Privacy and Cookies

This policy governs how we use your personal data for the purpose of providing Medicspot services to Medicspot patients. Please get in touch for our NHS privacy policies.

Medic Spot Limited (“we”, “us” or “our”) is committed to protecting and respecting your privacy.

This policy sets out the basis on which any personal data 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 data and how we will treat it. By visiting< www.medicspot.co.uk (“our site”) and/or our mobile or web application Medic Spot App (“our application”) you are accepting and consenting to the practices described in this policy.

For the purposes of the Data Protection Act 2018 (as amended or re-enacted from time to time) and all applicable laws and regulations relating to the processing of personal data and privacy, including (insofar as it is in force from time to time) the General Data Protection Regulation ((EU) 2016/679) (the “Data Protection Legislation”), the data controller is Medic Spot Limited (company number: 10089666) of Medicspot, Iberian Park, Drury Lane, Hastings, TN38 9XP.

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 (known as “anonymous data”).

We will collect and process the following data about you:

• Information you give us. This is information about you that you give us by filling in booking forms on our site or on our application or by corresponding with us by phone, e-mail or otherwise. It includes information you provide when you register to use our site or our application, subscribe to or use our services, including participating in a consultation with any of our clinicians, search for a service, make a booking on our site or our application, enter a competition, promotion or survey, sign-up to our email newsletter and when you report a problem with our site or our application. The information you give us may include your name, date of birth, address, e-mail address, phone number, gender, financial and credit card information, photograph or ID documentation, and any other information that you provide to us about yourself.
• Information we collect about you. With regard to each of your visits to our site or our application we will automatically collect the following information:
  • technical information, including the Internet protocol (IP) address used to connect your computer to the Internet, your login information, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform;
  • information about your visit, including the full Uniform Resource Locators (URL), clickstream to, through and from our site (including date and time), products or services you viewed or searched for, page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), methods used to browse away from the page, and any phone number used to call our customer service number.
• Special categories of personal data. We may ask you to provide us with certain special categories of personal information, particularly during the course of a consultation. Such data may include data concerning your health, including medical records and past medical history, sex life or sexual orientation.
• Information we receive from other sources. This is information we receive about you if you use any of the websites with which we are affiliated and through which you can make a booking for our services or in order to provide the services to you. We are working closely with third parties (including, for example, business partners, sub-contractors in technical, payment and delivery services, advertising networks, analytics providers, search information providers, credit reference agencies and pharmacies). We will notify you when we receive information about you from them and the purposes for which we intend to use that information.

We will only use your personal data when the law allows us to. Most commonly, we will use your personal information:

• to carry out our obligations arising from any contracts entered into between you and us or to take steps at your request before entering into any contracts;
• to comply with any legal obligations to which we are subject; or
• where it is necessary for our or a third party’s legitimate interests, including for the purposes of preventing fraud, except where such interests are overridden by your interests or fundamental rights and freedoms.

Special categories of personal data. We will only use and process such data where:

• it is necessary for the purposes of preventive or occupational medicine, medical diagnosis, or the provision of health care or treatment; or
• you have provided your explicit consent to us doing so; or
• where it is necessary for the establishment, exercise or defence of legal claims.

If we intend to process your special category personal data for any other lawful purpose, we will notify you before doing so (where possible) of the legal basis on which we are seeking to rely.

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 | Identity, contact details, ID documentation | Performance of a contract with you | | To process and provide the services that you have ordered including: (a) Manage payments, fees and charges; (b) Collect and recover money owed to us | Identity, contact details and financial and credit card information | (a) Performance of a contract with you (b) Necessary for our legitimate interests (to recover debts due to us)| | To carry out a consultation and to provide you with medical advice or treatment | Identity, special categories of data concerning your health, sex life and sexual orientation, other information regarding your lifestyle | (a) Performance of a contract with you (b) Special categories of data – necessary for the purposes of preventive or occupational medicine, medical diagnosis, or the provision of health care or treatment, or where you have provided your explicit consent| | 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 | Identity, contact details, and marketing preferences | (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 administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data) | Identity, contact details and technical data such as IP address | (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 | Identity, contact details, technical data such as IP address, marketing preferences | 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 | Technical data such as IP address | 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 | Identity, contact details, usage data and marketing preferences | 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.

We may use your identity, contact details, usage data, technical data and marketing preferences 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 that marketing.

We will get your express opt-in consent before we share your personal data with any company outside the Medic Spot Limited group for marketing purposes.

You can ask us or third parties to stop sending you marketing messages at any time by contacting us 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 service purchase, service experience or other transactions.

If we intend to use your information for any other purpose, we will let you know what we intend to do with such data and the legal basis we are relying on for processing such data. This may include obtaining your express consent to the use of such data.

Other than in respect of special category personal data, you agree that we have the right to share your personal information with the third parties set out below, or any other third parties notified to you, for the purposes set out in paragraph 3 above:

• The pharmacy where you have booked your consultation or wish to have a prescription collected/delivered from.
• Couriers or the postal system to deliver medical supplies, letters or prescriptions to patients.
• Stripe, our payment services provider.
• Trustpilot, to keep track of user reviews.
• Professional advisers including lawyers, bankers, auditors and insurers based in the UK.
• Regulators and other authorities who require reporting of processing activities in certain circumstances.
• Third parties to whom we may choose to sell, transfer or mere 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 policy.
• Fraud prevention agencies.

We will only share your special category personal information with third parties where:

• It is necessary for the purposes of preventive or occupational medicine, medical diagnosis, or the provision of health care or treatment; or
  • The pharmacy where you have booked your consultation or wish to have a prescription collected/delivered from
  • Another healthcare service provider/named clinician for the purposes of sending a medical referral to
  • Ashlee Healthcare Ltd, our supplier of home/onsite blood collection services
  • The Doctors Laboratory (TDL) to analyse blood/pathology samples for patients
  • London Medical Laboratory to analyse blood/pathology samples for patients
  • Other partners with whom we deliver either joint care or care for patients on their behalf (such as Healthy.io Ltd)
• You have provided your explicit consent to us doing so; or
• Where it is necessary for the establishment, exercise or defence of legal claims.

If we intend to share your special category personal data with any third parties for any other lawful purpose, we will notify you before doing so (where possible) of the legal basis on which we are seeking to rely.

Where you participate in a consultation, the relevant clinician will make notes of your consultation and the treatment or advice provided. We encourage you to allow us to share your consultation notes with your regular doctor or general practitioner, but we will only do so with your explicit consent; unless required to do so by law. In such circumstances, we will only disclose so much of your clinical notes as you request.

Some of our external third parties may be based outside the European Economic Area (“EEA”) so their processing of your personal data would involve a transfer of data outside the EEA. This will only involve the transfer of non-special category personal 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 Europe and the US.

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

All information you provide to us is stored on our secure servers in the EEA (normally UK) and is encrypted.

Where we have given you (or where you have chosen) a password which enables you to access certain parts of our site or our application, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.

Unfortunately, the transmission of information via the internet is not completely secure which can depend on factors on your end. Although we will do our best to protect your personal data and use industry-standard security and encryption measures, we cannot guarantee the security of your data transmitted to our site or our application; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access.

Under the Data Protection Legislation:

• Where you have provided your consent to the processing of your personal data for any purpose, you have the right to withdraw such consent at any time by contacting us at Medicspot, Iberian Park, Drury Lane, Hastings, TN38 9XP or by email to info@medicspot.co.uk.
• You can ask us to rectify any inaccuracies in the personal information that we hold about you.
• You may have the right to request the erasure of personal information that we hold about you where there is no good reason for us to continue processing it, where you have successfully exercised your right to object to processing, where we may have processed you information unlawfully or where we are required to erase your personal data to comply with local law.
• You may have the right to object to our processing of your personal data for certain purposes, including for direct marketing purposes, for scientific or historical research purposes or statistical purposes.
• You may have the right to restrict our processing of your personal data in certain circumstances.
• You may have the right to request a copy of your personal data from us in a commonly used and machine-readable format or that we transmit your personal data to another data controller.
• You may have the right not to be subject to automated decision-making, including profiling, which has legal or other significant effects on you.

You can exercise any of the above rights at any time by contacting us at Medicspot, Iberian Park, Drury Lane, Hastings, TN38 9XP or by email to info@medicspot.co.uk.

We may anonymise and aggregate your personal data and process and share such data with third parties in order to monitor usage of our site, our application and our services, to market and improve our services, or for research purposes. You will not be capable of being identified from such data and we may use such data indefinitely without further notice to you.

Our site may, from time to time, contain links to and from the websites of our partner networks, advertisers and affiliates. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies. Please check these policies before you submit any personal data to these websites.

10. Access to information

The Data Protection Legislation gives you the right to access information held about you. Your right of access can be exercised in accordance with the Data Protection Legislation. You may request details or a copy of the personal data that we hold about you by writing to us at Medicspot, Iberian Park, Drury Lane, Hastings, TN38 9XP.

11. Retention

We will only retain your personal information for as long as is necessary to carry out the purpose for which it was collected. We adhere to the NHS’s recommended retention policies.

Any changes we make to our privacy policy in the future will be posted on this page and, where appropriate, notified to you by e-mail. Please check back frequently to see any updates or changes to our privacy policy.

Our website uses cookies to distinguish you from other users of our website. This helps us to provide you with a good experience when you browse our website and also allows us to improve our site.

A cookie is a small file of letters and numbers that we store on your browser or the hard drive of your computer if you agree. Cookies contain information that is transferred to your computer’s hard drive.

We use the following cookies:

• Strictly necessary cookies. TThese are cookies that are required for the operation of our website. They include, for example, cookies that enable you to log into secure areas of our website, use a shopping cart or make use of e-billing services.
• Analytical/performance cookies. They allow us to recognise and count the number of visitors and to see how visitors move around our website when they are using it. This helps us to improve the way our website works, for example, by ensuring that users are finding what they are looking for easily. We use Google Analytics to analyse the use of our site. The analytics cookies used by our site have the following names. The analytics cookies used on our site have the following names: _ga, _gat, __utma, __utmt, __utmb, __utmc, __utmz and __utmv. Google Analytics’ privacy policy is available at: http://www.google.com/policies/privacy/.
• Functionality cookies. These are used to recognise you when you return to our website. This enables us to personalise our content for you, greet you by name and remember your preferences (for example, your choice of language or region).
• Targeting cookies. These cookies record your visit to our website, the pages you have visited and the links you have followed. We will use this information to make our website and the advertising displayed on it more relevant to your interests.

Please note that third parties (including, for example, advertising networks and providers of external services like web traffic analysis services) may also use cookies, over which we have no control. These cookies are likely to be analytical/performance cookies or targeting cookies. In particular:

• We use Google Analytics to analyse the use of our site. The analytics cookies used by our site have the following names. The analytics cookies used on our site have the following names: _ga, _gat, __utma, __utmt, __utmb, __utmc, __utmz and __utmv. Google Analytics’ privacy policy is available at: http://www.google.com/policies/privacy/.
• To determine your interests, Google will track your behaviour on our site and on other websites across the internet using the DoubleClick cookie. This behaviour tracking allows Google to tailor the advertisements you see on other websites to reflect your interests (we do not publish interest-based advertisements on our site). You can view, delete or add interest categories associated with your browser by visiting: http://www.google.com/settings/ads/. You can also opt out of the AdSense partner network cookie using those settings or using the NAI’s (Network Advertising Initiative’s) multi-cookie opt-out mechanism at: http://www.networkadvertising.org/choices/. However, these opt-out mechanisms themselves use cookies, and if you clear the cookies from your browser your opt-out will not be maintained. To ensure that an opt-out is maintained in respect of a particular browser, you may wish to consider using the Google browser plug-in available at: https://www.google.com/settings/ads/plugin.

You block cookies by activating the setting on your browser that allows you to refuse the setting of all or some cookies. However, if you use your browser settings to block all cookies (including essential cookies) you may not be able to access all or parts of our site.

Questions, comments and requests regarding this privacy policy are welcomed and should be addressed to Medicspot, Iberian Park, Drury Lane, Hastings, TN38 9XP or emailed to info@medicspot.co.uk.

If you have any complaints relating to our privacy policy or our use of your personal data, please contact us at Medicspot, Iberian Park, Drury Lane, Hastings, TN38 9XP or by email to info@medicspot.co.uk. You also have the right to make a complaint to the Information Commissioner’s Office. Further information can be found at https://ico.org.uk/.