Last updated 18 October 2021
We are a registered in the UK with company number 12500620 and our registered office address at the Technology Centre, Occam Road, Guildford, UK (“Company”).
This website is not intended for children under 18 years of age and people over 60 years of age, and we do not knowingly collect data relating to children under 18 nor people over 60.
1. THE DATA THAT WE COLLECT FROM YOU AND HOW WE COLLECT IT FROM YOU
We collect personal data, or personal information, which means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).
We may collect, use, store and transfer different kinds of personal data about you, which we have grouped together as follows:
1.1 Information that you give to us directly: You may give us the following data when you apply for our services, subscribe to our service or publications, request marketing to be sent to you, give us feedback or contact us:
Identity Data: Includes first name, maiden name, last name, username or similar identifier, marital status, title, date of birth and gender.
Contact Data: Includes billing address, payment details, delivery address, email address and telephone numbers.
Sensitive Data: Includes information about your health, any adverse events*, treatments, or care pathways, ethnicity, sexual orientation, sex life, religious beliefs or opinion or genetic data where this is relevant to your health assessment, or the services you are obtaining from us.
Updates: Includes any updates or changes you provide to us.
Surveys and Feedbacks: Includes responses that we might ask you to complete for research purposes.
Marketing and Communications Data: Includes your preferences in receiving marketing from our third parties, your communication preferences, and us.
*Adverse Events: An unexpected medical problem that happens during treatment with a drug or other therapy. Adverse events may be mild, moderate, or severe, and may be caused by something other than the drug or therapy being given. Also called adverse effect.
Technical Data: Includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access this website.
Usage Data: Includes information about how you use our website, products and services.
1.3 Information that we collect from third parties or publicly available sources:
I. Health Diagnosis, Doctor Commentaries on test´s results and others: From business partners, GPs, expert clinicians, pharmacies, suppliers and subcontractors.
II. Technical Data: From analytics, providers such as Google based outside the EU and search information providers based inside the EU.
III. Contact, Financial and Transaction Data: from providers of technical, payment and delivery services inside the EU; Identity and Contact Data from data brokers or aggregators based inside the EU; Identity and Contact Data from publicly available sources such as Companies House and the Electoral Register based inside the EU.
We may collect any Sensitive Data (Special Categories of Personal Data) about you, including your race or ethnicity, sex life, sexual orientation, genetic and biometric data. However, we will not collect details about religious or philosophical beliefs, political opinions and trade union membership that are not relevant to your health assessment, or the services you are obtaining from us.
All personal information that you provide to us must be true, complete and accurate, and you must notify us of any changes to such personal information by sending it by email to our data privacy officer: firstname.lastname@example.org or contact us.
2. IF YOU FAIL TO PROVIDE YOUR PERSONAL DATA?
Where we need to collect your personal data by law, or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with goods or services). In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time
3. HOW DO WE USE YOUR DATA?
We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:
3.1 Where you have given us your consent to process your personal information for a specific purpose.
3.2 Where we need to perform the contract, we are about to enter into or have entered into with you.
3.3 Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
3.4 Where we need to comply with a legal obligation.
3.5 Where we need to use it to provide health or social care purposes, or which could be deemed to be in the public interest or to serve a substantial public interest.
4. PURPOSES FOR WHICH WE WILL USE YOUR PERSONAL DATA
We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.
Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us to email@example.com if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below:
4.1 Provision of Our Services: To deliver our consulting services, we need to share your personal information with our Expert Clinicians (including GPs and pharmacists) so that we can provide our services to you (e.g. our consultation services). Only those Expert Clinicians and personnel who need access to such information to perform their responsibilities are allowed access.
We may also need to share information with other partner organisations that help administer our services (e.g Doctors and Pharmacists). We have vetted these organisations to ensure that they will deal with your personal information responsibly. We do not allow these partner organisations to use your personal information for their own purposes. We only permit them to use your personal information in accordance with our instructions.
On occasion, we may be required to share information with regulators like the Care Quality Commission, the General Medical Council, the Information Commissioner’s Office, the Health Service Ombudsman, or the Medicines, Healthcare Products Regulatory Agency (MHRA).
[With your agreement, information can be shared with relatives, partners or friends who act as a carer for you. We will only share information once the person you have asked us to share the information with has provided us with proof of their identity. We may share information with anyone you have given as an emergency contact, for example your next of kin.
4.2 Marketing: We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you (we call this marketing). You will receive marketing communications from us if you have requested information from us or purchased services from us and you have asked to receive information and/or marketing from us.
4.3 Third-Party Marketing: We will get your express opt-in consent before we share your personal data with any third party for marketing purposes.
4.4 Opting out: You can ask us or third parties to stop sending you marketing messages at any time. Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us because of a service purchase, warranty registration, service experience or other transactions.
4.5 Change of Purpose: We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us by emailing our data privacy officer: firstname.lastname@example.org .
If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis, which allows us to do so.
Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by the law.
5. DISCLOSURES OF YOUR PERSONAL DATA?
We may share your personal data with the parties set out below for the purposes set out in the table above, with Internal and External Third Parties as follows:
5.1 Our service providers and sub-contractors, including but not limited to payment processors, suppliers of technical and support services and cloud service providers, including our expert clinicians, doctors and pharmacists.
5.2 In rare circumstances such as the police, fire, ambulance, rescue service, and public health bodies, where there is a material risk to your health or the public at large.
5.3 Companies that assist us in our marketing, advertising and promotional activities.
5.4 Analytics and search engine providers that assist us in the improvement and optimisation of our Website
5.5 Any third parties that you have agreed that we may share your personal information with for marketing purposes.
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 specified purposes and in accordance with our instructions
6. WHERE DO WE STORE YOUR DATA?
We store your data in the UK.
We may transfer your personal information outside the United Kingdom (UK) and European Economic Area (EEA) in the event we have a legitimate need to do so. Such countries may not have the same data protection laws as the UK and EEA. While the European Commission has not given a formal decision that such countries provide an adequate level of data protection similar to those which apply in the UK and EEA, any transfer of your personal information will be subject to us providing appropriate, suitable and relevant safeguards as approved by the European Commission (as permitted under Article 46(5) of the General Data Protection Regulation) that are designed to help safeguard your privacy rights and give you remedies in the unlikely event of a misuse of your personal information.
7. DATA SECURITY
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.
8. DATA RETENTION - HOW LONG ARE WE GOING TO USE YOUR PERSONAL DATA FOR?
We will only retain your personal information for as long as we need it unless we are required to keep it for longer to comply with our legal, accounting or regulatory requirements.
We will delete dormant accounts after 3 years of no activity. We will anonymise and keep any health assessments indefinitely in order to comply with our legal and regulatory obligations. We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe, there is a prospect of litigation in respect to our relationship with you.
To determine the appropriate retention period for personal data, we consider: the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.
By law, we have to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for six years after they cease being customers for tax purposes.
In some circumstances, you can ask us to delete your data: see your legal rights below for further information.
In some circumstances we will anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.
9. YOUR LEGAL RIGHTS
9.1 Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
9.2 Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
9.3 Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with our legal obligations. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons, which will be notified to you, if applicable, at the time of your request.
9.4 Object to processing of your personal data where we are 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 as you feel it affects your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information, which override your rights and freedoms.
9.5 Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios:
• If you want us to establish the data’s accuracy.
• Where our use of the data is unlawful but you do not want us to erase it.
• Where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims.
• You have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
9.6 Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
9.7 Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.
If you wish to exercise any of the rights set out above, please contact us by emailing our data privacy officer: email@example.com
10. COOKIES POLICY
11. THIRD-PARTY LINKS
Throughout our website, we may link to other websites owned and operated by certain trusted third parties to make additional services available to you. Once you leave our site and go to such third party websites, we do not have any control over, nor do we warrant any of the information contained on that site, or how your personal information and data is used, nor do we have any legal liability regarding your use of, the content with that that website or how that website uses your personal data. These other third party websites may also gather information about you in accordance with their own separate privacy policies. For privacy information relating to these other third party websites, please consult their privacy policies as appropriate.
12. CHANGES TO YOUR PERSONAL DATA
It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.
13. CONTACT DETAILS
You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). Nonetheless, we would appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.