 unauthorized use or disclosure, the processing purposes, if these can be achieved by other means and legal requirements. 

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

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. 

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 support@enhancedtechnology.co.uk  

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 several 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) https://www.oicjersey.orgor 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. COOKIES 

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