2. THE DATA WE COLLECT ABOUT YOU
Personal data, or personal information, 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:
Identity Data includes first name, last name, title, date of birth, staff or patient number
Contact Data includes billing addresses, email addresses, and telephone numbers.
Transaction Data includes details about payments to and from you and other details of products and services you have purchased from us.
Health Data includes age, gender, height, weight, current health conditions; smoking, alcohol and other habits, health background, medical history (previous or planned operations), adverse events, symptoms, secondary effects, past and medication (drugs and therapies), and past, current or new results from blood and other tests.
Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.
We also collect, use, and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity.
We do not collect Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership). Nor do we collect any information about criminal convictions and offences.
3. IF YOU FAIL TO PROVIDE PERSONAL DATA
Where we need to collect 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 the services on our Platform). In this case, we may have to cancel your account on our Platform, but we will notify you if this is the case at the time.
4. HOW IS YOUR PERSONAL DATA COLLECTED?
We use different methods to collect data from and about you including through:
Direct interactions. You may give us your data by filling in forms when you sign up to our Platform or use our services on our Platform. This includes personal data you provide when you:
apply for our services;
request marketing to be sent to you; or
give feedback or contact us.
5. DATA FROM MINORS
We do not knowingly solicit data from or market to children under the age of 18 years. By using the Platform, you represent that you are at least 18 or that you are the parent or guardian of such a minor and consent to such minor dependent’s use of the Platform. If we learn that personal information from users less than 18 years of age has been collected, we will deactivate the account and take reasonable measures to promptly delete such data from our records. If you become aware of any data we have collected from children under age 18, please contact us at email@example.com. Any access by minors shall only be with the consent of a guardian who is representing the minor in entering into this legally binding agreement. Any access to or use of the Site or Platform by anyone under 18 or without the express consent of their guardian is expressly prohibited. By accessing or using the Site or Platform you represent and warrant that you are 18 or older or that you have an adult representative.
6. HOW WE USE YOUR PERSONAL DATA
We will use your information to provide and personalise our service. As you are signing up to our Platform and for the services that come with it, it is in the course of performing our contract with you that we will collect and use your personal data.
We will only ever use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:
Where we need to perform the contract, we are about to enter into or have entered into with you.
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.
Where we need to comply with a legal obligation.
Generally, we do not rely on consent as a legal basis for processing your personal data although we will get your consent before sending third party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us.
Please note that there may be instances where it may be necessary for us to communicate with you, in any event, for medical, administrative or operational reasons relating to our service that you have signed up to.
7. HOW LONG WILL YOU USE MY PERSONAL DATA FOR?
We will only retain your personal data for as long as reasonably necessary to fulfill 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.
8. OPTING OUT
You can ask us to stop sending you marketing messages at any time by adjusting your marketing preferences or by following the opt-out links on any marketing message sent to you or by contacting us at any time.
Where you opt-out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a product/service purchase, product/service experience, or other transactions.
9. CALIFORNIAN SPECIFIC LAWS
The California Civil Code Section 1798.83, allows all users who reside in California to request and obtain from us, once a year and free of charge, information about categories of personal information (if any) we disclosed to third parties for direct marketing purposes and the names and addresses of all third parties with which we shared personal information in the previous year. If you are a Californian resident and would like to make such a request, please submit your request in writing to us at our email address firstname.lastname@example.org.
10. SECURITY OF YOUR PERSONAL INFORMATION
We are committed to keeping the personal information you provide us secure and we will take reasonable precautions to protect your personal information from loss, misuse, or alteration.
We have implemented information security policies, rules, and technical measures to protect the personal information that we have under our control from:
improper use or disclosure;
unauthorised modification; and
unlawful destruction or accidental loss.
All our employees and data processors (i.e. those who process your personal information on our behalf, for the purposes listed above), who have access to, and are associated with the processing of personal information, are obliged to respect the confidentiality of the personal information.
Last updated August 2020