We collect, use and are responsible for certain personal information about you. When we do so we are subject to the General Data Protection Regulation, which applies across the European Union (including in the United Kingdom) and we are responsible as ‘controller’ of that personal information for the purposes of those laws.
We have appointed a Data Protection Officer (DPO), who helps to make sure we apply the highest standards to protecting and safeguarding your personal information. Our DPO can be reached by email on [email protected] or by mail at 5 City Garden Row, N1 8DW London, United Kingdom if you have any questions about how we use or store your personal information.
Personal information we collect about you
We may collect and use the following personal information about you. This personal information is required to provide products and services to you. If you do not provide personal information we ask for, it may delay or prevent us from processing your order.
- your name, date of birth, gender, and contact information, including email address, delivery details and telephone number
- information about your health and medical history submitted when you complete a consultation questionnaire
- your payment details
- your purchase history
How your personal information is collected We collect most of this personal information directly from you:
- when you contact us by email, via our live-chat feature on the website, and/or over the phone when you call us
- when you provide us with personal health and medical information by filling out an online questionnaire
- when you place an order and provide us with payment and delivery details
However, we may also collect information automatically when you visit our website:
- from Internet Protocol (“IP”) addresses to gather non-personal information, such as the regions that users visit our website from
- from IP addresses as an additional security feature to ensure only you can access your account
- from cookies on our website
- via our IT systems, e.g.: automated monitoring of our websites and other technical systems, such as our computer networks and connections and email
How we use your personal information
The below explains what we use (process) your personal information for and our reasons for doing so:
- Account registration: we will use your personal information such as name and contact details to register an account with us if you wish to do so.
- Medical assessment: we will use your personal information such as date of birth, gender and medical history to assess if our products are safe and suitable for you to use.
- Provision of products and services: we will use your personal information to fulfil our contractual obligations to deliver products to you and provide you with customer support.
- Prevention and protection of fraud: for our interests or those of our payment provider we will use your personal information to minimise fraud that could be damaging for us and for you.
- Compliance with professional, legal, and regulatory obligations: we may process personal information if we are required to do so to comply with laws and regulations.
- Improving efficiency, training, and quality control: we may process your personal information (including recording of calls), to improve our services and products to you and to ensure we deliver the best services possible. We may also use your information to personalise or customise our website to improve your experience with our services.
- Feedback: if you voluntarily provide us with feedback about our website we may use your personal information to improve our website, products or services we provide.
- Communication and marketing: provided that we have your consent, we may use your information to tell you about changes on our website, or our products and services. Please see section ‘Promotional communications’ on how to remove the consent if you no longer wish to be informed about these updates.
We may use your personal information to send you updates (by email, SMS, telephone, or post) about our products and services, including exclusive offers, promotions or new products. We will always treat your personal information with the utmost respect and never share it with other organisations for marketing purposes. You have the right to opt out of receiving promotional communications at any time by contacting us at [email protected] or using the ‘unsubscribe’ link in our emails. We may ask you to confirm or update your marketing preferences if you instruct us to provide further products in the future, or if there are changes in the law, regulation, or the structure of our business.
Who we share your personal information with
Personal information about your health or your medical history is only shared with a very selected number of people at Satio Pharma Ltd and Oasis Pharmacy, our partner pharmacy. For example, our pharmacists need certain information to assess the right treatment for you. Other than a very selected number of people at our partner pharmacy, we will never share personal information about your health or your medical history with third parties unless we are compelled to do so by law. In order to provide you with our services and products, we need to share certain personal information with some selected third parties. Note that we only share information that is absolutely necessary, and we make sure everyone we work with takes your privacy as seriously as we do. We only allow our service providers to handle your personal information if we are satisfied that they take appropriate measures to protect your personal information. We also impose contractual obligations on service providers relating to ensure they can only use your personal information to provide services to us and to you. We routinely share data with third parties who help us deliver our services and products to you:
- Payment service providers (e.g. SagePay) to process your payments (incl. fraud checks)
- Logistical providers (e.g. Royal Mail) to deliver our products
- Email and SMS providers (e.g. MailChimp) to send you notifications about your order status
- Customer Relationship Management tools (e.g. Intercom) to offer you customer support services
- Data storage providers to store your data securely
To help us improve our services and products and for the purpose of marketing, we share information with certain third party providers:
- Data collection & analysis software (e.g. Google Analytics) to improve the use and efficiency of our website
- Email service providers (e.g. MailChimp) to send you marketing emails
From time to we may have to share some personal information for legal reasons:
- We may disclose data with a future buyer if we decide to sell all or parts of this business. The recipient of the information will be bound by confidentiality obligations.
- We may disclose and exchange information with law enforcement agencies and regulatory bodies to comply with our legal and regulatory obligations or if we are compelled by law.
Our legal basis for using and storing your personal
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/or regulatory obligations;
- for the performance of our contract with you;
- for our legitimate interests, e.g. to contact you about new products or services;
- where you have given consent.
See section ‘Your privacy rights’ for details about how to withdraw your consent for marketing purposes.
Where your personal information is held
Information may be held at our offices and those of our service providers, as described above (see above: ‘Who we share your personal information with’). Some of these third parties may be based outside the European Economic Area. For more information, including on how we safeguard your personal information when this occurs, see below: ‘Transferring your personal information out of the EEA’.
How long your personal information will be kept
We will keep your personal information while you have an account with us or we are providing products to you. Thereafter, we will keep your personal information for as long as is necessary:
- to respond to any questions, complaints or claims made by you or on your behalf;
- to show that we treated you fairly;
- to keep records required by law.
We will not retain your personal information for longer than necessary for the purposes set out in this policy. Different retention periods apply for different types of personal information.
Transferring your personal information out of the EEA
To deliver services to you, it is sometimes necessary for us to share your personal information outside the European Economic Area (EEA), e.g.:
- with our service providers located outside the EEA;
- if you are based outside the EEA.
These transfers are subject to special rules under European and UK data protection law. These non-EEA countries do not have the same data protection laws as the United Kingdom and EEA. We will, however, ensure the transfer complies with data protection law and all personal information will be secure. Our standard practice is to use standard data protection contract clauses that have been approved by the European Commission.
Your privacy rights
You have the following rights, which you can exercise free of charge:
- Access: The right to be provided with a copy of your personal information (the right of access);
- Rectification: The right to require us to correct any mistakes in your personal information;
- Right to be forgotten: The right to require us to delete your personal information – in certain situations. For legal reasons we need to store your medical data and any communications about your treatments for the foreseeable future. Such data cannot, therefore, be deleted;
- Restriction of processing: The right to require us to restrict processing of your personal information – in certain circumstances, e.g. if you contest the accuracy of the data;
- Data portability: The right to receive the personal information you provided to us, in a structured, commonly used and machine-readable format and/or transmit that data to a third party;
- Right to object:
- at any time to your personal information being processed for direct marketing (including profiling);
- in certain other situations to our continued processing of your personal information, e.g. processing carried out for the purpose of our legitimate interests.
- Right not to be subject to automated individual decision-making: the right not to be subject to a decision based solely on automated processing (including profiling) that produces legal effects concerning you or similarly significantly affects you
For further information on each of those rights, including the circumstances in which they apply, please contact us or see the Guidance from the UK Information Commissioner’s Office (ICO) on individuals’ rights under the General Data Protection Regulation. If you would like to exercise any of those rights, please write to us at 5 City Garden Row, N1 8DW London, United Kingdom or email us at [email protected] or contact our Data Protection Officer directly at [email protected] Please make sure to include the following information:
- information to identify you (e.g. your full name, address, and if available, your order reference number);
- what right you want to exercise and the information to which your request relates.
Keeping your personal information secure
We have appropriate security measures to prevent personal information from being accidentally lost, or used or accessed unlawfully. We limit access to your personal information to those who have a genuine business need to access it. Those processing your information will do so only in an authorised manner and are subject to a duty of confidentiality. We also have procedures in place to deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected data security 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 www.getsafeonline.org. Get Safe Online is supported by HM Government and leading businesses.
How to complain
We hope that our Data Protection Officer can resolve any query or concern you may raise about our use of your information. The General Data Protection Regulation also gives you right to lodge a complaint with a supervisory authority, in particular in the European Union (or European Economic Area) state where you work, normally live or where any alleged infringement of data protection laws occurred. The supervisory authority in the UK is the Information Commissioner who may be contacted at https://ico.org.uk/concerns or telephone: 0303 123 1113.
This privacy notice was published on 10th August 2018 and last updated on 17th October 2018. We may change this privacy notice from time to time – when we do we will inform you by issuing a notice on our website.