We are the controller of the personal data provided to us for the purposes of applicable data protection legislation. However, if you book a video consultation with a clinician, we will provide your personal data to your chosen clinician and they will also act as a controller of your personal data.
Whose personal data do we collect?
- Contact Dataincludes data such as your email address, telephone number and correspondence address
- Identity Dataincludes data such as first name, last name, username or similar identifier
- Health Data includes any information you or your clinician provides to us about your health;
- Technical Dataincludes data such as internet protocol (IP) address, your mobile device unique ID, the IP address of your mobile device, your mobile operating system, the type of mobile Internet browser you use, unique device identifiers and other diagnostic data devices you use to access our website and any communications we may send to you.
- Usage Dataincludes information about how you use our website such as information about your visit to our website, including the full Uniform Resource Locators (URL) clickstream to and through, pages you viewed or searches you made, page response times, download errors, length of visit, page interaction information (such as scrolling, clicks, and mouse-overs), and methods used to browse away from the page.
- Marketing Data includes your preferences in receiving marketing messages from us and your communication preferences.
- Financial Data includes any payment information we receive from you, such as bank details and credit or debit card information.
If you provide to us personal data about any other individual, you must have their consent to do so. In particular, if you provide to us information about a person under the age of 18, we may ask for confirmation of your relationship with that person and you confirm you have the lawful right to provide their information to us.
Personal data you provide to us
From time to time you may provide to us personal data. This may be because:
- You access and interact with our website;
- You book a video conference and/or access a video conference with us;
- You request support from us;
- You or your employer provide services to us;
- You apply to work with us;
- You provide feedback or reviews to us, respond to a survey or questionnaire;
- You fill in a form or sign up to receive marketing communications from us;
- You otherwise contact us including with queries, comments or complaints.
All personal data that you provide to us must be true, complete and accurate. If you provide us with inaccurate or false data, and we suspect or identify fraud, we will record this and we may also report this to the appropriate authorities.
When you contact us by email or post, we may keep a record of the correspondence and we may also record any telephone call we have with you.
Personal data we automatically collect about you
When you use our website, we may automatically collect and store information about your Technical Data and Usage Data.
Some of this information is collected using cookies and similar tracking technologies. If you want to find out more about the types of cookies we use, why, and how you can control them, please see our Cookies Policy.
Personal data we receive from others
If we reasonably believe that any of the personal data you have provided to us is inaccurate, we may receive further personal data from third parties, such as credit reference agencies and the electoral register, confirming or otherwise, your identity.
We may also receive personal data about you from our third party service providers, such as our clinicians, payment processing services and our IT service suppliers.
Legal basis for processing your personal data
- consent (where you choose to provide it);
- performance of our contract with you;
- compliance with legal requirements; and
- legitimate interests. When we refer to legitimate interests we mean our legitimate business interests in the normal running of our business which do not materially impact your rights, freedom or interests.
If you wish to book and participate in a video conference with a clinician, we shall use your personal data accordance with our Patient Booking Terms.
If you are a clinician offering services through our website, we shall use your personal data in accordance with the terms we have agreed with your organisation.
We may from time to time need to use your personal data to comply with any legal obligations, demands or requirements, for example, as part of anti-money laundering processes or to protect a third party’s rights, property, or safety.
We may also use your personal data for our legitimate interests including:
- to improve our website and services;
- in connection with, or during negotiations of, any merger, sale of assets, consolidation or restructuring, financing, or acquisition of all or a portion of our business by or into another company;
- to deal and respond to any questions or comments you raise, and any support you request;
- for audit purposes; and
Who do we share your data with?
If you are a clinician offering your services to patients, your name and photograph will be available to all users of our website.
For our legitimate interests, we may also share your personal data with our service providers, sub-contractors and agents that we may appoint to perform functions on our behalf and in accordance with our instructions, including IT service providers, payment providers, accountants, auditors and lawyers. We shall provide our service providers, sub-contractors and agents only with such of your personal data as they need to provide the service for us and if we stop using their services, we shall request that they delete your personal data or make it anonymous within their systems.
If we may need to use your personal data to comply with any legal obligations, demands or requirements, for example, as part of anti-money laundering processes or to protect a third party’s rights, property, or safety then in doing so, we may share your personal data with third party authorities and regulatory organisations and agencies.
Where we hold and process your personal data
Some or all of your personal data may be stored or transferred outside of the United Kingdom and/or European Economic Area (the EEA) for any reason, including for example, if our email server is located in a country outside the United Kingdom or the EEA or if any of our service providers are based outside of the United Kingdom or the EEA.
Where your personal data is transferred outside the United Kingdom and/or the EEA, it will only be transferred to countries that have been identified as providing adequate protection for personal data or to a third party where we have approved transfer mechanisms in place to protect your personal data – i.e., by entering into the European Commission’s Standard Contractual Clauses, or by ensuring the entity is Privacy Shield certified (for transfers to US-based third parties).
We shall process your personal data in a manner that ensures appropriate security of the personal data, including protection against unauthorised or unlawful processing and against accidental loss, destruction or damage. In particular, access is restricted to employees who need to know your personal data, and we use appropriate password protection and appropriate strong encryption electronic measures within our electronic data management systems.
However, unfortunately, because of the nature of electronic storage, we cannot promise that your personal data or any other data you provide to us will always remain secure. If there is a security breach, we will do all that we can as soon as we can to stop the breach and minimise the loss of any data.
You may consent to receive marketing email messages, from us about our website and our services and business generally. You can choose to no longer receive such marketing emails from us by contacting us or clicking unsubscribe from a marketing email. Please note that it may take us a few days to update our records to reflect your request.
If you ask us to remove you from our marketing list, we shall keep a record of your name and email address to ensure that we do not send to you marketing information.
You have a number of rights under applicable data protection legislation. Some of these rights are complex, and not all of the details have been included below. Further information can be found here
- Right of access: You have the right to obtain from us a copy of the personal data that we hold for you.
- Right to rectification: You can require us to correct errors in the personal data that we process for you if it is inaccurate, incomplete or out of date.
- Right to portability: You can request that we transfer your personal data to another service provider if you initially provided consent for us to use the personal data or where we used the personal data to perform a contract with you.
- Right to restrict or object to processing: In certain circumstances, you have the right to require that we restrict the processing of your personal information. If you believe our processing impacts on your fundamental rights and freedoms. However, we may demonstrate that we have legitimate grounds to process your personal data not withstanding your rights and freedoms.
- Right to be forgotten: You also have the right at any time to require that we delete the personal data that we hold for you, where it is no longer necessary for us to hold it. However, whilst we respect your right to be forgotten, we may still retain your personal data in accordance with applicable laws and when we respond to your request we shall notify you of any specific legal reasons that we have to retain your personal data
- Right to stop receiving marketing information: You can ask us to stop sending you marketing information, but please note we shall continue to contact you in relation to any matters relating to your plan, if you have one.
We reserve the right to charge an administrative fee if your request in relation to your rights is manifestly unfounded or excessive.
Retention of personal data
In particular, we shall retain your personal data for as long as you access or use our website. However, we may also be required to retain personal data for a particular period of time to comply with legal, auditory or statutory requirements, including requirements of HMRC in respect of financial documents.
Where we have no legal basis for continuing to process your personal data, we shall either delete or anonymise it or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.
What are cookies?
We also use pixels which are small blocks of code on web pages that do things like allow another server to measure viewing of a webpage and often are used in connection with cookies.
We also use other tracking technologies like web beacons (sometimes called “tracking beacons” or “clear gifs”) and local storage. These are tiny graphics files that contain a unique identifier that enable us to recognise when someone has visited our website or opened an email that we have sent them.
You can find more information about cookies at http://www.allaboutcookies.org/.
Cookies help us to operate our website and provide services to you. In particular, they can:
- make your online experience more efficient and enjoyable, including by recognising you when you return to our website and to customise the website according to your individual interests;
- enhance and customise your experience across our website including by speeding up your searches;
- enable us to perform research and carry out analytics; and
- deliver advertising and marketing that is relevant to you.
Third party cookies enable third party features or functionality to be provided on or through our website, such as advertising, interactive content and analytics. These third-parties are responsible for the cookies they set on our website and we have no control over them
What cookies do we use?
We use the following cookies:
- Operationally necessary cookies. These are cookies that are required for the operation of our website. For instance, cookies to enable you to log in to access our services, or cookies that are needed to take advantage of our e-billing services.
- Performance cookies. These cookies allow us to track how our users use our website, the number of visits on each page, and behaviour on each page. This helps us optimise our website so you can find the things you are looking for and have the best experience possible.
- Functionality cookies. These cookies allows us to recognise you by name and create a more personalised experience for you.
- Targeting cookies. These cookies record your visit to our website, the pages you have visited and the links you may have clicked. We will use this information to curate services and content based on your needs. This information may also be shared with third-party providers.
What technical information do we collect about your device?
We may collect the following information about the device you are using to access our website:
- the type of device you use;
- a unique device identifier, for example, your device’s IMEI number;
- network information;
- your operating system;
- your IP address;
- the browser you are using and what version it is; and
- your time zone setting.
We may collect usage data about your activities on our website, including:
- full Uniform Resource Locators (URL) clickstream to, through and from our online properties (including date and time);
- different types of services/products 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;
How can you control cookies?
To change your cookie settings, or if you want to be notified each time a cookie is about to be used, you should amend the settings provided in your web browser to prevent us from storing cookies on your computer hard drive.
Most advertising networks also offer you the option to opt out of targeted advertising. For more info, visit http://www.aboutads.info/choices/ or http://www.youronlinechoices.com.
You can manage your cookie settings by following your browser’s instructions. Here are some links that might be of assistance:
Last updated:  June 2020