1.1 www.boxofmeds.co.uk (“our website”), is owned by [REMOVED]. Registered in England. Company number: [REMOVED]. Registered office: [REMOVED] is committed to safeguarding the privacy of our website visitors and customers.
1.3 This policy applies where we are acting as a data controller with respect to your personal data; in other words, where we determine the purposes and means of the processing of that personal data. We respect your privacy and are committed to protecting your data, and we appreciate your trust in us to do that carefully and sensibly.
1.5 In this policy, “we”, “us” and “our” refers to [REMOVED] and “our website” refers to www.boxofmeds.co.uk.
2. The personal data that we collect
2.1 In this section, we have set out the general categories of personal data that we process.
2.2 We process data enabling us to safely prescribe medication for you and to contact you (“contact data“); the latter in instances where queries may arise prior to prescribing or dispatching your medicines. The contact data will include your name, date of birth, email address, telephone number, postal address and may include your social media account identifiers. The source of the contact data will be made available by you, the website visitor.
2.3 We may process your website user account data (“account data“). The account data may include your account identifier, name, email address, business name, account creation and modification dates, website settings and marketing preferences. The primary source of the account data will be made available by you, the website visitor, although some elements of the account data may be generated by our website.
2.4 We may process information relating to transactions, including purchases of goods and/or services, through our website (“transaction data“). The transaction data may include your name, your postal/card address, your contact details, your payment card details (or other payment details) and the transaction details. The source of the transaction data will be made available by you, the website visitor and/or our payment services provider.
2.5 We may process information contained in or relating to any communication that you send to us or that we send to you (“communication data“). The communication data may include the communication content and metadata associated with the communication. Our website will generate the metadata associated with communications made using the website contact forms.
2.6 We may process data about your use of our website and services (“usage data“). The usage data may include your IP address, geographical location, browser type and version, operating system, referral source, length of visit, page views and website navigation paths, as well as information about the timing, frequency and pattern of your service use. The source of the usage data is provided by our analytics tracking system.
3. Purposes of processing and legal bases
3.1 In this Section 3, we have set out the purposes for which we may process personal data and the legal bases of the processing.
3.2 Operations – We may process your personal data for the purposes of operating our website, the processing and fulfilment of orders, providing our services, supplying our goods, generating invoices, bills and other payment-related documentation, and credit control. The legal basis for this processing is to ensure proper administration of our website, services and business.
3.3 Publications – We may process account data for the purposes of publishing such data on our website and elsewhere through our services in accordance with your express instructions. The legal basis for this processing is for the publication of content in the ordinary course of our operations.
3.4 Relationships and communications – We may process contact data, account data, customer relationship data, transaction data and/or communication data for the purposes of managing our relationships, communicating with you (including communicating for the purposes of direct marketing, if opted by you) by email, SMS, post, fax and/or telephone, providing support services and complaint handling. The legal basis for this processing is to ensure communications with our website visitors, service users, individual customers and customer personnel, the maintenance of our relationships, enabling the use of our services, and the proper administration of our website, services and business.
3.5 Personalisation – We may process account data and/or usage data for the purposes of personalising the content and advertisements that you see on our website and through our services to ensure that you only see material that is relevant to you. The legal basis for this processing is to offer the best possible experience for our website visitors and service users.
3.6 Direct marketing – We may process contact data, account data, customer relationship data and/or transaction data for the purposes of creating, targeting and sending direct marketing communications by email, SMS, post and/or fax and making contact by telephone for marketing-related purposes. The legal basis for this processing is to help promote our business and communicating marketing messages and offers to our website visitors and service users.
3.7 Research and analysis – We may process usage data and/or transaction data for the purposes of researching and analysing the use of our website and services, as well as researching and analysing other interactions with our business. The legal basis for this processing is to enable us to monitor, support, improve and secure our website, services and business generally.
3.8 Record keeping – We may process your personal data for the purposes of creating and maintaining our databases, back-up copies of our databases and our business records generally. The legal basis for this processing is our legitimate interests, namely ensuring that we have access to all the information we need to properly and efficiently run our business in accordance with this policy.
3.9 Security – We may process your personal data for the purposes of security and the prevention of fraud and other criminal activity. The legal basis of this processing is our legitimate interests, namely the protection of our website, services and business, and the protection of others.
3.10 Insurance and risk management – We may process your personal data where necessary for the purposes of obtaining or maintaining insurance coverage, managing risks and/or obtaining professional advice. The legal basis for this processing is our legitimate interests, namely the proper protection of our business against risks.
3.11 Legal claims – We may process your personal data where necessary for the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure. The legal basis for this processing is our legitimate interests, namely the protection and assertion of our legal rights, your legal rights and the legal rights of others.
3.12 Legal compliance and vital interests – We may also process your personal data where such processing is necessary for compliance with a legal obligation to which we are subject or in order to protect your vital interests or the vital interests of another natural person.
4. Automated decision-making
4.1 We will use your personal data for the purposes of automated decision-making in relation to the consultation questionnaire required for the prescribing of an appropriate medicinal product for your specified medical condition.
4.2 This automated decision-making will depend entirely on the accurate completion of the consultation questionnaire by you, as the patient or client visiting the website.
5. Providing your personal data to others
5.1 We may share your Identity, Contact and Medical Data with your Doctor or any other third party, where you have provided your express consent for us to share Your Data with them. Please note that we will never share your Medical Data without your express consent.
5.2 We may share Marketing and Communications Data where you have provided your express consent for us to share such with third parties for marketing purposes. We may also share Your Data in the event of a joint venture, collaboration, financing, sale, merger or re-organisation of the company. If a change happens to our business, then the new owners may use Your Data in the same way as set out in this Policy and to further fraud protection and reduce the risk of fraud (for example, to comply with anti-money laundering regulations).
5.3 Your personal data held in our website database will be stored on the servers of our hosting services providers.
5.4 Financial transactions relating to our website and services are handled by our payment services providers, [Stripe]. We will share transaction data with our payment services providers only to the extent necessary for the purposes of processing your payments, refunding such payments and dealing with complaints and queries relating to such payments and refunds. You can find information about the payment services providers’ privacy policies and practices at https://stripe.com/gb
5.5 In addition to the specific disclosures of personal data set out in this Section 5, we may disclose your personal data where such disclosure is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person. We may also disclose your personal data where such disclosure is necessary for the establishment, exercise, or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure.
6. International transfers of your personal data
6.1 In this Section 6, we provide information about the circumstances in which your personal data may be transferred to [countries outside the United Kingdom and the European Economic Area (EEA)].
6.2 In addition to the disclosures set out in “Providing your personal data to others”above, some of our third parties may be based outside the European Union so their processing of your data will involve a transfer of data outside the European Union.
6.3 Whenever we transfer your data out of the European Union, we will only transfer Your Data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission.
6.4 Where we use providers based in the US, we may transfer data to them if they are part of the EU-US Privacy Shield Framework which requires them to provide similar protection to personal data shared between the Europe and the US.
6.5 You acknowledge that [personal data that you submit for publication through our website or services] may be available, via the internet, around the world. We cannot prevent the use (or misuse) of such personal data by others.
7. Retaining and deleting personal data
7.1 This Section 7 sets out our data retention policies and procedures, which are designed to help ensure that we comply with our legal obligations in relation to the retention and deletion of personal data.
7.2 Personal data that we process for any purpose or purposes shall not be kept for longer than is necessary for that purpose or those purposes.
7.3 To determine the appropriate retention period for your data, we will consider various factors to ensure your data is kept for the appropriate time period according to the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your data, the purposes for which we process your data and whether we can achieve those purposes through other means, and the applicable legal requirements.
7.4 In some cases it is not possible for us to specify in advance the periods for which your personal data will be retained.
7.5 Notwithstanding the other provisions of this Section 7, we may retain your personal data where such retention is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.
8. Security of personal data
8.1 We will take appropriate technical and organisational precautions to secure your personal data and to prevent the loss, misuse or alteration of your personal data.
8.2 We will store your personal data on secure servers, personal computers and mobile devices, and in secure manual record-keeping systems.
9. Your rights
9.1 In this Section, we have listed the rights that you have under data protection law.
9.2 Your principal rights under data protection law are:
(a) the right to access – you can ask for copies of your personal data; this enables you to receive a copy of your data we hold about you and to check that we are lawfully processing it.
(b) the right to rectification – you have the right to have any inaccurate personal data about you rectified and, taking into account the purposes of the processing, to have any incomplete personal data about you completed.
(c) the right to erasure – In some circumstances you have the right to the erasure of your personal data without undue delay. Those circumstances include: the personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed; you withdraw consent to consent-based processing; you object to the processing under certain rules of applicable data protection law; the processing is for direct marketing purposes; and the personal data have been unlawfully processed. However, there are exclusions of the right to erasure. The general exclusions include where processing is necessary: for exercising the right of freedom of expression and information; for compliance with a legal obligation; or for the establishment, exercise or defence of legal claims.
(d) the right to restrict processing – In some circumstances you have the right to restrict the processing of your personal data. Those circumstances are: you contest the accuracy of the personal data; processing is unlawful but you oppose erasure; we no longer need the personal data for the purposes of our processing, but you require personal data for the establishment, exercise or defence of legal claims; and you have objected to processing, pending the verification of that objection. Where processing has been restricted on this basis, we may continue to store your personal data. However, we will only otherwise process it: with your consent; for the establishment, exercise or defence of legal claims; for the protection of the rights of another natural or legal person; or for reasons of important public interest.
(e) the right to object to processing – You have the right to object to our processing of your personal data on grounds relating to your particular situation, but only to the extent that the legal basis for the processing is that the processing is necessary for: the performance of a task carried out in the public interest or in the exercise of any official authority vested in us; or the purposes of the legitimate interests pursued by us or by a third party. If you make such an objection, we will cease to process the personal data unless we can demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms, or the processing is for the establishment, exercise or defence of legal claims.
– You have the right to object to our processing of your personal data for direct marketing purposes (including profiling for direct marketing purposes). If you make such an objection, we will cease to process your personal data for this purpose.
(f) the right to data portability – you can ask that we transfer your personal data to another organisation or to you;
(g) the right to complain to a supervisory authority – If you consider that our processing of your personal data infringes data protection laws, you have a legal right to lodge a complaint with a supervisory authority responsible for data protection. You may do so in the EU member state of your habitual residence, your place of work or the place of the alleged infringement.
(h) the right to withdraw consent – To the extent that the legal basis for our processing of your personal data is consent, you have the right to withdraw that consent at any time. Withdrawal will not affect the lawfulness of processing before the withdrawal.
9.3 These rights are subject to certain limitations and exceptions. You can learn more about the rights of data subjects by visiting https://ico.org.uk/for-organisations/guide-to-data-protection/guide-to-the-general-data-protection-regulation-gdpr/individual-rights/.
9.4 You may exercise any of your rights in relation to your personal data by contacting us on [text-blocks id=”teamemail” plain=”1″] or calling [text-blocks id=”phonenumber” plain=”1″] and requesting to speak to the DPL.
10. Third party websites
10.1 Our website may include hyperlinks to, and details of, third party websites. Clicking on these links may allow these third party websites to collect and share information about you and your data.
10.2 In general we have no control over, and are not responsible for, the privacy policies and practices of third parties.
11. Personal data of children
11.1 Our website and services are targeted at persons over the age of 18 years.
11.2 If we have reason to believe that we hold personal data of a person under that age in our databases, we will delete that personal data.
12. Updating information
12.1 Please let us know if the personal information that we hold about you needs to be corrected or updated.
13. About cookies
13.1 A cookie is a file containing an identifier (a string of letters and numbers) that is sent by a web server to a web browser and is stored by the browser. The identifier is then sent back to the server each time the browser requests a page from the server.
13.2 Cookies may be either “persistent” cookies or “session” cookies: a persistent cookie will be stored by a web browser and will remain valid until its set expiry date, unless deleted by the user before the expiry date; a session cookie, on the other hand, will expire at the end of the user session, when the web browser is closed.
13.3 Cookies may not contain any information that personally identifies a user, but personal data that we store about you may be linked to the information stored in and obtained from cookies.
14. Cookies that we use
15. Cookies used by our service providers
16. Managing cookies
16.1 Most browsers allow you to refuse to accept cookies and to delete cookies. The methods for doing so vary from browser to browser, and from version to version. You can however obtain up-to-date information by visiting the browser’s respective information pages.
16.2 Blocking all cookies will have a negative impact upon the usability of many websites.
16.3 If you block cookies, you will not be able to use all the features on our website.
17. Cookie preferences
18.1 We may update this policy from time to time by publishing a new version on our website.
18.2 You should check this page occasionally to ensure you are happy with any changes to this policy.
18.3 We may notify you of significant changes to this policy by email, but are not mandated to do so.
19. Our details
19.1 This website is owned and operated by [REMOVED].
19.2 We are registered as [REMOVED].
19.3 Our principal registered office is [REMOVED].
Tel: [text-blocks id=”phonenumber” plain=”1″]
19.4 You can contact us:
(a) by post, to the postal address given above;
(b) using our website contact form;
(c) by telephone, on the contact number published on our website; or
(d) by email, using the email address published on our website.
20. Data protection officer
20.1 [REMOVED] Ltd is a controller and responsible for all personal data it receives and holds. An appointed data protection leader (“DPL”) is responsible for overseeing questions in relation to this Policy. If you have any questions about this Policy, including any requests to exercise your legal rights, please contact the DPL using the details set out below:
- Full name of legal entity: [REMOVED]
- Name of DPL: [REMOVED]
- Email address: firstname.lastname@example.org
- Postal address: [REMOVED]
- Telephone number: [text-blocks id=”phonenumber” plain=”1″]
20.2 If you have any queries, concerns or complaints about the use of your data, then please contact the DPL.
20.3 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. We value feedback from our customers and website visitors and therefore would appreciate you contacting us in the first instance to help resolve any questions or complaints you may have.