Privacy Policy

BACKGROUND:

Northumbria Pharma Ltd understands that your privacy is important to you and that you care about how your personal data is used. Werespect and value the privacy of everyone who visits this website, www.northumbriahealth.co.uk (“OurSite”) and will only collect and use personal data in ways that are described here, and in a way that is consistent with our obligations and your rights under the law.

Please read this Privacy Policy carefully and ensure that you understand it. Your acceptance of this Privacy Policy is requested when you visit Our Site.

Definitions and Interpretation

In this Policy the following terms shall have the following meanings:

“Account”	means an account required to access and/or use certain areas and features of Our Site;
“Cookie”	means a small text file placed on your computer or device by Our Site when you visit certain parts of Our Site and/or when you use certain features of Our Site. Details of the Cookies used by Our Site are set out in Part 14, below; and
“Cookie Law”	means the relevant parts of the Privacy and Electronic Communications (EC Directive) Regulations 2003;

Information About Us

OurSite is owned and operated by Northumbria Pharma Ltd, a limited company registered in England under company number 10509764.

Registered address: NETPark, Thomas Wright Way, Sedgefield, TS21 3FD

Email address: info@northumbriahealth.co.uk

Telephone number: 01740 617450.

Postal address: NETPark, Thomas Wright Way, Sedgefield, TS21 3FD

What Does This Policy Cover?

This Privacy Policy applies only to your use of OurSite. Our Site may contain links to other websites. Please note that wehave no control over how your data is collected, stored, or used by other websites and weadvise you to check the privacy policies of any such websites before providing any data to them.

What Is Personal Data?

Personal data is defined by the General Data Protection Regulation (EU Regulation 2016/679) (the “GDPR”) and the Data Protection Act 2018 (collectively, “the Data Protection Legislation”) as ‘any information relating to an identifiable person who can be directly or indirectly identified in particular by reference to an identifier’.

Personal data is, in simpler terms, any information about you that enables you to be identified. Personal data covers obvious information such as your name and contact details, but it also covers less obvious information such as identification numbers, electronic location data, and other online identifiers.

What Are My Rights?

Under the Data Protection Legislation, you have the following rights, which we will always work to uphold:

The right to be informed about our collection and use of your personal data. This Privacy Policy should tell you everything you need to know, but you can always contact us to find out more or to ask any questions using the details in Part 15.
The right to access the personal data wehold about you. Part 13 will tell you how to do this.
The right to have your personal data rectified if any of your personal data held by usis inaccurate or incomplete. Please contact us using the details in Part 15 to find out more.
The right to be forgotten, i.e. the right to ask us to delete or otherwise dispose of any of your personal data that we hold. Please contact us using the details in Part 15 to find out more.
The right to restrict (i.e. prevent) the processing of your personal data.
The right to object to ususing your personal data for a particular purpose or purposes.
The right to withdraw consent. This means that, if we arerelying on your consent as the legal basis for using your personal data, you are free to withdraw that consent at any time.
The right to data portability. This means that, if you have provided personal data to usdirectly, we areusing it with your consent or for the performance of a contract, and that data is processed using automated means, you can ask usfor a copy of that personal data to re-use with another service or business in many cases.
Rights relating to automated decision-making and profiling. Wedo not use your personal data in this way.

For more information about ouruse of your personal data or exercising your rights as outlined above, please contact ususing the details provided in Part 15.

It is important that your personal data is kept accurate and up-to-date. If any of the personal data we hold about you changes, please keep usinformed as long as wehave that data.

Further information about your rights can also be obtained from the Information Commissioner’s Office or your local Citizens Advice Bureau.

If you have any cause for complaint about our use of your personal data, you have the right to lodge a complaint with the Information Commissioner’s Office. We would welcome the opportunity to resolve your concerns ourselves, however, so please contact usfirst, using the details in Part 15.

What Data Do You Collect and How?

Depending upon your use of OurSite, we may collect and hold some or all of the personal and non-personal data set out in the table below, using the methods also set out in the table. Please also see Part 14 for more information about our use of Cookies and similar technologies. Wedo not collect any ‘special category’ or ‘sensitive’ personal data or personal data relating to children or data relating to criminal convictions and/or offences.

We may collect, use, store and transfer different kinds of data about you which we have categorised as follows:

Identity Data includes first name, last name, date of birth and gender.
Contact Data includes delivery address email address and telephone numbers.
Financial Data includes bank account, payment records and payment card details.
Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.

We also collect and use Aggregated Data such as statistical or demographic data for internal purposes. Aggregated Data may be derived from Your Data but is not personal data as it does not directly or indirectly reveal your identity. For example, we may aggregate information about how you use our website and services to calculate the percentage of users accessing a specific website feature, but this is anonymised. However, if we combine or connect Aggregated Data with Your 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 Policy.

We use different methods to collect data from and about you, including through:

Automated technologies or interactions If you interact with our website, we may automatically collect data about your equipment, browsing actions and patterns. When you visit our website, we automatically collect information about your use of our site including details of your visits such as pages viewed and the resources that you access. Such information may include Aggregated Data, traffic data, location data and other communication data. For more information about the cookies we use, please see our Cookie Policy.

Direct interactions You may give us your Identity, Contact, Medical 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:

make an online enquiry;
completing forms and medical questionnaires on our website. This includes information provided at the time of registering to use our site, subscribing to our service, consultations for treatments, posting material or requesting further services;
make an online payment;
subscribe to our services or publications;
request marketing material to be sent to you;
provide us with feedback.

How Do You Use My Personal Data?

Under the Data Protection Legislation, wemust always have a lawful basis for using personal data. We will only use the information that we collect from you as follows:

To enable us to provide our health services to you
To enable us to comply with regulatory requirements
To communicate with you in the event that there is a query or problem with your order
To inform you of any changes to our website, services or goods and products
For record keeping purposes
To track and analyse activity on our website

With your permission and/or where permitted by law, wemay also use your personal data for marketing purposes, which may include contacting you by email or telephone or text message or post with information, news, and offers on ourproducts orservices. You will not be sent any unlawful marketing or spam. Wewill always work to fully protect your rights and comply with our obligations under the Data Protection Legislation and the Privacy and Electronic Communications (EC Directive) Regulations 2003, and you will always have the opportunity to opt-out.Wewill always obtain your express opt-in consent before sharing your personal data with third parties for marketing purposes and you will be able to opt-out at any time.

Third parties whose content appears on OurSite may use third-party Cookies, as detailed below in Part 14. Please refer to Part 14 for more information on controlling cookies. Please note that wedo not control the activities of such third parties, nor the data that they collect and use themselves, and weadvise you to check the privacy policies of any such third parties.

Wewill only use your personal data for the purpose(s) for which it was originally collected unless wereasonably believe that another purpose is compatible with that or those original purpose(s) and need to use your personal data for that purpose. If wedo use your personal data in this way and you wish usto explain how the new purpose is compatible with the original, please contact ususing the details in Part 15.

If weneed to use your personal data for a purpose that is unrelated to, or incompatible with, the purpose(s) for which it was originally collected, wewill inform you and explain the legal basis which allows usto do so.

In some circumstances, where permitted or required by law, we may process your personal data without your knowledge or consent. This will only be done within the bounds of the Data Protection Legislation and your legal rights.

How Long Will You Keep My Personal Data?

We will only retain Your 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 Your Data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of Your Data, the purposes for which we process Your Data and whether we can achieve those purposes through other means, and the applicable legal requirements.

During the provision of our services to you we will retain Your Data to provide our goods or services to you.

We are required by law to retain specific categories of Your Data for certain periods after we stop providing our goods or services to you. We are therefore required to store any Identity Data and Contact Data submitted to us to comply with our legal obligations.

Please note that we may keep Your Data for longer than the periods stated above if it is necessary. However, this will be assessed on a case by case basis. If we determine that it is necessary to keep Your Data for longer than the periods listed above, we will confirm this to you in writing when we have finished providing our goods and services to you and explain why it is necessary.

How and Where Do You Store or Transfer My Personal Data?

The data that we collect from you will be transferred to, and stored at, a destination within the European Economic Area (“EEA“). It will also be processed by staff operating within the EEA who work for us or for one of our suppliers. This includes staff engaged in, among other things, the fulfilment of your order, the processing of your payment details and the provision of support services. By submitting your personal data, you agree 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.

All information that you provide to us is stored on our secure servers. Any payment transactions will be encrypted using SSL technology. Where we have given you (or where you have chosen) a password which enables you to access certain parts of our site, you are responsible for keeping this password confidential. We ask you not to share your 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.

Do You Share My Personal Data?

Details of whom we will share your data with and why is set out in our Data Record. Copies of our Data Record are available from our data protection officer.

Sharing your information within our company and partners

We share the information that you provide to us with our staff so that we can provide our products and services to you.

We may share the information that you provide to us with other partner companies and other websites that we operate. For example, if you place an order online, we may share information with the prescribing doctor to enable you to receive the prescription and also the pharmacy to arrange despatch to you via post.

Sharing your information with third parties

We may share your information with selected third parties including:

advertisers and advertising networks that require the data to select and serve relevant adverts to you and others. We do not disclose information about identifiable individuals to our advertisers, but have the right to provide them with aggregate information about our users. We may make use of the personal data that we have collected from you to enable us to comply with our advertisers’ wishes by displaying their advertisement to that target audience;

analytics and search engine providers that assist us in the improvement and optimisation of our site; and

credit reference agencies for the purpose of assessing your credit score where this is a condition of us entering into a contract with you.

There are certain exceptional circumstances in which we may disclose your information to other third parties. This would be where we believe that the disclosure is:

required by the law, or in order to comply with judicial proceedings, court orders or legal or regulatory proceedings;

necessary to protect the safety of our employees, our property or the public;

necessary for the prevention or detection of crime, including exchanging information with other companies or organisations for the purposes of fraud protection and credit risk reduction; and/or

proportionate as part of a merger, business or asset sale, in the event that this happens we will share your information with the prospective seller or buyer involved.

How Can I Control My Personal Data?

In addition to your rights under the Data Protection Legislation, set out in Part 5, whenyou submit personal data via OurSite, you may be given options to restrict ouruse of your personal data. In particular, weaim to give you strong controls on ouruse of your data for direct marketing purposes (including the ability to opt-out of receiving emails from uswhich you may do by unsubscribing using the links provided in our emailsat the point of providing your details and by managing your Account).
You may also wish to sign up to one or more of the preference services operating in the UK: The Telephone Preference Service (“the TPS”), the Corporate Telephone Preference Service (“the CTPS”), and the Mailing Preference Service (“the MPS”). These may help to prevent you receiving unsolicited marketing. Please note, however, that these services will not prevent you from receiving marketing communications that you have consented to receiving.

Can I Withhold Information?

You may access certain areas ofOurSite without providing any personal data at all. However, to use all features and functions available on OurSite you may be required to submit or allow for the collection of certain data.

You may restrict use of Cookies. For more information, see Part 14 and our Cookie Policy.

How Can I Access My Personal Data?

If you want to know what personal data wehave about you, you can ask usfor details of that personal data and for a copy of it (where any such personal data is held). This is known as a “subject access request”.

All subject access requests should be made in writing and sent to the email or postal addresses shown in Part 15. To make this as easy as possible for you, a Subject Access Request Form is available for you to use. You do not have to use this form, but it is the easiest way to tell useverything weneed to know to respond to your request as quickly as possible.

There is not normally any charge for a subject access request. If your request is ‘manifestly unfounded or excessive’ (for example, if you make repetitive requests) a fee may be charged to cover ouradministrative costs in responding.

We will respond to your subject access request within 2 weeks and, in any case, not more than one month of receiving it. Normally, weaim to provide a complete response, including a copy of your personal data within that time. In some cases, however, particularly if your request is more complex, more time may be required up to a maximum of three months from the date wereceive your request. You will be kept fully informed of ourprogress.

How Do You Use Cookies?

Our site uses cookies to distinguish you from other users of our site. This helps us to provide you with a good experience when you browse our site and also allows us to improve our site. By continuing to browse our site, you are agreeing to our use of cookies.

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

We use the following cookies:

Strictly necessary cookies: These are required for the operation of our site. They include cookies that enable you to log into secure areas of our site, use the shopping cart, or make use of e-billing services.

Analytical/performance cookies: These allow us to track the number of visitors to our site. This helps us to improve the way our site works, for example by ensuring that users are finding what they are looking for easily.

Functionality cookies: These are used to recognise you when you return to our site, enabling us to personalise our content for you, greet you by name and remember your preferences.

Targeting cookies: These cookies record your visit to our site, the pages you have visited and the links you have followed. We will use this information to make our site and the advertising displayed on it more relevant to your interests. We may also share this information with third parties for this purpose.

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.

You can 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

How Do I Contact You?

To contact about anything to do with your personal data and data protection, including to make a subject access request, please use the following details for the attention of Paul Watson:

Email address: info@northumbriahealth.co.uk.

Telephone number: 01740 617 450.

Postal Address: NETPark, Thomas Wright Way, Sedgefield, TS21 3FD.

Changes to this Privacy Policy

Wemay change this Privacy Notice from time to time. This may be necessary, for example, if the law changes, or if wechange our business in a way that affects personal data protection.

Any changes will be immediately posted on OurSite and you will be deemed to have accepted the terms of the Privacy Policy on your first use of OurSite following the alterations. Werecommend that you check this page regularly to keep up-to-date. This Privacy Policy was last updated on 20^th May 2020.