Instant e-Care Limited is the controller and responsible for your personal data (collectively referred to as “Instant eCare“, “we”, “us” or “our” in this privacy notice).
We are registered with the Information Commissioner’s Office (ICO), the UK’s independent authority which upholds information rights in the public interest, promoting data privacy for individuals.
We have appointed a Data Protection Officer (DPO) 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 DPO using the details set out below.
Our full details are:
- Full name of legal entity: Instant e-Care Limited
- Name or title of DPO: Shah Hoque
- Email address: email@example.com
- Postal address: 307 Forgeside House, Cardiff Bay Business Centre, Cardiff, CF24 5FA
- Telephone number: 02920488127
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.
By using this website and giving your information to us, you indicate your consent to us and any Third Parties collecting and using your personal information in accordance with the terms set out in this policy.
Purpose of this privacy notice
This privacy notice aims to give you information on how we collect and processes your personal data through your use of this website, including any data you may provide during website use, when you create an account, purchase a product or service or sign up to the marketing (newsletter) preferences of Instant eCare.
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.
Changes to the privacy notice and your duty to inform us of changes
This version was last updated on 12th of November 2019.
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.
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.
We work with a number of affiliate partners and advertising agencies. If you are referred to us through a text link or a banner advertisement on a referrer’s website, we may pay the referrer a commission. None of your identifiable personal data is shared with any of our third party affiliate partners or advertisement agencies.
How We Use Your Information
We are required by law to hold all prescriptions for two years. We will automatically delete prescriptions after two years, but we will still hold a copy of your medical record in our database. We are required to hold patient records for ten years after death. This means we are unable to delete your account even when you request it.
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 you have given your consent to the processing of your personal data for one or more of the Special Categories of Personal Data referred to above.
- Where we need to perform the contract we are about to enter into or have entered into with you, including for order fulfilment, billing and delivery of our services and products.
- 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 it is necessary for compliance with your vital interest.
Click here to find out more about the types of lawful basis that we will rely on to process your personal data.
Unless we are processing Special Categories of Personal Data (regarding your health information, biometric or genetic data or information on your sex life) 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||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 enable you to 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 (d) Profile||(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) Contact(b) Technical(c) 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||Necessary for our legitimate interests (to develop our products/services and grow our business)|
|To advertise to similar audiences and develop customer behavioral targeting through Facebook Custom Audiences.||(a) Contact||Necessary for our legitimate interests (to define types of customers for our products and services, to develop our business and to inform our marketing strategy).|
|Personal information provided by you may be disclosed to a credit reference agency, after consent is given.||(a) Identity (b) Contact (c)Technical||This is to confirm your identity; A soft credit check (also known as soft search) will be performed – they have no impact on your credit score or any future credit applications you might make and your credit rating will not be affected. All information you provide to us will be treated securely and strictly in accordance with applicable data protection legislation.|
|To conduct your treatment review, if required||(a) Identity (b) Contact (c) personal information relevant to condition||For certain conditions you will be directed to complete a pre-consultation before taking part in a 1-2-1 phone/video consultation with our a healthcare professional. Any third party platforms we use to conduct these consultations will remain secure and comply with data protection regulations.|
|To communicate with your general practice relating to your medical condition||(a) Identity (b) contact (c) profile||This is mandatory for patients who are accessing treatments with additional safeguards. Additionally, if you are asked to provide your General Practitioner (GP) details to us, we may also ask your consent to contact your GP in relation to your order. This is a requirement of GPhC (General Pharmaceutical Council) guidelines for online pharmacies, which you can read more about here.|
Updates to our business, similar products or services
If you have already bought medications, treatments or other products from us, we may contact you with information about similar products or important changes to our business/services that we offer under the current PECR regulations.
We have a legitimate interest to contact you for this purpose, but you may object to receiving these messages at any time separate to your marketing preferences. We will only contact you by email or text message. You can choose not to receive these messages by simply following the unsubscribe instructions in the message, or by contacting us.
We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising. You can choose your preference during the account sign-up process or can log-in to your acount dashboard to opt in or out of receiving marketing emails. Alternatively you use the unsubscribe instructions in the marketing emails, or contact us (firstname.lastname@example.org).
Where you opt out of receiving marketing messages, this will not apply to personal data provided to us as a result of a product/service purchase, product/service experience or other transactions.
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.
The Information We May Collect From 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 follows:
- Identity Data includes first name, last name, username or similar identifier, date of birth and gender, as well as the photo identification (passport or driving licence) you upload to our site. We may also introduce facial recognition software and signature recognition in the future.
- Special Categories of Personal Data includes information about your sex life, medical conditions and medical history, your health, genetic and biometric data.
- Contact Data includes billing address, delivery/shipping address, email address and telephone numbers.
- 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 or email address and password, purchases or orders made by you, subscriptions, 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.
We do not collect any other Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sexual orientation, political opinions, trade union membership,). Nor do we collect any information about criminal convictions and offences.
We may also collect sensitive personal data concerning health matters from or about you if you register for the online doctor service, details of transactions you carry out through our site and of the fulfilment of your orders.
How your personal data is 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; or
- Give us some feedback.
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 and Usage Data:
- analytics providers
- advertising networks
- search information providers
- Contact, Financial and Transaction Data from providers of technical, payment and delivery services.
- Identity and Contact Data from publicly available sources such as Companies House, DVLA and the Electoral Register based inside the EU.
- Identification software systems to complete identification checks.
Your medical data and order history is completely confidential and will only be viewable by our pharmacy staff, pharmacists, pharmacist independent prescribers and medical doctors. We will never disclose this data unless legally required to by law. We are committed to protecting and respecting your privacy and to using technology to enhance your online security.
Before you use certain areas of this website we ask you to register on it by requiring you to enter your personal information, including ‘sensitive personal data’ as defined by the Data Protection Act I998 (‘the Act’). In respect of the aforementioned ‘sensitive personal data’ by accepting this Agreement you grant us explicit consent to collect such data. The personal information which we hold, will be held securely in accordance with our internal security policy and the law. To make sure your personal information remains confidential, we communicate these privacy guidelines to all of our employees.
However, we may have to share your personal data with the parties set out below for the purposes set out in the table in “Purposes for which we will use your personal data”, above.
- External Third Parties as set out below.
- Specific Third Parties listed in “Purposes for which we will use your personal data”, 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 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 Parties 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.
External Third Parties
- Service providers such as Google, Microsoft, Amazon, Apple, Facebook, Twitter, Pinterest, LinkedIn, SEMRush, Moz, Customer.io, Dot Digital, Zend Desk, HotJar, SendinBlue, Slack, Glew.io, Crisp.im, Segment and The Doctor’s Lab (and their search information partners e.g. Yahoo) [acting as processors] based outside the EU who provide IT and system administration services.
- Service providers such as Facebook, Twitter, Instagram and Pinterest [actiing as processors] based outsidfe the EU who provide customer behavioral targeting.
- Professional advisers [acting as processors or joint controllers] including lawyers, bankers and auditors and based in the EU who provide consultancy, banking, legal, insurance and accounting services.
- Regulators and other authorities acting as processors or joint controllers based in the United Kingdom who require reporting of processing activities in certain circumstances.
Storing Your Personal Data
In operating our website it may become necessary to transfer data that we collect from you to locations outside of the European Union for processing and storing by the third parties named above (where strictly necessary).
By providing your personal data to us, you agree to this transfer, storing or processing. We do our utmost to ensure that all reasonable steps are taken to make sure that your data is transferred and stored securely.
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.
How long will we use your 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.
We are required to keep prescriptions for two years and patient records (which for Instant eCare is all account information) for ten years after death.
Your legal rights
Under certain circumstances, you have rights under data protection laws in relation to your personal data. 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, including why we have been using your information, what categories of information we were using, who we have shared the information with and how long we envisage holding your information.
- 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 the 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: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) 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; or (d) 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.
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.
Disclosing Your Information
We will not release to any Third Party any personally identifying information obtained in this way, without your prior written consent. We will only use the information that we collect about you lawfully and in accordance with the Act. Exceptional circumstances where your personal information may be disclosed to a Third Party includes; in the event that we sell any or all of our business to the buyer, where we are legally required by law to disclose your personal information, to further fraud protection and reduce the risk of fraud. We will limit the collection and use of such information to the minimum required to deliver, develop and improve our services and other opportunities and the better administration of the consultations.
Please note, if you do turn cookies off this will limit the service that we are able to provide to you and may affect your visitor experience. For further information on cookies and how to switch them off see AllAboutCookies.org.
TheCookies We Use
Strictly Necessary cookies let you move around the website and use essential features like secure areas, shopping baskets and online billing. These cookies don’t gather any information about you that could be used for marketing or remembering where you’ve been on the Internet.
Performance cookies collect information about how you use our website e.g. which pages you visit, and if you experience any errors. These cookies don’t collect any information that could identify you – all the information collected is anonymous and is only used to help us improve how our website works, understand what interests our users and measure how effective our advertising is.
Functionality cookies are used to provide services or to remember settings to improve your visit.
Targeting cookies are linked to the services provided by third parties, such as ‘Like’ buttons and ‘Share’ buttons. The Third Party provides these services in return for recognising that you have visited our website. You can adjust the settings on your computer to decline any cookies if you wish; activating the reject cookies setting on your computer or browser can easily do this. 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.
Support & Information
For more information please contact us via email at email@example.com Instant eCare is regulated by the GPhC and is on the approved registered pharmacy premises register, with the registration number 1124966. The General Pharmaceutical Council (GPhC) is the responsible governing body for the independent regulation of pharmacists, and pharmacy premises in Great Britain.
You can find us on their website http://www.pharmacyregulation.org/.