Privacy Policy

Introduction

At AJPharm Ltd T/A Croydon Pharmacy First we are committed to safeguarding and preserving the privacy of our visitors. These 'key points' summarise some of the more important provisions in our privacy policy. We also recommend that you read the full privacy policy.

Information we collect

When you visit our website, we automatically collect and save your IP address. Where you volunteer this information (i.e. by filling in an online form to use our services), we will also save your name, delivery address, email address, date of birth, telephone number, Doctor address, patient notes, consultation notes, payment records and details of the medicines you have ordered.

Use of your information

We use Your Data:

• To provide our services to you (namely, medical consultations for prescription medications) and to comply with regulatory requirements.
• To send you details of our goods and services, or those of other companies within our group, but only if you give us permission to do so.

Patient confidentiality

Some of the information we collect is medical data. This information is always treated confidentially. We will never disclose medical data unless legally required or permitted to do so. It will not be used by us for marketing purposes unless you give us your express permission.

Privacy Policy – The Details

Introduction

AJPharm Ltd T/A Croydon Pharmacy First (registered number 06999357), whose registered office is at 160 Gillett Road, Thornton Heath, United Kingdom, CR7 8SN ("Croydon Pharmacy First", "we", "us" or "our") knows that you care how information about you ("Your Data") is used and shared and we appreciate your trust in us to do that carefully and sensibly. We respect your privacy and are committed to protecting Your Data.

At Croydon Pharmacy First we are committed to safeguarding and preserving the privacy of our customers and website visitors.

This Privacy Policy ("Policy") forms part of our website terms and conditions ("Website Terms"), as set out here. This Policy explains what happens to any personal information that you provide to us, or that we collect from you whilst you visit our site.

We do update this Policy from time to time so please do review this Policy regularly.

Important information about who we are

AJPharm Ltd is a controller and responsible for all personal data it receives and holds. We have appointed a data protection leader ("DPL") who is responsible for overseeing questions in relation to this Policy. If you have any questions about this Policy, including any requests to exercise your legal rights, please contact the DPL using the details set out below:

• Full name of legal entity: AJPharm Ltd
• Name or title of DPL: Raavish Appadoo
• Email address: info@prescriptioncounter.co.uk
• Postal address: AJPharm Ltd, 160 Gillett Road, Thornton Heath, CR7 8SN
• Telephone number: 0203 659 3149

If you have any queries, concerns or complaints about the use of Your Data by us, please raise them with the DPL. If this does not resolve the problem to your satisfaction, or, if you prefer to raise the issue with somebody else, then please speak to Raavish Appadoo who will deal with your complaint.

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. We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.

Changes to the Policy and your duty to inform us of the changes

This version was last updated in October 2022.

It is important that the personal data we hold about you is accurate and current. Please keep us informed if Your Data changes during your relationship with us.

Information We Collect

If you register with us, we will collect personal data or personal information 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 a person's identity has been removed (anonymous data).

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.
• Medical Data includes your patient medical records, Doctor details, patient notes, consultation notes and details of medicines you have ordered and order history. This category of data constitutes sensitive personal data for the purposes of data protection legislation. This will only be collected where you have expressly provided your consent to provide us with this data through any online forms and medical questionnaires you complete and send to us, telephone conversations and secure messaging with us, as well as through photo assessments.
• 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.

How is Your Data collected?

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;
  • complete 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.
• We collect your public profile data only from your consent that you grant before initiating Social Login, from the social network used to login at our website. This data includes your first name, last name, email address, link to your social media profile, unique identifier, link to social profile avatar. This data is used to create your user profile at our website. You can revoke this consent at any time from your profile page at our website or by sending us an email.

Confidentiality

Your Medical Data is treated confidentially, which means that none of our staff can access it unless they are a healthcare professional (or owe a similar duty of confidentiality). We will never disclose Medical Data without your consent unless legally required or permitted to do so.

Your Medical Data will not be used by us to send you information about our products and services (i.e. for marketing purposes) unless you give us your express consent to use your Medical Data this way.

Use of Cookies

You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly. For more information about the cookies we use, please see our Cookie Policy.

Use of Your Information

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

Marketing purposes

We will only contact you for marketing purposes where you have given us your express consent to contact you for this purpose. Once you have given us your permission to contact you for marketing purposes, we may use Your Data for one or more of the following:

• To provide information to you that you request from us relating to our products or services.
• To provide information to you relating to other products that may be of interest to you.
• To allow selected third parties to use Your Data to enable them to provide you with information regarding unrelated goods and services, which we believe may interest you.

You may change your mind and withdraw your permission for us to contact you for marketing purposes at any time by emailing us at info@prescriptioncounter.co.uk. This will not affect your use of our services.

Use of your Medical Data for marketing purposes

Where you have given us your express permission in advance (separately to permitting us to send you more general marketing material), we may also use your Medical Data to send you specialist information about our products and services. For example, if a customer told us that they suffer from asthma and asked us to send them marketing material about asthma related goods and services, we may do so. This information would never be shared with third parties to enable them to send you information regarding their goods and services.

You can change your mind and withdraw your permission for us to use your Medical Data for marketing purposes at any time by emailing us at info@prescriptioncounter.co.uk. This will not affect your use of our services.

Change of purpose

We will only use Your 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 email info@prescriptioncounter.co.uk. Should we need to use Your 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 Data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

Storing Your Personal Data

We have put in place appropriate security measures to prevent Your Data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to Your Data to those employees, agents, contractors and other third parties who have a business need to know. They will only process Your 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.

Please note that sending information via the internet is not totally secure and on occasion such information can be intercepted. We cannot guarantee the security of personal information that you choose to send us electronically and sending such information is entirely at your own risk.

Data retention

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 Medical Data, 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.

Disclosing Your Data

We may disclose Your Data to third parties, in accordance with this Policy, in the following circumstances:

• Where permitted by law and subject to us taking steps to ensure that Your Data is properly protected and only used in accordance with this Policy, we may share your Identity, Contact, Financial and Medical Data with:
  • Your Doctor;
  • Another third party, where you have provided your express consent for us to share Your Data with them.
• We may share your Personal Data with External Third Parties to carry out processing activities on our behalf (for example, we may provide your postal address to a courier or we may share your name, address and age with a third-party service provider in order to verify your age and identity). The External Third Parties we work with include:
  • Viva Payments and Take payments: To process your online payment.
  • Royal Mail: For delivering your order.
  • Google email servers: We send marketing emails to you if you have consented to receive marketing material. We send emails using the Google email servers.
• We may share Marketing and Communications Data where you have provided your express consent for us to share such with third parties for marketing purposes.
• We may also share Your Data where permitted by law:
  • In the event of a joint venture, collaboration, financing, sale, merger or reorganisation of the company. If a change happens to our business, then the new owners may use Your Data in the same way as set out in this Policy.
  • To further fraud protection and reduce the risk of fraud (for example, to comply with anti-money laundering regulations).
• Other than in the specific circumstances set out above we will never share your Medical Data without your express consent.

International transfers

In addition to the disclosures set out in "Disclosing Your Data" above, some of our third parties are based outside the United Kingdom or European Union so their processing of Your Data will involve a transfer of data outside the United Kingdom European Union. Whenever we transfer Your Data out of the United Kingdom or European Union, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

• We will only transfer Your Data to countries that have been deemed to provide an adequate level of protection for personal data by the UK Government or the European Commission.
• Where we use certain service providers, we may use specific contracts approved by the UK Government or the European Commission which give personal data the same protection it has in Europe.

Please email info@prescriptioncounter.co.uk if you want further information on the specific mechanism used by us when transferring Your Data outside the United Kingdom or European Union.

Third Party Links

On occasion we include links to third-party websites, plug-ins and applications on this website. 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 and/or policies. When you leave our website, we encourage you to read the privacy policy of every website you visit.

Your legal rights

In certain circumstances, you have the following rights under data protection laws in relation to Your Data. You have the right to:

• Request access to Your Data (commonly known as a "data subject access request"). This enables you to receive a copy of the Your Data we hold about you and to check that we are lawfully processing it.
• 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 Data. This enables you to ask us to delete or remove Your 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 Data where you have successfully exercised your right to object to processing (see below), where we may have processed Your Data unlawfully or where we are required to erase Your 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 processing of Your Data where we are relying on a legitimate interest (or those of a third party) and there is something about your 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 Data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process Your Data which override your rights and freedoms.
• Request restriction of processing of Your Data. This enables you to ask us to suspend the processing of Your Data in the following scenarios:
  • if you want us to establish the data's accuracy;
  • where our use of Your Data is unlawful, but you do not want us to erase it;
  • where you need us to hold Your Data even if we no longer require it as you need it to establish, exercise or defend legal claims; or
  • you have objected to our use of Your Data, but we need to verify whether we have overriding legitimate and/or legal grounds to use it.
• Request the transfer of Your Data to you or to a third party. We will provide to you, or a third party you have chosen, Your 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 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. Please note that we may not be able to comply with this request where we have a legal obligation to keep Your Data.

If you wish to exercise any of the rights set out above, please email info@prescriptioncounter.co.uk or telephone 0203 659 3149 and ask to speak to the DPL.

Data subject access request

You will not have to pay a fee to access Your Data (or to exercise any of the other rights set out above). 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 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 several requests. In this case, we will notify you and keep you updated.

Contacting Us

Please do not hesitate to contact us regarding any matter relating to this Policy at info@prescriptioncounter.co.uk.