Privacy Policy


Introduction

MEDESSENTIALLY LIMITED respects your privacy and is committed to protecting your personal data. This privacy notice will inform you as to how we look after your personal data when you visit our website (regardless of where you visit it from) and tell you about your privacy rights and how the law protects you.

This Policy (together with ourTerms of Website Use and any other documents referred to on it) sets out the basis on which any personal information we collect from you, or that you provide to us, will be processed by us. Please read the following carefully to understand our views and practices regarding your personal information and how we will treat it. By visiting https://medessentially.com/ ("website") you are accepting and consenting to the practices described in this privacy notice.

Please use the Glossary to understand the meaning of some of the terms used in this privacy notice.

Who we are and how to contact us

MEDESSENTIALLY.COM is a website operated by MEDESSENTIALLY LIMITED ("we", “us” or “our”). We are a company incorporated and registered in England and Wales with company number 09905657 whose registered office is at Suite 12, 2nd Floor Queens House, 180 Tottenham Court Road, London, United Kingdom, W1T 7PD.

To contact us, please email info@medessentially.com

Important information

This privacy notice 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 register for our service.

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

It is important that you read this privacy notice together with any other privacy notice or fair processing notice 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 using your data. This privacy notice supplements the other notices and is not intended to override them.

Controller

We are the controller and responsible for your personal data, "we", "us" or "our" in this privacy notice).

We have appointed a data privacy manager who is responsible for overseeing questions in relation to this privacy notice. If you have any questions about this privacy notice, including any requests to exercise your legal rights, please contact the data privacy manager using the details set out below.

Contact details

Our full details are:

Full name of legal entity:MEDESSENTIALLY LIMITED

Email address: info@medessentially.com

Postal address:

MedEssentially Ltd
Kings House
9/10 Haymarket
London, SW1Y 4BP
United Kingdom

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 (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.

Changes to the privacy notice

This version was last updated on 10.08.2018.

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data 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 notice of every website you visit.

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, username or similar identifier, marital status, title, date of birth and gender, job title, company name, personal references.
  • 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, 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 may be derived from your personal data but is not considered personal data in law as this data does 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 notice.

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 goods or services). 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.

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:
  • enquire about the service;
  • 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; or
  • give us some feedback.
  • Automated technologies or interactions. As you interact with our website, we may 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. We may also receive Technical Data about you if you visit other websites employing our cookies. 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 and public sources as set out below:
  • Technical Data and Usage Data;
  • contact, Financial and Transaction Data from providers of technical, payment and delivery services; and

Identity and Contact Data from publicly availably sources.

How we use your personal data

We will only 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; or
  • where we need to comply with a legal or regulatory obligation.

Generally, we do not rely on consent as a legal basis for processing your personal data other than in relation to 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, in a table format, 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 what our legitimate interests are 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 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 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

Provision of services and/or performance of a contract with you

To process your requests 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) Provision of services and/or 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) Provision of services and/or 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 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

Necessary for our legitimate interests

To provide treatment quotations

(a) your ethnic origin

(b) our physical or mental health or condition

(c) your medical files

(d) your sexual health

Explicit consent







Sensitive personal data

We may ask you to provide sensitive personal data, such as:

  • your ethnic origin;
  • your physical or mental health or condition;
  • your medical files; and
  • your sexual health,

for the purpose of providing you with treatment quotes from the medical practitioners.

We will process such sensitive personal data only when you expressly consent to such processing upon submitting the relevant request form on the website.

If you consent to processing of your sensitive personal data, we may transfer it to the medical practitioners located and operating across the United Kingdom.

You have the right to refuse consent to processing of your personal sensitive data, however the medical practitioners may not be able to provide treatment plan quotes.

We will not carry out automated decision-making (including profiling) based on your personal sensitive data.

Data relating to children

This paragraph 13 applies to children under the age of 13 in the UK.

We may collect and process your sensitive personal data. Medical practitioners in partnership with us provide pediatrics services. If you are under the age of 13 we must first seek your parents’ or guardians’ consent before we can collect and process your personal sensitive data. We will never collect and process your personal sensitive data without your consent.

When you provide personal information, we will rely on our legitimate business interest for the purpose of collecting and processing such information.

If your parents or guardians are consenting on your behalf, we may gather limited amount of personal information, such as contact details) of your parents or guardians.

The parental consent will expire once you reach the age of digital consent, which is 13 years old. Once the parental consent expires, we will delete your personal and personal sensitive data unless you consent to its processing.

Children have the same rights with respect to their date as adults. Please see paragraph 24 below to learn more about your rights.

Marketing

We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising. Please note that if you register on our website, we will, as part of the service, send you periodic newsletters by email, which are not marketing and advertising, but an integral part of our service.

We comply with the direct marketing requirements of the Privacy and Electronic Communications Regulations. When considering marketing directed to children, we take into account their reduced ability to recognise and critically assess the purposes behind processing and the potential consequences of providing their personal data.

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.

You will receive marketing communications from us if you have requested information from us or purchased services from us and, in each case, you have not opted-out of receiving marketing communication.

Third-party marketing

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

Opting out

You can ask us or 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.

Cookies

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 cookie policy

Change of purpose

We will only use your personal data and sensitive 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.

Disclosures of your personal data

We may have to share your personal data with the parties set out below for the purposes set out in the table in clause 11 above:

  • other companies within our group;
  • External Third Parties as defined in the Glossary;
  • law enforcement agencies in connection with any investigation to help prevent unlawful activity;
  • our business partners in accordance with the Marketing section above;
  • 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 happens to our business, then the new owners may use your personal data in the same way as set out in this privacy notice.

We will not disclose your personal sensitive data without your explicit consent.

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

Some of our external third parties are based 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.
  • 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.
  • 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 the Europe and the US. For further details, see European Commission: EU-US Privacy Shield.

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

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

How long will you use my personal data for?

We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, 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 requirements.

By law, we have to keep basic information about our customers (including Contact, Identity, Financial and Transactional Data) for 6 years after they cease being customers for tax purposes.

In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.

Your legal rights

Under certain circumstances, you have rights under the relevant data protection laws in relation to your personal data. Please click on the links below to find out more about these rights:

  • right to rectification:

if your personal information is incorrect or incomplete any way, you may notify a person dealing with your matter and where inaccurate or incomplete, we will correct it without delay

  • right of access:
  • you may request a confirmation from us that we are processing your personal data;
  • access your personal data held by us and request a copy (unless providing a copy adversely affects the rights and freedoms of others);
  • obtain certain information about how we process your personal data, categories of personal data processed, recipients or categories of recipients who receive personal data from us; and
  • how long we store your personal data for and the criteria we use to determine retention periods.
  • right to be informed:
  • how your personal data is being process;
  • how long it will be stored for;
  • the legal basis for processing,
  • recipients (or categories of recipients) of your personal data; and
  • whether personal data must be provided under statute or for another reason and the consequences of not providing the personal data to ensure the fair and transparent processing of your personal data;
  • right to restrict processing under certain circumstances:
  • if you contest the accuracy of your personal data, we may restrict its processing, until we can verify its accuracy;
  • if the processing is unlawful;
  • if we no longer need to process your personal data, unless we still need your personal data for the establishment, exercise, or defence of legal claims;and
  • if you object to processing that relies on public interest or our (or third party’s) legitimate interest as the lawful processing ground.
  • right to data portability:
  • right to receive from us a copy of your personal data in commonly used and machine-readable format and store it for further use on a private devise; and
  • right to transmit personal data to another third party; or have your personal data transmitted directly from one third party to another where technically possible.
  • right not to be subject of automated processing:

right not to be subject to automated decision-making, including profiling, which has legal or other significant effects on you. This does not apply when the automated decision is necessary for entering into or performing a contract with you; or it is authorised by EU or member state law applicable to us if the law requires suitable measures to safeguard your rights and freedoms and legitimate interests; or based on your explicit consent.

  • the right to object to processing:

you may object to direct marketing, including profiling related to direct marketing. We will stop processing your personal data once notified by you, except if we can demonstrate a compelling legitimate ground for processing the personal data that overrides your request; or processing is necessary to exercise or defend legal claims.

If you wish to exercise any of the rights set out above, please contact info@medessentially.com

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 may 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 may 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.

Glossary

Comply with a legal or regulatory obligation: means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.

External Third Parties:

  • Service providers acting as processors based in the European Economic Area who provide hosting and email management services in respect of the services provided by MEDESSENTIALLY LIMITED.
  • Professional advisers acting as processors or joint controllers including lawyers, bankers, auditors and insurers 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 United Kingdom who require reporting of processing activities in certain circumstances.

Legitimate Interest: means the interest of our business in conducting and managing our business to enable us to give you the best service 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.

Special Categories of Personal Data: means information about your race, ethnic origin, genetics information, biometric information and information concerning your health, sex health or sexual orientation.

Third Parties

  • HM Revenue & Customs, regulators and other authorities acting as processors or joint controllers based who require reporting of processing activities in certain circumstances;
  • Medical practices providing;
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