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Privacy Policy

 

General

 

Welcome to the privacy policy of Instant e-Care Limited trading as “Instant eCare”.

 

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  respect the privacy of visitors to our website and we are committed to protecting your personal information. This notice describes our privacy policy and forms part of our terms and conditions.

 

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: dpo@instantecare.co.uk
  • 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 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 through this website when you sign up to our newsletter or purchase a product or 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.

 

Changes to the privacy notice and your duty to inform us of changes

 

This version was last updated on 31 May 2018 and historic versions are archived here.

 

The data protection law in the UK will change on 25 May 2018. Although this privacy notice sets out most of your rights under the new laws, we may not yet be able to respond to some of your requests (for example, a request for the transfer of your personal data) until May 2018 as we are still working towards getting our systems ready for some of these changes.

 

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 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 and 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 and 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.

 

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, sessions, 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  below 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:
      1. analytics providers such as Google based outside the EU;
      2. advertising networks such as Google, Microsoft, Amazon, Apple, Facebook, Twitter, Pinterest, LinkedIn (and their advertising partners e.g. Yahoo and Instagram) based outside the EU ; and
      3. search information providers such as Google, Microsoft, Amazon, Apple, Facebook, Twitter, Pinterest, LinkedIn, SEMRush, Moz (and their search information partners e.g. Yahoo) based outside the EU.
  • Contact, Financial and Transaction Data from providers of technical, payment and delivery services such as Payvision, KingPay Payment and Elavon based inside the EU.
  • Identity and Contact Data from publicly available sources such as Companies House, DVLA and the Electoral Register based inside the EU.

 

How We Use Your Information

 

All personal information that we obtain about you and/or any other person whose details you provide will be recorded, used, and protected by us in accordance with current data protection legislation, our Terms of Use and this Privacy Policy.

 

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 goods and services.
  • 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 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

(c) Notifying you about changes to products, including product recalls and safety notices

(a) Identity

(b) Contact

(c) Profile

(d) Marketing and Communications

(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 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) Technical

(b) 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)

 

Marketing

 

We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising. You can log-in to your account dashboard to opt in or out of receiving marketing emails. (This functionality is currently being built into the website, so to opt out of marketing click the unsubscribe button in a marketing email or send an email to support@instantecare.co.uk.)  

 

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 (we call this marketing).

 

You will receive marketing communications from us if you have requested information from us or purchased goods or services from us and, in each case, you have opted into receiving that marketing.

 

Opting out

 

You can ask us or third parties to stop sending you marketing messages at any time by logging into your account dashboard and unchecking the relevant box 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.

 

Where you opt out of receiving these 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.

 

Patient Confidentiality

 

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-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.

 

External Third Parties

  • Service providers such as Google, Microsoft, Amazon, Apple, Facebook, Twitter, Pinterest, LinkedIn, SEMRush, Moz, Customer.io, 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.
  • 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.

 

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.

 

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:

    1. 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.
    2. 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.
    3. 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.
    4. Object to 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.
    5. 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.
    6. 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.
    7. 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.

 

If you wish to exercise any of the rights set out above, please contact us at support@instantecare.co.uk.

 

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.

 

Cookies

 

Cookies are small text files that are placed on your computer by websites that you visit. They are widely used to make websites work, or work more efficiently, as well as provide information to us. Our cookies enable us to develop our website to reflect our customers’ interests, and to note who has seen which pages, properties and advertisements (including click through from emails). They also monitor how frequently particular pages are visited, allowing us to determine the most popular areas of our website. We may use cookies to enrich your experience using the website by tailoring what you see to what we have learned about your preferences during your visits to the site.

 

Most browsers automatically accept cookies, but you can usually change your browser to prevent cookies being stored. We may use cookies where appropriate to gather information about your computer in order to assist us in improving our website. We may gather information about your general Internet use by using the cookie. Where used, these cookies are downloaded to your computer and stored on the computer’s hard drive. Such information will not identify you personally. It is statistical data. This statistical data does not identify any personal details whatsoever.

 

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.

 

The Cookies 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 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 support@instantecare.co.uk. 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/.