Data Protection and Privacy Policy

Purpose of this data protection and privacy policy

We are committed to protecting the privacy and security of your personal information.

Please read this data protection and privacy policy carefully as it contains important information on who we are and how and why we collect, store, use and share your personal information. It also explains your rights in relation to your personal information and how to contact us or supervisory authorities in the event you have a complaint.

We are a "data controller". This means that we are responsible for deciding how we hold and use personal information about you. We are required under data protection legislation to notify you of the information contained in this privacy notice.

It is important that you read this policy together with any other privacy notice or fair processing notice we may provide on specific occasions when we are collecting or processing personal information about you. This policy supplements the other notices and is not intended to override them.

By submitting your personal information to us, you are consenting to the processing of your personal information by us in accordance with this privacy policy and any other privacy notice we may provide on specific occasions. In particular you acknowledge and consent that the personal information we collect from you may be transferred to, processed and stored by us at destinations outside the European Economic Area (EEA).

This Website is not intended for children and we do not knowingly collect data relating to children.

Data protection principles

We will comply with data protection law. This says that the personal information we hold about you must be:

  • Used lawfully, fairly and in a transparent way.

  • Collected only for valid purposes that we have clearly explained to you and not used in any way that is incompatible with those purposes.

  • Relevant to the purposes we have told you about and limited only to those purposes.

  • Accurate and kept up to date.

  • Kept only as long as necessary for the purposes we have told you about.

  • Kept securely.

This policy is set out in a layered format with the below headings.

  • important information and who we are

  • personal information we collect about you

  • how your personal information is collected

  • how and why we use your personal information

  • promotional communications

  • who we share your personal information with

  • where your personal information is held

  • how long your personal information will be kept

  • transferring your personal information out of the EEA

  • your rights

  • keeping your personal information secure

  • how to complain

  • how to contact us

01. Important information and who we are

Controller

Practio UK Ltd is a limited company, registered under company number 11705491 whose registered office is at Edward Pavillion, Albert Dock, Liverpool, England, L3 4AF (Practio). Practio UK Ltd is in the Data protection register of the Information Commissioner's Office (ICO) with the registration number ZA798291.

We are wholly owned by Practio ApS (company registration number 36392576) located in Copenhagen, Denmark.

Practio is the data controller for the purposes of the personal information we have collected and processed through your use of our Website, devices, services and applications that reference this policy or for the provision of any services to you.

If you have any questions about this policy, including any requests to exercise your legal rights, please contact us (see ‘How to contact us’ below).

Please note that for the provision of any services to you we will share your personal information with our pharmacy partners or with other third parties (see further details in section 6 of this policy). Our pharmacy partners and other third parties will in most cases be data controllers in their own right. This means that these other parties will process your personal information in accordance with their own privacy policy and you need to check their privacy policies for more information on how they process your personal information.

Changes to the privacy policy and your duty to inform us of changes

Our business and the content or services provided by us may be changed in the future and consequently this policy may also change. Any changes we may make to this policy in the future will be posted on this webpage and where appropriate, notified to you by email. We recommend that you re-visit this page regularly to see any updates or changes to our policy.

It is important that the personal information we hold about you is accurate and current. Please keep us informed if your personal information changes during your relationship with us.

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 policy of the websites you visit.

Key terms

It would be helpful to start by explaining some key terms used in this policy:

You, your: Identifiable individuals, including those associated with our business clients

We, us, our: Practio UK LTD is a limited company, registered under company number 11705491 whose registered office is at Edward Pavillion, Albert Dock, Liverpool, England, L3 4AF and our group companies

Personal information: Any information relating to an identified or identifiable individual

02. Personal information we collect about you

Non-Special Category of Personal 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 your name, username or similar identifier, title, date of birth, gender and other information to enable us to check and verify your identity.

  • Contact Data includes billing address, delivery address, email address, telephone numbers and mobile numbers.

  • Financial Data includes bank account details, billing information, transaction and payment card information and other information to enable us to verify the banking, billing, transaction and payment information.

  • Sensitive Personal Data includes your personal health data in relation to our services.

  • Transaction Data includes your contact history, username, purchase history, saved items you have viewed or made enquiries about on our Website, details about payments to and from you and other relevant details of products and services you have purchased or supplied via our business.

  • 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 our Website or applications.

  • Profile Data includes your username and password, purchases or orders made by you, your preferences, feedback, survey responses, reviews and comments on our Website or via our web-applications.

  • Usage Data includes information about how you use our Website, systems, products and services.

  • Marketing and Communications Data includes your preferences in receiving marketing from us, retailer and 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 information but is not considered personal data in law as this data will not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific Website feature.

However, if we combine or connect Aggregated Data with your personal information so that it can directly or indirectly identify you, we treat the combined data as personal information which will be used in accordance with this privacy policy.

Special Categories of Personal Data

This category of data was previously referred to as ‘Sensitive Personal Data'. This type of data is required for the provision of health care services intended to be provided by our Website and via our applications. We may collect:

Medical Data: this may include blood pressure, weight, sexual orientation, glucose levels, test results, repeat prescription information, family information, genetic data, biometric data, medical history or other details contained in your health records.

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 an online consultation). 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.

03. How your personal information is collected

You may give us your Identity, Contact, Medical, and Financial Data by filling in forms on our Website or application or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you subscribe to our services. We collect most of this personal information via direct interactions with you, for example when you interact with us via our Website and web applications, in person, by telephone, text or email.

Automated technologies or interactions

As you interact with our Website, we will automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies. Please see the information regarding cookies in our cookies policy. We may also receive Technical Data about you if you visit other websites employing cookies.

Third parties

We may receive personal data about you from various third parties as set out below:

  • Technical Data from the following parties from analytics providers, such as Google, based outside the EU and from our third party providers for emails and communications.

  • Contact, Financial and Transaction Data from providers of technical, payment and delivery services based inside the EU.

  • Identity and Contact Data from the electoral roll and similar sources.

  • Contact, Identity and Medical Data from third party insurance providers, our pharmacy partners, employers, and other third parties who you provide us access to via your account and from whom we may put a call for data from.

04. How and why we use your personal information

Under data protection law, we can only use your personal information if we have a proper reason for doing so, e.g.:

  • to comply with our legal and regulatory obligations;

  • for the performance of a contract to which you are a party or to take steps at your request before entering into a contract;

  • for our legitimate interests or those of a third party; or

  • where you have given consent.

A legitimate interest is when we have a business or commercial reason to use your information, so long as this is not overridden by your own rights and interests.

Where we use a ‘Special Category’ of data, including Medical Data, we are required to confirm an additional lawful basis (to that set out above) for the processing of such data which will most commonly include the following circumstances:

  • Where processing is necessary for, medical diagnosis, the provision of health or social care or treatment.

  • Express consent that is freely, affirmatively, and transparently, given with regards to the processing described.

In addition to the data protection laws which we adhere to, we also respect the common law right of confidentiality relation to your health and medical data. We will never share your records to any third party not involved in the provision of services (other than our pharmacy partner, your registered GP or if required for the purposes of improving medical care and services – i.e. to the Care Quality Commission) between us unless you expressly consent to us doing so (i.e. for continuity of care). We may also share details with insurers where you consent/request us to do so.

Purposes for which we will use your personal data

We have set out below, 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.

Please 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 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 below.

1 Purpose/Activity To register you as a new user, including sending emails relating to your account set up, status and account credentials. External Third Parties will be used for the hosting of such data. Where you expressly authorise us, we may draw information into your account from authorised third parties .

Type of data (a) Identity (b) Contact

Lawful basis for processing including basis of legitimate interest Performance of a contract with you (i.e. a user subscribing to our service via our Website or application).

2 Purpose/Activity To deliver services to you in the manner of organisation, co-ordination and facilitation of consultations with medical practitioners and for managing payments, fees and charges relating to the same. We may disclose data (including Medical Data) to our medical practitioners and other health care professionals for the purpose of providing you with our services, at our request and direction. External Third Parties may be used for facilitation of payments and hosting.

Type of data (a) Identity (b) Contact (c) Financial (d) Transaction (e) Medical

Lawful basis for processing including basis of legitimate interest (a) Performance of a contract with you (b) Necessary for our legitimate interests (to recover debts due to us) In addition, with regards to Special Data – Medical Data: (a) Performance of a contract with you (i.e. the request for our service) (b) Medical diagnosis, the provision of health or social care or treatment

3 Purpose/Activity To allow for recording and archiving of records of services provided to you and the audit, review, activity monitoring, waiting list management, and production of datasets to submit for commissioning purposes and national collections, including disclosure of the same to the Care Quality Commission. We may process your data to anonymise it for the above purposes.

Type of data (a) Identity (b) Contact (c) Financial (d) Transaction (e) Medical

Lawful basis for processing including basis of legitimate interest (a) For compliance with a legal obligation, being the Care Quality Commission Regulatory framework that applies to all providers of medical and health services. (b) Medical diagnosis, the provision of health or social care or treatment or the management of health or social care systems

4 Purpose/Activity To deliver services to you in the manner of medicine prescription fulfilment, delivery of prescriptions and for managing payments, fees and charges relating to the same. We will disclose data (including Medical Data) to our pharmacy partner for the purpose of providing the vaccination, fulfilling, processing and recording prescriptions. External Third Parties may be used for facilitation of payments and hosting.

Type of data (a) Identity (b) Contact (c) Financial (d) Transaction (e) Medical

Lawful basis for processing including basis of legitimate interest (a) Performance of a contract with you (b) Necessary for our legitimate interests (to recover debts due) In addition, with regards to Special Data – Medical Data: (a) Performance of a contract with you; our pharmacy partner may require disclosure of Medical Data prior to dispensing medicines, and without which, the fulfilment of prescription cannot occur. (b) Medical diagnosis, the provision of health or social care or treatment or the management of health or social care systems.

5 Purpose/Activity To verify with a third party your identity, status of Parental Responsibility (and consent of a child), validity and information regarding private prescriptions as required for regulatory and legal reasons. External Third Parties may be used for verification purposes.

Type of data (a) Identity (b) Contact (c) Financial (d) Transaction (e) Medical

Lawful basis for processing including basis of legitimate interest a) for compliance with a legal obligation being the Care Quality Commission Regulatory framework that applies to all providers of medical and health services. (b) Processing is necessary for reasons ensuring high standards of quality and safety of health care and of medicinal products or medical devices. (c) Processing is necessary to protect the vital interests of the data subject or of another natural person where the data subject is physically or legally incapable of giving consent.

6 Purpose/Activity To internally review and evaluate the quality of services, including ensuring that the quality of live video and audio consultations provided meet or exceed clinical care standards.

Type of data (a) Identity (b) Contact (c) Financial (d) Transaction (e) Medical

Lawful basis for processing including basis of legitimate interest (a) Necessary for our legitimate interests (to improve and better the services provided and, considering your rights, to ensure you and third parties receive the required standard of care) In addition, with regards to Special Data – Medical Data: (a) Necessary for our legitimate interests (to improve and better the services provided and, considering your rights, to ensure you and third parties receive the required standard of care) (b) Medical diagnosis, the provision of health or social care or treatment or the management of health or social care systems

7 Purpose/Activity To manage our relationship with you which will include: (a) Notifying you about changes to our terms or privacy policy (b) Asking you to leave a review or take a survey We may use External Third Parties for the processing of data to assist in sending emails and other correspondence.

Type of data (a) Identity (b) Contact (c) Profile (d) Marketing and Communications

Lawful basis for processing including basis of legitimate interest (a) Performance of a contract with you (b) Necessary to comply with a legal obligation (c) Necessary for our legitimate interests (to keep our records updated and to study how customers use our services)

8 Purpose/Activity To enable you complete a survey or provide feedback. We may use External Third Parties for the processing of data to assist in sending emails and other correspondence.

Type of data (a) Identity (b) Contact (c) Profile (d) Usage (e) Marketing and Communications

Lawful basis for processing including basis of legitimate interest (a) Performance of a contract with you (b) Necessary for our legitimate interests (to study how customers use our products/services, to develop them and grow our business)

9 Purpose/Activity To administer and protect our business and this Website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)

Type of data (a) Identity (b) Contact (c) Technical

Lawful basis for processing including basis of legitimate interest (a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise) (b) Necessary to comply with a legal obligation

10 Purpose/Activity To deliver relevant Website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you

Type of data (a) Identity (b) Contact (c) Profile (d) Usage (e) Marketing and Communications (f) Technical

Lawful basis for processing including basis of legitimate interest Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy)

11 Purpose/Activity To use data analytics to improve our Website, products/services, marketing, customer relationships and experiences

Type of data (a) Technical (b) Usage

Lawful basis for processing including basis of legitimate interest Necessary for our legitimate interests (to define types of customers for our products and services, to keep our Website updated and relevant, to develop our business and to inform our marketing strategy)

12 Purpose/Activity To make suggestions and recommendations to you about services that may be of interest to you

Type of data (a) Identity (b) Contact (c) Technical (d) Usage (e) Profile (f) Marketing and Communications

Lawful basis for processing including basis of legitimate interest Necessary for our legitimate interests (to develop our products/services and grow our business)

05. Promotional communications

We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising. We have established the following personal data control mechanisms:

Promotional offers from us

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 not opted out of receiving that marketing.

Third-party marketing

We will get your express opt-in consent before we share your personal data with any third party for marketing purposes.

Opting out

You can ask us our 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 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 using the services, requesting services, ordering prescriptions, or providing feedback or surveys.

Cookies

We use a technology called ‘Cookies’ across all of its websites and applications in order to deliver the best possible user experience. Cookies are files that are stored on your device each time you visit a website or use an application and enables understanding of your preferences and habits.

Cookies do not contain person-identifiable information such as Medical Data, Identity, Contact Data or Financial Data.

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. For more information about the cookies we use, please see our Cookie policy.

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.

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 law.

06. Who we share your personal information with

We routinely share personal information with:

  • companies within the Practio group of companies;

  • third parties we use to help deliver services to you, e.g. our pharmacy partner, payment service providers, system administration services providers;

  • practitioners, being qualified medical practitioners as regulated and by the General Medical Council, acting as processors based in England and Wales who provide medical consulting services;

  • the regulators in England and Wales, such as the Care Quality Commission, of your health data for fulfilment of regulatory requirements and other national interest uses as it so determines.

  • other third parties we use to help us run our business, e.g. website hosts, IT services providers;

  • third parties approved by you, e.g. third party payment providers;

  • professional advisers including lawyers, bankers, auditors, insurers and insurance brokers who provide consultancy, banking, legal, insurance and accounting services to us;

  • HM Revenue & Customs, regulators and other authorities who require reporting of processing activities in certain circumstances; and

  • our banks.

We only allow service providers processing personal information on our behalf to handle your personal information if we are satisfied they take appropriate measures to protect it. We also impose contractual obligations on such service providers to ensure they can only use your personal information to provide goods and services to you and us.

07. Where your personal information is held

Information may be held at our offices in the UK and those of our group companies, third party agencies, service providers, representatives and agents as described above.

International transfers

Some of our External Third Parties are based in the US outside the European Economic Area (EEA) so their processing of your personal data will involve a transfer of data outside the EEA.

Whenever we transfer your personal data out of the EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

  • We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission. For further details, see European Commission: Adequacy of the protection of personal data in non-EU countries.

  • Where we use certain service providers, we may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe. For further details, see European Commission: Model contracts for the transfer of personal data to third countries.

  • Where we use providers based in the US, we may transfer data to them if they are part of the Privacy Shield which requires them to provide similar protection to personal data shared between Europe and the US. For further details, see European Commission: EU-US Privacy Shield.

Please contact us using the contact details below if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.

08. 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.

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

If you want detailed information from Get Safe Online on how to protect your information and your computers and devices against fraud, identity theft, viruses and many other online problems, please visit https://www.getsafeonline.org/. Get Safe Online is supported by HM Government and leading businesses.

09. Data retention

How long your personal information will be kept

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.

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.

Details of retention periods for different aspects of your personal data are available in our retention policy which you can request from us by contacting us.

Where we have anonymised your personal data (with consent where appropriate) or collected aggregated data for research or statistical purposes, we may continue to use that data indefinitely without further notice to you.

10. Your rights

Under certain circumstances, you have rights under data protection laws in relation to your personal data:

Request access: The right to be provided with a copy of your personal information (the right of access). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.

Request correction: The right to require us to correct any mistakes in your personal information 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.

Request erasure: The right to require us to delete your personal information—in certain situations. 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 local law. 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.

Object to processing: The right to require us to stop processing 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 impacts on 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.

Restriction of processing: The right to require us to restrict processing of your personal information—in certain circumstances. 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.

Request the transfer: The right to transfer 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.

Right to withdraw consent: The right to 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 would like to exercise any of those rights, please contact us using the details below.

No fee usually required

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. Alternatively, we could refuse to comply with your request in these circumstances.

What we may need from you

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.

Time limit to respond

We try to respond to all legitimate requests within one month. Occasionally it could 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 and keep you updated.

11. Keeping your personal information secure

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.

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

12. How to complain

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 (https://ico.org.uk/). We would, however, appreciate the chance to deal with your concerns and resolve any query before you approach the ICO, so please contact us in the first instance.

13. How to contact us

Please contact us by post or email if you have any questions about this privacy policy or the information we hold about you.

Our contact details are shown below:

Practio UK LTD Edward Pavillion, Albert Dock, Liverpool, England, L3 4AF Email at: uk@practio.com