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Privacy Notice
PURPOSE OF THIS PRIVACY NOTICE
R3 Prescriptions Limited (Company number 09339828), trading as ED Treated, is the data controller and responsible for your personal data (“ED Treated”, “we”, “us” or “our”).
ED Treated 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), when you become a customer of ED Treated or use our Products and/or services and tell you about your privacy rights and how the law protects you.
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.
THIRD PARTY LINKS
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, including sensitive special category data, that may be provided by you when you: (i) complete or partially complete a form on our website (including medical screening information); (ii) correspond with us (for example via SMS, email, telephone, WhatsApp or otherwise); (iii) during consultations; and (iv) by making enquiries on social media platforms or when you purchase a Product.
We have grouped the data types together follows:
Identity Data includes title, first name, last name, username or similar identifier, date of birth.
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, URL, your login data, browser type and version, time zone setting and location, page interaction, 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 (e.g. product searches Products and/or Orders made by you).
Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties that may be of interest to you and your communication preferences.
Special Category Data: includes information revealing racial or ethnic origin, physical or mental health conditions and facts, sexual life, sexual orientation or genetic data.
It is very important that the personal data we hold about you is accurate and current, particularly where a prescription is being issued. Please keep us informed if your personal data changes during your relationship with us.
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 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.
We also collect Special Categories of Personal Data about you (defined above) for the purposes set out below. We do not collect any information about religious or philosophical beliefs, political opinions, trade union membership, criminal convictions and offences or biometric data.
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, Financial Data and Special Category Data by creating an account with us, filling in forms (e.g completing or partially completing medical screening information), or by corresponding with us online (social media platforms, WhatsApp), post, phone (including sms), email, during consultations or otherwise. This includes personal data you provide when you:
Third parties or publicly available sources. We may receive personal data about you from various third parties and public sources as set out below:
want to order Products and/or use our services
create an account;
subscribe to our newsletters or messages;
request marketing to be sent to you; 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 from the following parties:
analytics providers;
advertising networks; and
search information providers.
Contact, Financial and Transaction Data from providers of technical, payment and delivery services.
Identity and Contact Data from data brokers or aggregators.
Identity and Contact Data from publicly available 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, including online prescriptions, processing payments and where required provide advice via third party provider.
To create statistical information which will help us manage the Products and/or services we provide and to make improvements to these.
To manage the effectiveness of our online service and deliver the website to you.
To allow you to access the interactive features of the website that facilitate account login to access your Order information.
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 or regulatory obligation.
Where you have given us consent for us to contact you.
In order to protect your data and your identity.
Generally we do not rely on consent as a legal basis for processing your personal data other than in relation to collecting Special Category Data or 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/ user of our website |
(a) Identity |
Performance of a contract with you |
|
To process and arrange delivery of your Product purchase: |
(a) Identity |
(a) Performance of a contract with you |
|
To manage our relationship with you which will include: |
a) Identity |
(a) Performance of a contract with you |
|
To administer and protect our business and our website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data). |
(a) Identity |
(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) |
To deliver relevant and effective website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you |
(a) Identity |
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 and send you marketing information about our Products and/or services that may be of interest to you. |
(a) Technical |
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) |
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.
MARKETING
We may use your Identity, Contact, Technical, Usage, 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 Products and/or services from us and, in each case, you have not opted out of receiving that marketing.
We will get your express opt-in consent before we share your personal data with any third party for marketing purposes.
You can ask us or third parties to stop sending you marketing messages at any time [by logging into the website and checking or unchecking relevant boxes to adjust your marketing preferences or by following the opt-out links on any marketing message sent to you or by Contacting us at any time].
DISCLOSURES OF YOUR PERSONAL DATA
We may have to share your personal data with the parties set out below:
Prescribers who provide Prescriber Services to you
Pharmacists/Pharmacy who provide Pharmacy Services to you
Delivery/logistics companies who arrange delivery of Products to you.
Distribution channels.
Service providers who provide IT and system administration services.
Professional advisers including lawyers, bankers, auditors and insurers who provide consultancy, banking, legal, insurance and accounting services.
HM Revenue & Customs, regulators and other authorities who require reporting of processing activities in certain circumstances.
Advertising agencies we choose to work with in order to target specific audiences and make our advertising relevant to individuals who wish to purchase our products and services
Other third parties that we work with in order to provide our Products and/or services to you including:
DHL
Royal Mail
Private Logistic Companies
Inspectlet
MBT Digital Marketing
The Chemist Live
Facebook Services
WhatsApp Services
Google Services
Text Marketer
Amazon Server
MailGun
Total Processing
Paypal
Trustpilot
Other 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 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
We do not transfer your personal data outside the European Economic Area (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
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.
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 no longer require Special Category Data for the purpose for which it was collected, we will delete it or render it permanently anonymous as soon as possible.
In some circumstances you can ask us to delete your data (see Request erasure below for further information).
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 data protection laws in relation to your personal data.
|
Request access… |
to your personal information (commonly known as a "data subject access request"). This enables you to receive a copy of the personal information we hold about you and to check that we are lawfully processing it. |
|
Request correction… |
of the personal information that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected. |
|
Request erasure.. |
of your personal information. This enables you to ask us to delete or remove personal information 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 information where you have exercised your right to object to processing (see below). |
|
Object to processing… |
of your personal information 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. You also have the right to object where we are processing your personal information for direct marketing purposes. |
Request the restriction of processing… |
of your personal information. This enables you to ask us to suspend the processing of personal information about you, for example if you want us to establish its accuracy or the reason for processing it. |
|
Request the transfer… |
of your personal information to another party. |
If you wish to exercise any of the rights set out above, please Contact us.
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.
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.
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.
DATA PRIVACY MANAGER
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.
Our full details are:
Full name of legal entity: R3 Prescriptions Limited, trading as ED Treated
Name or title of Data Protection Manager Mohammed Rafiq
Email address: admin@r3rx.co.uk
Postal address: Merchants House 24-25 Market Place Stockport SK1 1EU
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