PRIVACY POLICY

This Privacy Policy explains how Vitality Cayman Ltd. T/A Vitality Physio & Wellness (“Vitality”) collects, uses, stores, protects and shares personal data and sensitive personal data Vitality is committed to handling personal information responsibly and in accordance with the Cayman Islands Data Protection Act (2021 Revision).

 

This Privacy Policy explains:

• the types of information we collect;

• how and why we use your information;

• when information may be shared;

• how your information is protected and retained; and

• your rights in relation to your personal data.

 

YOUR RIGHTS

Under the Cayman Islands Data Protection Act, you have rights in relation to your personal data, including rights relating to:

• being informed about the use of your personal data;

• access to your personal data;

• rectification of inaccurate information;

• stopping or restricting certain processing;

• direct marketing;

• automated decision-making; and

• making a complaint and seeking compensation where applicable.

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CLINIC INFORMATION

 

Vitality Cayman Ltd. T/A Vitality Physio & Wellness
37 Pasadora Place, 94 Smith Road

P.O. Box 11254

George Town, Grand Cayman
Cayman Islands

KY1-1008

Telephone: +1 345 746 2222
Email: info@vitality.ky
Website: www.vitality.ky

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Vitality is a Data Controller in relation to the personal and healthcare information it collects and determines how and why that information is processed.

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INFORMATION WE COLLECT

We collect personal and sensitive personal data that is reasonably necessary to provide healthcare services and manage the clinic.

This may include:

• personal information such as your name, date of birth, gender, address, telephone number and email address;

• emergency contact or next-of-kin information;

• relevant employment information;

• health insurance and billing information;

• appointment and consultation information;

• clinical records, including assessment findings, treatment notes, treatment plans and referrals;

• medical and family history relevant to your care;

• correspondence with healthcare professionals, insurers and other organisations;

• information received from healthcare professionals, medical facilities, caregivers, insurers and government agencies; and

• relevant diagnostic or investigation reports, including radiology, pathology or laboratory reports.

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LAWFUL BASIS FOR PROCESSING

Vitality processes personal and sensitive personal data where there is an appropriate lawful basis under the Cayman Islands Data Protection Act.

Depending on the circumstances, this may include:

• your consent;

• processing necessary to provide services or fulfil a contract;

• compliance with a legal obligation;

• protection of your vital interests;

• Vitality's legitimate interests in operating and managing the clinic, where those interests are not overridden by your rights; and

• processing of health information where necessary for medical diagnosis, healthcare or treatment.

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HOW WE COLLECT INFORMATION

Information may be collected directly from you in person, by telephone, electronically, in writing or through our online systems.

Where appropriate, information may also be received from other sources involved in your care or the administration of your healthcare, including healthcare professionals, medical facilities, insurers, caregivers and family members.

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HOW WE USE AND DISCLOSE YOUR INFORMATION

Your personal and healthcare information is used primarily to provide and manage your care and the services you receive from Vitality.

Where appropriate, information may be shared with:

• healthcare professionals and facilities involved in your care;

• imaging or diagnostic facilities;

• persons involved in your care where you have authorised disclosure;

• health insurance providers for benefit verification, pre-authorisation, claims and payment purposes; and

• other persons or organisations where disclosure is authorised or required by law.

We will only disclose information that is reasonably necessary for the relevant purpose.

Where consent is the basis for a disclosure, you may withdraw that consent. This may affect Vitality's ability to provide certain services or submit information to an insurer on your behalf.

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ACCURACY OF INFORMATION

Vitality will take reasonable steps to ensure that personal information is accurate and up to date. Patients are encouraged to notify Vitality of changes to their contact information, insurance information, next of kin or other relevant details.

You may request correction of inaccurate personal data held by Vitality.

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ACCESS TO YOUR INFORMATION

You may request access to personal information Vitality holds about you and may request a copy of that information, subject to any applicable legal restrictions or exemptions.

Where appropriate and authorised by you, healthcare information may also be transferred to another healthcare provider or organisation. Information relating to another person may be withheld or redacted where necessary to protect that person's privacy or confidentiality.

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DATA STORAGE AND SECURITY

Vitality uses electronic systems, including Jane App, to maintain patient records and manage clinical information. Vitality takes appropriate technical and organisational measures to protect personal information against unauthorised access, disclosure, alteration, loss or destruction. These measures include physical security of the clinic, password-protected systems, appropriate access controls and confidentiality requirements for staff and persons working on behalf of Vitality.

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DATA RETENTION

Vitality retains patient medical records for 10 years following the patient's last encounter with the clinic, unless a longer retention period is required by law or another applicable requirement.

Personal information that is no longer required will be securely deleted or disposed of as appropriate.

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INTERNATIONAL TRANSFERS

Some electronic systems or service providers used by Vitality may store or process information outside the Cayman Islands. Where personal data is transferred internationally, Vitality will take appropriate measures to ensure that the transfer is permitted under applicable data-protection requirements and that appropriate safeguards are in place.

Information may also be transferred internationally where necessary for a patient's care or where the patient has authorised the transfer.

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CONFIDENTIALITY

All staff and persons working on behalf of Vitality are required to maintain the confidentiality of patient information. Personal and healthcare information will not be disclosed without appropriate authority unless disclosure is permitted or required by law or is necessary in circumstances such as protecting the vital interests of an individual.

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DIRECT MARKETING

You have the right to object to the use of your personal information for direct marketing. Vitality will respect requests to stop direct-marketing communications.

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COMPLAINTS

If you have concerns about how Vitality has collected, used, stored or disclosed your personal information, please contact us so that the matter can be reviewed in accordance with our complaints procedure. You also have the right to make a complaint to the Cayman Islands Ombudsman in relation to the handling of your personal data.

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PERSONAL DATA BREACHES

A personal data breach may include the accidental or unlawful loss, destruction, alteration, unauthorised disclosure of, or access to, personal data. Vitality will investigate suspected personal data breaches promptly and take appropriate steps to contain and address the incident. Where notification is required under the Cayman Islands Data Protection Act, Vitality will notify the Ombudsman and affected individuals within the applicable legal timeframes. The current policy identifies a five-day notification requirement where the relevant threshold is met.

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CONTACT FOR DATA PROTECTION AND PRIVACY

Questions, concerns or requests relating to your personal information or rights under the Cayman Islands Data Protection Act may be directed to:

 

Clinical Director / Data Protection Contact
Vitality Physio & Wellness
Email: rose@vitality.ky
Telephone: +1 345 746 2222

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POLICY REVIEW

This Privacy Policy will be reviewed at least annually and updated where necessary to reflect changes in Vitality's operations or applicable data-protection requirements.

 

Effective Date: 4 September 2025
Date Last Reviewed: 22 September 2026
Next Review Date: September 2027