We at (med)24 Ltd understand that your privacy is important to you & that you care about how your personal data is used & shared online. We respect & value the privacy of our Clients & everyone else who visits this website, www.med24.clinic (“our Site”) & will only collect & use personal data in ways that are described here, & in a manner that is consistent with our obligations & your rights under the law.
The procedures & principles set out in this Policy will be followed at all times by us as a company, as well as any other parties working on our behalf.
This Policy (v1.0) shall be deemed effective as of 7th August 2020. No part of this Policy shall have retroactive effect & shall thus apply only to matters occurring on or after this date.
Please read this Privacy Policy carefully & ensure that you understand it. You are deemed to have accepted our Privacy Policy when you first use our Site. If you do not accept & agree with this Privacy Policy, you must stop using our Site immediately.
We are registered under the ICO under number ZA612235 & our data compliance team can be contacted by email at compliance@med24.clinic or by post to 3rd Floor 1 Ashley Road, Altrincham, Cheshire, United Kingdom, WA14 2DT.
1. Definitions & Interpretation
In this Policy, the following terms have the following meanings:
“Client” means any individual, firm or corporate body to which we provide our services;
“Cookie” means a small text file placed on your computer or device by our Site when you visit certain parts of our Site &/or when you use certain features of our Site. Details of the Cookies used by our Site are set out in section 12 (use of cookies), below;
“Data Protection Legislation” means the General Data Protection Regulation ((EU) 2016/679), the Data Protection Act 2018 & successor legislation
“Personal data” means any & all data that relates to an identifiable person who can be directly or indirectly identified from that data. In this case, it means personal data that you give to us by becoming a Client of ours or by visiting our Site. This definition shall, where applicable, incorporate the definitions provided in the Data Protection Legislation; &
“We/Us/Our” means (med)24 Ltd, a company registered in England & Wales under company number 11652936, whose registered address is 3rd Floor 1 Ashley Road, Altrincham, Cheshire, United Kingdom, WA14 2DT.
2. What Does This Policy Cover?
- This Privacy Policy applies to our use of personal data collected when you become a Client of ours, when you enquire about our services or when you visit our Site.
- Our Site may contain links to other websites, including social media links. Please note that we have no control over how your data is collected, stored, or used by other websites & we advise you to check the privacy policies of any such websites before providing any data to them.
3. Your Rights
- As a data subject, you have the following rights under the Data Protection Legislation, which this Policy & our use of personal data have been designed to uphold:
1.0. The right to be informed about our collection & use of personal data;
1.1. The right of access to the personal data we hold about you (see section 11);
1.2. The right to rectification if any personal data we hold about you is inaccurate or incomplete (please contact us using the details in section 13);
1.3. The right to be forgotten – i.e. the right to ask us to delete any personal data we hold about you (we only hold your personal data for a limited time, as explained in section 5 but if you would like us to delete it sooner, please contact us using the details in section 13);
1.3.0 The right to restrict (i.e. prevent) the processing of your personal data;
1.3.1. The right to data portability (obtaining a copy of your personal data to re-use with another service or organisation);
1.3.2. The right to object to us using your personal data for particular purposes; &
1.3.3. Rights with respect to automated decision making & profiling.
- If you have any cause for complaint about our use of your personal data, please contact us using the details provided in section 13 & we will do our best to solve the problem for you. If we are unable to help, you also have the right to lodge a complaint with the UK’s supervisory authority, the Information Commissioner’s Office.
- For further information about your rights, please contact the Information Commissioner’s Office or your local Citizens’ Advice Bureau.
4. What Data Do We Collect?
- If you are a Client of ours, we will collect some or all of the following personal data in order for us to provide our services to you;
1.0. Your name;
1.1. Contact information including email address, & telephone number;
1.2. Billing details;
1.3. Insurance details;
1.4. Date of birth;
1.5. Gender & ethnicity;
1.6. Medical history.
- If you have enquired about our services or are otherwise a business contact of ours, we may collect some or all of the following personal data in order for us to provide our services &/or where we have received consent to do so:
2.0. Your name;
2.1. Contact information including email address, postal address & telephone number;
2.2. Date of birth;
2.3. Gender & ethnicity;
2.4. Medical history.
- If you visit our Site, we may collect some or all of the following personal data. Please refer to section 12 below regarding Cookies:
3.0. Your name & email address, if you complete our contact form;
3.1. Any login information if applicable;
3.2. Any information uploaded through our document upload portal;
3.3. Demographic information such as post code, preferences, & interests;
3.4. IP address;
3.5. Web browser type & version & operating system; &
3.6. Information about your visit, including but not limited to: products you viewed or searched for, page response times, website errors, length of visits to certain pages, page interaction information, methods used to browse away from the page & any phone number used to call our helpline.
Should you use our Site on behalf of another person, it shall be your responsibility to ensure you have gained express consent to transfer their personal data to us.
Please note our site may ask you for payment details, such as billing information or credit or debit card information, however all payments made on our website will go through a third party processor & as such, we shall have no access to this data. A separate contractual relationship shall be created between you & the payment processor on their terms & conditions & we cannot be held liable for any errors, actions, omissions or incorrect charges that may be made by them.
5. How Do We Use Your Data?
- All personal data is processed & stored securely, for no longer than is necessary or statutorily required in light of the reason(s) for which it was first collected. We will comply with our obligations & safeguard your rights under the Data Protection Legislation at all times. For more details on security see section 6, below.
- Our use of your personal data will always have a lawful basis, either because it is necessary for our performance of a contract with you, because you have consented to our use of your personal data (e.g. by providing an email address &/or phone number), or because it is in our legitimate interests. Specifically, we may use your data for the following purposes:
- Providing & managing your access to our Site;
- Personalising & tailoring your experience on our Site;
- Supplying our services to you (please note that we require your personal data in order to enter into a contract with you);
- Replying to emails & text messages from you;
- Supplying you with emails & text messages that you have opted into (you may unsubscribe or opt-out at any time by emailing us directly);
- Notify you of products & services that we feel may interest you;
- Analysing your use of our Site to enable us to continually improve our Site & your user experience;
- To notify you about changes to our services or our terms & conditions.
- With your permission &/or where permitted by law, we may also use your data for marketing purposes which may include contacting you by email with information, news & offers on our services. We will not, however, send you any unsolicited marketing or spam & will take all reasonable steps to ensure that we fully protect your rights & comply with our obligations under the Data Protection Legislation & the Privacy & Electronic Communications (EC Directive) Regulations 2003.
- Third parties whose content appears on our Site may use third party Cookies, as detailed below in section 12. Please refer to section 12 for more information on controlling Cookies. Please note that we do not control the activities of such third parties, nor the data they collect & use & advise you to check the privacy policies of any such third parties.
- You have the right to withdraw your consent to us using your personal data at any time, & to request that we delete it. Unless we have reasonable grounds to refuse to delete it (where this is permitted under the Data Protection Legislation), we will do so without delay & within no longer than one month from receiving your request.
- We do not keep your personal data for any longer than is necessary in light of the reason(s) for which it was first collected.
6. How & Where Do We Store Your Data?
- We only keep your Personal Data for as long as we need to in order to use it as described above in sections 4 & 5, &/or for as long as we have your permission to keep it.
- We will only store your data in our secure encrypted systems, details available on request. Where these are located outside of the European Economic Area (“the EEA”) (The EEA consists of all EU member states, plus Norway, Iceland, & Liechtenstein) we shall take all reasonable steps to ensure that your data is treated as safely & securely as it would be within the UK & under the Data Protection Legislation.
- Data security is very important to us & to protect your data, we have taken suitable measures to safeguard & secure data collected. The website is protected by various levels of security technology, which are designed to protect your information from any unauthorised or unlawful access, processing, accidental loss, destruction & damage.
7. Do We Share Your Data?
- We may share your personal information with any member of our group, which means our subsidiaries, our ultimate holding company & its subsidiaries, as defined in section 1159 of the Companies Act 2006.
- We may sometimes contract with other third parties to supply services to you on our behalf. In some cases, these third parties may require access to some or all of your data. Where any of your data is required for such a purpose, we will take all reasonable steps to ensure that your data will be handled safely, securely, & in accordance with your rights, our obligations, & the obligations of the third party under the law.
- We may compile statistics about the use of our Site including data on traffic, usage patterns, user numbers, & other information. All such data will be anonymised & will not include any personally identifying data, or any anonymised data that can be combined with other data & used to identify you. We may from time to time share such data with third parties such as prospective investors, affiliates, partners, & advertisers. Data will only be shared & used within the bounds of the law.
- We may use third party data processors that are located outside of the European Economic Area (“the EEA”) (The EEA consists of all EU member states, plus Norway, Iceland, & Liechtenstein). Where we transfer any personal data outside the EEA, we will take all reasonable steps to ensure that your data is treated as safely & securely as it would be within the UK & under the Data Protection Legislation.
- In certain circumstances, we may be legally required to share certain data held by us, which may include your personal data, for example, where we are involved in legal proceedings, where we are complying with legal requirements, a court order, or a governmental authority.
8. What Happens If Our Business Changes Hands?
- We may, from time to time, expand or reduce our business & this may involve the sale &/or the transfer of control of all or part of our business. Any personal data that you have provided will, where it is relevant to any part of our business that is being transferred, be transferred along with that part & the new owner or newly controlling party will, under the terms of this Privacy Policy, be permitted to use that data only for the same purposes for which it was originally collected by us.
- In the event that any of your data is to be transferred in such a manner, you will not be contacted in advance & informed of the changes.
9. How Can You Control Your Data?
- In addition to your rights under the Data Protection Legislation, set out in section 3, when you submit personal data to us via email or via our Site, you may be given options to restrict our use of your data. In particular, we aim to give you strong controls on our use of your data for direct marketing purposes (including the ability to opt-out of receiving emails from us).
- You may also wish to sign up to one or more of the preference services operating in the UK: The Telephone Preference Service (“the TPS”), the Corporate Telephone Preference Service (“the CTPS”), & the Mailing Preference Service (“the MPS”). These may help to prevent you receiving unsolicited marketing. Please note, however, that these services will not prevent you from receiving marketing communications that you have consented to receiving.
10. Your Right to Withhold Information
- You may access certain areas of our Site without providing any data at all. However, to use all features & functions available on our Site you may be required to submit or allow for the collection of certain data.
- You may restrict our use of Cookies. You can choose to enable or disable Cookies in your internet browser. Most internet browsers also enable you to choose whether you wish to disable all cookies or only third party Cookies. By default, most internet browsers accept Cookies but this can be changed. For further details, please consult the help menu in your internet browser or the documentation that came with your device.
11. How Can You Access Your Data?
You have the right to ask for a copy of any of your personal data held by us (where such data is held). Please contact us for more details using the contact details below in section 13.
12. Our Use of Cookies
- Cookies are small text files which a website may put on your computer or mobile device when you first visit the website. These cookies will help the website recognise your device the next time you visit.
- All Cookies used by & on our Site are used in accordance with current Cookie law.
- We may place & access the following first party & third party Cookies on your computer or device, to facilitate & improve your experience of our Site & to provide & improve our services:
- First party Cookies are those placed directly by us & are used only by us. Third party Cookies are those placed by websites, services, &/or parties other than us. These Cookies are not integral to the functioning of our Site & your use & experience of our Site will not be impaired by refusing consent to them.
- Before Cookies are placed on your computer or device, you will be shown a pop-up requesting your consent to set those Cookies. By giving your consent to the placing of Cookies, you are enabling us to provide the best possible experience & service to you. You may, if you wish, deny consent to the placing of Cookies; however certain features of our Site may not function fully or as intended.
- Certain features of our Site depend on Cookies to function. Cookie Law deems these Cookies to be “strictly necessary”. These Cookies are also shown above. Your consent will not be sought to place these Cookies, but it is still important that you are aware of them. You may still block these Cookies by changing your internet browser’s settings as detailed in section 10.2, but please be aware that our Site may not work properly if you do so. We have taken great care to ensure that your privacy is not at risk by allowing them.
- You can choose to delete Cookies on your computer or device at any time, however you may lose any information that enables you to access our Site more quickly & efficiently.
- It is recommended that you keep your internet browser & operating system up-to-date & that you consult the help & guidance provided by the developer of your internet browser & manufacturer of your computer or device if you are unsure about adjusting your privacy settings.
- Our Site uses Google Analytics. Website analytics refers to a set of tools used to collect & analyse anonymous usage information, enabling us to better underst& how our Site is used. This, in turn, enables us to improve our Site & the services offered through it. You do not have to allow us to use these Cookies, however whilst our use of them does not pose any risk to your privacy or your safe use of our Site, it does enable us to continually improve our Site, making it a better & more useful experience for you. Google's privacy policy is available at: https://www.google.com/policies/privacy/
- We use a cookie on our site which tracks visitors using the Site to advertise particular information on their first time accessing the Site; all additional cookies through the Site are standard Shopify cookies. For full information about these types of cookies & other tracking technologies that we may place on your device, please visit https://www.shopify.co.uk/legal/cookies
13. Contacting Us
If you have any questions or complaints about our Site or this Privacy Policy, please contact us by email at compliance@med24.clinic. Please ensure that your query is clear, particularly if it is a request for information about the data we hold about you (as under section 11, above). You also have the right to complain to the relevant supervisory authority in your jurisdiction. In the UK, the supervisory authority is the Information Commissioner's Office. Contact details for the ICO can be found at https://ico.org.uk/
14. Changes to Our Privacy Policy
We may change this Privacy Policy from time to time (for example, if the law changes). Any changes will be immediately posted on our Site & you will be deemed to have accepted the terms of the Privacy Policy on your first use of our Site following the alterations. We recommend that you check this page regularly to keep up-to-date.