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Privacy Policy

 

Fully regulated

At The Independent Pharmacy we take the privacy of our customers seriously. We are a leading online pharmacy in the UK, and are registered with the General Pharmaceutical Council (GPhC - who regulate pharmacies), Medicines Health Regulatory Authority (MHRA - who regulate online medicine sales) and the Care Quality Commission (CQC - who regulate GPs). We are registered with the Information Commissioner's Office (ICO - who uphold data privacy laws) as a data controller under the Data Protection Act 1998 and General Data Protection Regulation (GDPR). For more information see our full regulations page.

 

Taking your privacy seriously

We respect your right to privacy and are committed to providing clear and honest information to explain how we use the information you give us.

We always use the minimum data required to provide our services, regularly review our data processing, and ensure that our security is regularly monitored.

We will never sell your data or use your information in a way that we believe is not in your best interests.

 

Who controls the data you provide?

This Website is owned and operated by ABSM Healthcare Ltd ('we', 'us', 'our'), trading as The Independent Pharmacy, to users and visitors ('you', 'your'). GP services and prescribing are undertaken by Red Label Medical Ltd, also operating under the trading name The Independent Pharmacy.

Our address is: The Independent Pharmacy, Unit 3 Heston House, 7-9 Emery Road, Bristol, BS4 5PF.

You can phone us on 0333 2200 519 or email us at support@theindependentpharmacy.co.uk

We take your privacy very seriously, and we are committed to protecting and respecting your privacy, and to using technology to enhance your online security. We ask that you read this Privacy Policy ('the Policy') carefully as it contains important information about how we will use your personal data. 

Please read this privacy policy carefully. By using our website and services, you are confirming that you agree to the terms of this privacy policy. If you do not agree to this privacy policy, do not use our website or services. You will be asked for explicit consent to this policy when completing a consultation on this website.

For the purposes of the Data Protection Act 1998, ABSM Healthcare Ltd is the 'data controller' (the company which is responsible for and controls the processing of your personal data).

ABSM Healthcare is registered with the Information Commissioner's Office with the registration number ZA024585.

Note: We may change or update this Policy from time to time. You should check this Policy occasionally to ensure you are aware of the most recent version that will apply each time you access this Website.

This Policy explains:

  • What information we may collect from you.
  • The types of cookies we use and how you can reject these cookies.
  • Where we store your personal data.
  • How we keep your information secure.
  • What we do with your data.
  • Uses we make of your data.
  • To whom we may disclose your data.
  • Your rights.


Information we may collect from you

In this Policy your "data" means information or pieces of information relating to you or that could allow you to be directly or indirectly identified.

We may collect and process the following data about you:

Information you voluntarily provide

  • Information that you provide by filling in forms and medical questionnaires on our website. This includes information provided at the time of accessing our website, subscribing to our services, or requesting further services. This includes your name, delivery address, email address, date of birth, telephone number, GP address, patient notes, consultation notes, payment records and details of the medicines you have ordered.
  • If you contact us, we may keep a record of that correspondence.
  • We may also ask you to complete surveys that we use for research purposes, although you do not have to respond to them.
  • Details of transactions you carry out through our website and of the fulfilment of your orders.

 

Information we collect from the device you use to access our website

When you visit our website or interact with our services, we (and our advertisers and/or other service providers) may use a variety of technologies that automatically or passively collect information about how our services are accessed and used including:

 

Technical device information

  • the type of device you use (e.g are you using an Apple or a Samsung device);
  • a unique device identifier (for example, your device's IMEI number or the MAC address of the device's wireless network interface);
  • network information (e.g are you on the 3 network or BT Broadband);
  • your operating system;
  • your IP address and HTTP referrer information;
  • your login information;
  • the browser you are using and what version it is (e.g. are you using the Chrome or Safari browser?);
  • time zone setting (e.g. GMT, EST?).

 

Other information about your visit 

  • the full Uniform Resource Locators (URL) clickstream to, through and from our website (including date and time);
  • 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), and methods used to browse away from the page;
  • any phone number used to call our customer service number.

 

Information we receive from other sources 

We work 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 may receive information about you from them.

 

Cookies and other similar technologies

Cookies are small pieces of data that are stored on your computer, mobile phone or other device. We use cookies to distinguish you from other users of our Site (including when you browse other third party websites). This helps us to provide to provide you with a good experience when you browse our Site. We also use cookies and similar technologies to show you more personalised advertising, including The Independent Pharmacy ads on other websites.

By using our Site, you agree to our use of cookies. Our Cookie Policy explains what cookies, including third party cookies, we use on our Site, and how you can refuse or withdraw your consent to cookies.

 

Where we store your personal data

We ensure that all of the data that The Independent Pharmacy holds about you is stored within the UK. However, the data that we collect from you may be transferred to, and stored at, a third party in a destination outside the European Economic Area ("EEA"). This will always be the minimum required information to carry out the task required and the data is anonymised. An example of this include anonymous website browsing data that is aggregated within Google Analytics.

We check that all of out third party suppliers are GDPR compliant before we engage their services to ensure any data is handled responsibly. By submitting your personal data, you acknowledge and consent to this transfer, storing or processing. We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this privacy policy.

 

Information security

At The Independent Pharmacy, we take your online security very seriously and look to protect all the data you provide to a high standard. All data, including; personal, medical and payment data, is 128-bit encrypted prior to transmission.

Our servers are monitored constantly and are protected by firewalls and the latest security updates, which cannot be directly accessed via the Internet. Our servers are regularly scanned to ensure that they meet PCI (Payment Card Industry) security standards.

We do not store your payment details, our payment gateway is provided by Sage Pay who are Level 1 PCI DSS compliant. You can find out more about their high-security standards at https://www.sagepay.co.uk/policies/security-policy

Where you have chosen a password which enables you to access certain parts of our website, 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. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our site; 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.

You can find more information on protecting your information and staying safe online here.

 

Uses made of your data

We use information held about you in the following ways:

  • To ensure that content from our website is presented in the most effective manner for you and for your computer.
  • To provide you with information, products or services that you request from us or which we feel may interest you, where you have consented to be contacted for such purposes including responding to your queries or comments.
  • To carry out our obligations arising from any contracts entered into between you and us. You understand that in order to provide our services to you we need to share your personal data (including sensitive medical data) with doctors and non-medical staff working at or with ABSM Healthcare Limited, Red Label Medical Ltd and our partner laboratory working with us to deliver medical services to you. We ensure that any personal data we disclose in accordance with our Policy is kept to the minimum required to allow the safe and effective delivery of services to you.
  • You also understand and agree, that we will use a third party delivery companies, such as Royal Mail and DPD (“Delivery Providers”), to deliver medicines to you.  We do not and cannot take responsibility for the errors of Delivery Providers.  For example, we are not responsible if your medicine is accidentally delivered to your neighbour.
  • To allow you to participate in interactive features of our services, when you choose to do so.
  • To notify you about changes to our services.
  • to provide and follow up the services you request from us and to request your feedback
  • to communicate with you in the event that any services requested are unavailable or if there is a query or problem with your order for record keeping purposes

By using our service you consent to ABSM Healthcare Limited using third party products and services to collect & analyse information about your use of the services. By doing this we aim to provide a better and more personalised and a continuous service for each of our customers and to use this information for marketing & administration purposes, as follows:

  • Analysing individual and aggregate customer data
  • Carrying out market research
  • Identifying and executing improvements to our services
  • Providing marketing communications to you about ABSM Healthcare Limited & partner products, services & offers
  • Informing you of changes to our services.

We will never sell your data! You understand that third party services that ABSM Healthcare Limited uses change from time-to-time and may not always be reflected concurrently in this Privacy and Cookie Policy. From time to time we may also use your data, or permit selected third parties to use your data, to receive feedback about our services or to provide you with information about our goods and services which may be of interest to you. We or they may contact you about these by SMS, Email, post or telephone. ABSM Healthcare Limited reserves the right to change third party service providers and will use best endeavours to notify you as soon as reasonably practicable each time ABSM Healthcare Limited adds or removes a third party service provider.

 

Disclosure of your information

If you order a product or service from us, we may share your personal data with our suppliers and other third parties to allow delivery of the products and services you have ordered. Any such suppliers or third parties are not authorised by us to use your personal data in any other way and will be required by us to implement measures to protect your personal data.

We may disclose your personal information to third parties:

  • In the event that we sell or buy any business or assets, in which case we may disclose your personal data to the prospective seller or buyer of such business or assets.
  • If ABSM Healthcare Ltd or substantially all of its assets are acquired by a third party, in which case personal data held by it about its customers will be one of the transferred assets.
  • If we are under a duty to disclose or share your personal data in order to comply with any legal obligation, or in order to enforce or apply our Terms & Conditions and other agreements; or to protect the rights, property, or safety of ABSM Healthcare Limited, our customers, or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction.
  • In order to detect, prevent or otherwise address fraud, security or technical issues.

Currently, The Independent Pharmacy works with the following third party service providers as standard:

  • MailGun - to send necessary email communications, such as order confirmation and dispatch emails (https://www.mailgun.com/privacy-policy);
  • Trustpilot - to solicit, collate & display reviews of products & services (https://uk.legal.trustpilot.com/end-user-privacy-terms)
  • Google Analytics, Google Tag Manager, & Google Optimize - to help us analyse how people use its websites and, identify and test improvements (https://www.google.com/policies/privacy/). You can decline cookies from Google Analytics by clicking on this link: https://tools.google.com/dlpage/gaoptout
  • Bing Ads - to help us analyse how people use of our websites and identify improvements; to measure the effectiveness of advertisements and communications; to provide relevant advertisements and communications to users (https://privacy.microsoft.com/en-gb/privacystatement)
  • Google Adwords - to help us analyse how people use of our websites and identify improvements; to measure the effectiveness of advertisements and communications; to provide relevant advertisements and communications to users (https://policies.google.com/technologies/ads)
  • Algolia - to power our website search functionality (https://www.algolia.com/doc/faq/security-privacy/gdpr/)
  • Awin - to track referrals from affiliates (https://www.awin.com/gb/terms-and-conditions/publisher-terms-and-conditions-2018)
  • SagePay - to process secure payments on our website (https://www.sagepay.co.uk/policies/privacy-policy)
  • Royal Mail - to deliver orders placed on our website, including providing delivery updates by email or SMS (https://www.royalmail.com/privacy-notice & https://www.royalmail.com/gdpr)
  • DPD Local - to deliver orders placed on our website, including providing delivery updates by email or SMS (https://www.dpdlocal.co.uk/gdpr.pdf)

The Independent Pharmacy also works with the following third parties in certain situations:

If you do not want us to use your data in this way, or to pass your details on to our selected third parties to collect & analyse information about your use of the services please do not agree to this policy and do not use our services. If you do not want The Independent Pharmacy to send you marketing communications, please do not opt in for this service. 

If you opt in to receive marketing communications, you can change your marketing preferences in your account or click the unsubscribe link that you will find at the bottom of every email we send to you.

 

Monitoring

We may monitor and record communications with you such as telephone conversations and emails for the purpose of training, quality assurance, fraud prevention and compliance. 

 

Identity Verification

To enable us to make medical decisions about you and for fraud prevention purposes, we use identity verification agents to search the files of credit reference and fraud prevention agencies (who will record the search).

If you provide false or inaccurate information and/or we suspect fraud, we will record this and we will be unable to fulfil your order.

Where we need to share information with our service providers, we give them only the minimum amount they need to provide services to us and you. Those we share your information with are not allowed to use it to try to sell their own services to you.

For ID verification purposes, we share your your name, date of birth, address (and if needed passport or driving license number) with Onfido and LexisNexis who use it to verify your identity. This is only done the first time you order or if you update your personal details. This check may appear on your credit record, however will not affect your credit score. If you are alerted that a check has been performed by a credit agency, please contact us and we will be happy to help. 

 

Information about other individuals

As we are unable to verify the identity of an individual or gauge patient consent for treatment or data processing, we are unable to accept orders made on the behalf of others.

 

Your rights

You have the right to ask us not to process your personal data for marketing purposes. We will usually inform you (before collecting your data) if we intend to use your data for such purposes. You can exercise your right to prevent such processing by selecting this option in your account or by checking certain boxes on the forms we use to collect your data. You can also exercise the right at any time by contacting us at ABSM Healthcare Ltd, Unit 3 Heston House, 7-9 Emery Road, Bristol, BS4 5PF or email: support@theindependentpharmacy.co.uk. Likewise you can contact us if you wish to report any violations of the Privacy Policy - see ‘Contact’ below.

Our website 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.

When you use our services, we make good faith efforts to provide you with access to your personal information and either to correct this data if it is inaccurate or to delete such data at your request, if it is not otherwise required to be retained by law or for legitimate business purposes. You can ask us to suspend the account you created on our website by emailing us support@theindependentpharmacy.co.uk

If you would like to discontinue The Independent Pharmacy as a patient you can email us and we will suspend your account. Your account will become inactive with immediate effect and you will not be able to access your account. This action cannot be undone. You acknowledge and agree that The Independent Pharmacy is required by law to archive electronic patient records including your personal information, communication and treatments for a minimum of 10 years.

 

Access to information

The Act gives you the right to access information held about you. Your right of access can be exercised in accordance with the Act. You can exercise the right at any time by sending us a request in writing to: The Independent Pharmacy, Unit 3 Heston House, 7-9 Emery Road, Bristol, BS4 5PF. We will endeavour to provide the requested information within 28 days.

 

Updating and correcting information

You are able to update or correct your personal information online via your account. We encourage you to promptly update your personal information if it changes. If you are providing updates or corrections about another person, we may require you to provide us with proof that you are authorised to provide that information to us.

 

Changes to our Policy

Any changes we may make to our Policy in the future will be posted on this page and, where appropriate, notified to you by email.

 

Contact

Questions, comments, requests, and concerns regarding this Privacy Policy are welcomed and should be addressed to support@theindependentpharmacy.co.uk

The data protection officer for The Independent Pharmacy is Andy Boysan.

If you believe that a request or concern has not been handled to your satisfaction, you can raise your concern with the Information Commissioner's Office (https://ico.org.uk), the UK independent regulator of data controllers and privacy.

 

Updated: 29/08/2018

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