Privacy Policy
AGENTHEALTH.CO.UK PRIVACY POLICY
Updated 24 February 2023
Purpose of this privacy
policy
This
privacy policy aims to give you information on how we collect and process your
personal data through your use of this website, including any data you may
provide through this website when you purchase a product or receive a consultation from us.
Please
read this privacy policy together with any other privacy policy or fair
processing policy we may provide on specific occasions when we are collecting
or processing personal data about you so that you are fully aware of how and
why we are collecting, storing, and using your data. This privacy policy
supplements other notices and privacy policies and is not intended to override
them. This policy also explains your rights in
relation to your personal information and how to contact us or supervisory
authorities if required.
We may
also update and change our site from time to time to reflect changes to our products,
our users' needs and our business priorities.
Please refer to
the Glossary to further understand the meaning of some of the terms used in
this policy.
We have
appointed a DPO who is responsible for overseeing questions in relation to this
privacy policy. If you have any questions about this privacy policy, including
any requests to exercise your legal rights, please contact the DPO using the
details set out below.
Contact
details
If you have any
questions about this privacy policy or our privacy practices, please contact
our DPO in the following ways:
Full name of
legal entity: ClickPharm Ltd
Email address: Clickpharmltd@gmail.com
Postal address: Ground
Floor 5, Building 11, Thames Industrial Park, Princess Margaret Road, East
Tilbury, Essex, RM18 8RH
You have the
right to make a complaint at any time to the Information Commissioner's Office
(ICO), the UK regulator for data protection issues (www.ico.org.uk). We would,
however, appreciate the chance to deal with your concerns before you approach
the ICO so please contact us in the first instance.
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 every website you visit.
Information we may collect
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, maiden name, last name, username or similar
identifier, marital status, title, date of birth and gender.
• Special Categories of Personal
Data includes details about your race or
ethnicity, religious or philosophical beliefs, sex life, sexual orientation,
information about your health, and genetic and biometric data.
• Contact Data includes billing address, delivery address, email address and
telephone numbers.
• Financial Data includes bank account and payment card details.
• Transaction Data includes details about payments to and from you and other details
of products and services you have purchased from us.
• 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.
• Profile Data includes your username and password, purchases or orders made by
you, your interests, preferences, feedback and survey responses.
• Usage Data includes information about how you use our website, products and
services.
• 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. 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 data so
that it can directly or indirectly identify you, we treat the combined data as
personal data which will be used in accordance with this privacy policy.
Third parties
Certain
medications require a prescription. Where this is the case, we may collect
information about you, and pass that information to a registered doctor to help
them assess (including through a consultation, if appropriate) whether they are
able to issue that prescription for you. We work with accredited GMC and
IMC General Practitioners for this part of the process, and you can find more
information about how they process personal data on their website/s.
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 product you have purchased). In this case, we may have
to cancel a product you have purchased with us but we will notify you if this
is the case at the time.
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 Identity, Contact and Financial Data by
filling in forms or by corresponding with us by post, phone, email or
otherwise.
This includes personal data you provide when you:
· purchase our products or
services;
· create an account on our
website;
· subscribe to our service or
publications;
· request marketing to be sent to
you;
· enter a competition, promotion
or survey;
· give us feedback; or
· contact us.
• 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 and other similar technologies. Please see our Cookie Policy for further details.
• Third parties or publicly available sources. We may receive personal data
about you from various third parties as set out below:
· Technical Data from the following parties:
a) analytics providers;
b) advertising networks;
c) search information providers;
· Contact, Financial and Transaction Data from providers of technical, payment
and delivery services.
How we use
your personal data
We will only use
your personal data in compliance with your rights under the Data Protection Laws.
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 obtain 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.
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. We have also identified our
legitimate interests 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 if you require
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.
|
Purpose/Activity |
Type of data |
Lawful basis for processing including basis of
legitimate interest |
|
To register you as a new customer |
(a) Identity (b) Contact |
Performance of a contract with you |
|
To complete a consultation or other
online service |
(a) Identity (b) Special Categories of Personal (c) Contact |
Performance of a contract with you |
|
To process and deliver your order
including: (a) Manage payments, fees and charges (b) Collect and recover money owed to
us |
(a) Identity (b) Contact (c) Financial (d) Transaction (e) Marketing and Communications |
(a) Performance of a contract with
you (b) Necessary for our legitimate
interests - to recover debts due to us |
|
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 |
(a) Identity (b) Contact (c) Profile (d) Marketing and Communications |
(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
products/services) |
|
To enable you to partake in a prize
draw, competition or complete a survey |
(a) Identity (b) Contact (c) Profile (d) Usage (e) Marketing and Communications |
(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 |
|
To administer and protect our
business and this website (including troubleshooting, data analysis, testing,
system maintenance, support, reporting and hosting of data) |
(a) Identity (b) Contact (c) Technical |
(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 |
|
To deliver relevant website content
and advertisements to you and measure or understand the effectiveness of the
advertising we serve to you |
(a) Identity (b) Contact (c) Profile (d) Usage (e) Marketing and Communications (f) Technical |
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 |
|
To use data analytics to improve our
website, products/services, marketing, customer relationships and experiences |
(a) Technical (b) Usage |
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 |
|
To make suggestions and
recommendations to you about goods or services that may be of interest to you |
(a) Identity (b) Contact (c) Technical (d) Usage (e) Profile (f) Marketing
and Communications |
Necessary for our legitimate
interests - to develop our products/services and grow our business |
Marketing
We strive to
provide you with choices regarding certain personal data uses, particularly
around marketing and advertising.
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 or purchased
goods 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
or third parties to stop sending you marketing messages by contacting us at Clickpharmltd@gmail.com
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 purchase or consultation experience or any
other transactions.
Cookies
Cookies are
small pieces of text sent by your web browser by a website you visit. A cookie
file is stored in your web browser and allows the site to recognize you and
make your next visit to the site more useful to you.
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 receive 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.
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.
• Internal Third Parties as set
out in the Glossary.
• External Third Parties as set
out in the Glossary.
• Third parties to whom we may
choose to sell, transfer or merge parts of our business or our assets.
Alternatively, we may seek to acquire other businesses or merge with them. If a
change to our business occurs, then the new owners may use your personal data
in the same way as set out in this privacy policy.
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.
International transfers
It is possible that your personal data may
be transferred outside of the UK by third parties referred to in the policies
as being the recipients of your data.
Wherever we
transfer your data outside of the UK, there are measures in place to ensure
that appropriate safeguards apply to protect your personal data, this may
include, inter alia, contracts with those parties which include standard data
protection clauses adopted by a data protection regulator and approved by the
European Commission. Please contact us if you would like further information
about the safeguards used by us when transferring your personal data out
outside of the UK.
We recommend
that you also refer to the privacy policies and/or terms and conditions of
these third parties if you are concerned about your data being transferred
outside the UK.
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.
Data retention
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.
Your legal rights
Under certain
circumstances, you have rights under Data Protection Laws in relation to your
personal data. To make a request as outlined below, please contact us. We aim
to comply with all requests without undue delay, and within one month of
receipt of the request.
• Request a copy of your
personal data. You have the right to request a copy
of your personal data or that we move, copy or transfer your personal data to
other IT systems.
• Request access to and/or the
correction of your personal data. You have the
right to request a copy of the personal information we hold about you and to
have any inaccuracies corrected.
We will use reasonable efforts to the extent
required by law to supply, correct or delete personal information held about
you on our files (and with any third parties to whom it has been disclosed).
• Object to or request the restriction
of processing of your personal data. You have
the right to request that we restrict, stop processing, or delete your personal data if:
o
you consented
to our processing the personal data, and have withdrawn that consent;
o
we no longer
need to process that personal data for the reason it was collected;
o
we are
processing that personal data because it is in the public interest or it is in
order to pursue a legitimate interest of ours or of a third party, you don’t
agree with that processing, and there is no overriding legitimate interest for
us to continue processing it;
o
your personal
data was unlawfully processed;
o
you need the
personal data to be deleted in order to comply with legal obligations;
o
the personal
data is processed in relation to the offer of a service to a child.
Fee
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.
Glossary
Lawful Basis
Legitimate
Interest means the interest of our business in conducting and managing our
business to enable us to give you the best service/product and the best and
most secure experience. We make sure we consider and balance any potential
impact on you (both positive and negative) and your rights before we process
your personal data for our legitimate interests. We do not use your personal
data for activities where our interests are overridden by the impact on you
(unless we have your consent or are otherwise required or permitted to by law).
You can obtain further information about how we assess our legitimate interests
against any potential impact on you in respect of specific activities by
contacting us.
Performance of
Contract means processing your data where it is necessary for the performance
of a contract to which you are a party or to take steps at your request before
entering into such a contract.
Comply with a
legal obligation means processing your personal data where it is necessary for
compliance with a legal obligation that we are subject to.
Third Parties
Internal Third Parties
Other companies acting as joint controllers
or processors, and who are based in the UK and provide IT and system
administration services.
External Third Parties
• Service providers acting as
processors based in the UK who provide IT and system administration services.
• Professional advisers acting as
processors or joint controllers including lawyers, bankers, auditors and
insurers based in the UK who provide consultancy, banking, legal, insurance and
accounting services.
• HM Revenue & Customs, regulators
and other authorities acting as processors or joint controllers based in the UK
who require reporting of processing activities in certain circumstances.
Your Legal Rights
You have the right to:
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.
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.
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 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 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 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.
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.
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.
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.