Website Privacy Policy

PRIVACY POLICY

Introduction

Welcome to Cambridge Women’s Health Limited’s privacy policy. 

Cambridge Women’s Health respects your privacy and is committed to protecting your personal data, keeping it safe and secure, and handling it in accordance with our legal obligations. This privacy policy will inform you in detail as to how we look after your personal data when you visit our website (regardless of where you visit it from), including the purposes for which we process your personal information, what rights you have in relation to that information, who we share it with and everything else we think is important for you to be aware of. 

 

• Important information and who we are

Purpose of this privacy policy

This privacy policy aims to give you information on how Cambridge Women’s Health Limited collects and processes your personal data through your use of this website and receipt of goods or services, including any data you may provide through this website when you book an appointment, send a contact us request, or purchase a product or service. It also applies to any personal information we collect about you by telephone, in person, by post, from third parties and when you otherwise communicate with us.

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 policy together with any other privacy policy or fair processing policy 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 policy supplements other notices and privacy policies and is not intended to override them. If you don’t agree with this privacy policy, then you shouldn’t use our website or purchase any goods/services from us. This is because by accessing our website or purchasing goods/services, you confirm that you accept the way in which we process your personal information. 

Controller

Cambridge Women’s Health Limited (collectively referred to as “COMPANY”, “we”, “us” or “our” in this privacy policy) is the data controller and responsible for your personal data processed in accordance with this privacy policy,. 

We have appointed a data privacy manager who is responsible for overseeing questions in relation to this privacy policy. If you have any questions about this privacy policy, including any requests to exercise your legal rights, please contact the data privacy manager using the details set out below. 

Contact details

If you have any questions or concerns about this privacy policy or our privacy practices, please contact our data privacy manager in the following ways:

Full name of legal entity: Cambridge Women’s Health Limited

Data privacy manager and their email address: Susanna Unsworth, susanna@cambridgewomenshealth.co.uk

Registered office address: First Floor Victory House, Vision Park, Chivers Way, Histon, Cambridge, United Kingdom, CB24 9ZR

If you have any cause for complaint about our use of your personal data, please contact us using the details provided in section 9 and we will do our best to solve the problem for you. You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK regulator 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. 

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

We keep our privacy policy under regular review. We may update this privacy notice from time to time as necessary (for example, if the law changes or if we change our business in a way that affects personal data protection). The terms that apply to you are those posted here on our website on the day you use our website. We advise you to print a copy for your records. We will also tell you about any important changes to our Privacy Policy. 

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. This privacy policy only applies to the personal information that we collect from you and we cannot be responsible for personal information collected and stored by third parties. 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 or privacy handling practices. When you leave our website and before you submit any personal information to those websites, we encourage you to read the privacy policy of every website you visit. 

If you give us information on behalf of someone else, by doing so you confirm that the other person has agreed that you can give consent on his/her behalf to the processing of their data and receive on their behalf any data protection notice.

• The data we collect about you

Personal data, or personal information, means any information about a living individual from which that person can be identified (directly or indirectly). 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. 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 as follows:

• Identity and Contact Data includes first name, last name, username or similar identifier, marital status, title, date of birth, gender, billing address, delivery address, email address and telephone numbers. This enables us to personally and uniquely identify and communicate with you, to deliver on our contractual obligations with you and to provide you with any products or services you have signed up to or purchased.
• Transaction and Financial Data includes bank account and payment card details, details about payments to and from you and other details of products and services you have purchased from us. Where we take any form of payment, we record payment and transaction data, to keep financial and security records for our business and to comply with our legal obligations to retain financial and transaction information. We also keep a record of where payments have been successful or have failed against an individual’s details in our systems.
• 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. This enables us to uniquely identify you and to distinguish you from other people. In turn, it enables us to deliver you a more personalised service.
• Profile and Usage Data includes your username and password, purchases or orders made by you, how you use our website, products and services, your interests, preferences, feedback and survey responses.  When someone signs up with us, we may generate unique identifiers (e.g. a number) as a mechanism to identify them across our technical systems, and to link that person with their preferences, history with us, interaction analytics and user service history.
• Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences. We store your preferences so we know how to communicate with you (e.g. for marketing or sending service communications), and in some cases, how not to communicate with you.

We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data could be derived from your personal data but is not considered personal data in law as this data will 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 policy.

Special Category Personal Data

We also collect sensitive confidential data known as “special category personal data”, in the form of health records (including personal and family medical history) and information, religious belief (if required in a healthcare setting), ethnicity, and sex during the services we provide to you and or linked to your healthcare through other health providers or third parties. This enables us to properly provide any medical consultation services we offer and accurately make diagnoses and recommend prescription medications. By filling out our health questionnaires and providing us with such information, you explicitly consent to our processing such data for these purposes.

If you fail to provide personal data

Where we need to collect personal data by law, or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with goods or services). In this case, we may have to cancel a service you have with us but we will notify you if this is the case at the time. 

• How is your personal data collected?

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

• Direct interactions. You may give us your Identity, Contact, Health 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:

• Apply for our products or services;
• create an account when booking an appointment on our website;
• subscribe to our service or publications; 
• request marketing to be sent to you;
• complete a health questionnaire; or
• give us feedback or contact us. 

• Automated technologies or interactions. As you interact with our website, we will automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies and other similar technologies. 
• Third parties or publicly available sources. We may receive personal data about you from other menopausal health services, including but not limited to Menopausal Not Mad, being an online menopause/HRT community and consultation provider run by Jane Pangbourne. Any personal data shared with us in this way will be subject to your express consent and in accordance with the terms of their privacy policy. 

 

• How we use your personal data

We will only use your personal data when the law allows us to and in line with applicable data protection laws – in particular, the EU General Data Protection Regulation (GDPR), the retained EU law version of the GDPR (UK GDPR) and the UK Data Protection Act 2018. In short, this means we only use it where we have a legal basis to do so. Most commonly, we will use your personal data in the following circumstances: 

• Where we need to perform the contract we are about to enter into or have entered into with you.
• 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 (including where processing is required to comply with or enforce a legal obligation, or to exercise or defend our legal rights).
• Where we need to comply with a legal obligation.
• Where the processing involves Special Category Personal Data, because you have consented to such processing.

Through certain actions when otherwise there is no contractual relationship between us, such as when you browse our website or ask us to provide you more information about our business, including our products and services, you provide your consent to us to process information that may be personal information.

Wherever possible, we aim to obtain your explicit consent to process this information.

If you have given us explicit permission to do so, we may from time to time pass your name and contact information to selected associates whom we consider may provide services or products you would find useful.

We continue to process your information on this basis until you withdraw your consent or it can be reasonably assumed that your consent no longer exists.

You may withdraw your consent at any time by instructing us at info@cambridgewomenshealth.co.uk. However, if you do so, you may not be able to use our website or our services further.

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 grounds 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 and process any health questionnaire you complete	Identity Contact Health Data	Performance of a contract with you
To provide you with our products and services	Identity Contact Health Data	Performance of a contract with you, including to provide medical diagnoses and prescriptions
To process and deliver your order including: (a) Manage payments, fees and charges (b) Collect and recover money owed to us	Identity  Contact  Financial  Transaction  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	Identity  Contact  Profile  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 administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)	Identity Contact Technical	(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	Identity  Contact  Profile  Usage  Marketing and Communications  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	Technical  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	Identity  Contact  Technical  Usage  Profile  Marketing and Communications	Necessary for our legitimate interests (to develop our products/services and grow our business)

Promotional offers from us 

We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising. 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 you have not opted out of receiving that marketing.

Third-party marketing 

We will get your express opt-in consent before we share your personal data with any third party for marketing purposes. 

Opting out

You can ask us or third parties to stop sending you marketing messages at any time by contacting us at any time at info@cambridgewomenshealth.co.uk 

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. We consider that we can lawfully send these communications to you as we have a legitimate interest to do so, namely to effectively provide you with the best service we can and to grow our business.

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.

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.

• Disclosures of your personal data

We may share your personal data with the parties set out below for the purposes set out in the table [Purposes for which we will use your personal data] above.

• External Third Parties, namely:
  • Semble which is an integrated clinical system for managing patient medical data and admin tasks and which provides IT, cloud hosting, system administration and back-up services; and 
  • Payment providers such as Stripe, which provides payment processing services on our behalf; 
  • Pharmacierge, which is an e-prescription provider that processes prescriptions and delivers medications to patients on our behalf; and
  • Medical health professionals to whom you have expressly requested a referral.
• 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 policy. 
• In some limited circumstances, we may be legally required to share certain personal data, which might include yours, if we are involved in legal proceedings or complying with legal obligations, a court order, or the instructions of a government authority.

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.

• International transfers

•  Some of the external third parties to whom we transfer your personal data are based outside the UK and European Economic Area (“EEA”) so their processing of your personal data will involve a transfer of data outside the UK/EEA. (The EEA consists of all EU member states, plus Norway, Iceland and Liechtenstein.) These are known as “third countries” and may not have data protection laws that are as strong as those in the UK and/or the EEA. This means that we will take additional steps in order to ensure that your personal data is treated just as safely and securely as it would be within the UK and will be fully protected under the UK GDPR, EU GDPR, Data Protection Act 2018 and/or to equivalent standards by law. Whenever we transfer your personal data out of the EEA, 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 personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission. For further details, see European Commission: Adequacy of the protection of personal data in non-EU countries;

• Where we use certain service providers, we may use standard contractual clauses (‘SCCs’), approved by the European Commission (or other specific contracts approved for use in the UK) which give personal data the same protection it has in Europe. For further details, see European Commission: Model contracts for the transfer of personal data to third countries;

• Where we use providers based in the US, we will make an assessment to determine whether we can transfer your personal data on the basis of SCCs taking into account the circumstances of the transfer, and put supplementary measures in place if required. The supplementary measures along with SCCs follow a case-by-case analysis of the circumstances surrounding the transfer and this would ensure that U.S. law does not encroach on the satisfactory level of protection guarantee. If we come to the decision, taking into account the circumstances of the transfer and possible supplementary measures, that appropriate safeguards would not be ensured, then we will either suspend the transfer of your personal data until we ensure an adequate level of protection can be provided or we might end the transfer of your personal data.

By giving us your personal data, you agree to the arrangements. Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.

• 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. 

• Data retention

How long will you use my personal data for?

We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements or until you request that the data be deleted. Even if we delete your personal information, it may persist on backup or archival media for legal, tax or regulatory purposes. In accordance with this privacy policy, you have the right to request that we delete your personal information, except where we are legally permitted or required to maintain certain personal information. For example, we are legally required to retain financial and transaction data for a minimum period of 7 years for tax, audit and accounting purposes. This includes keeping a record of the amount of each transaction, what it related to, and who we transacted with. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you. There may be other situations where we have legitimate business interests to retain personal information, such as to prevent fraud or protect security of our other customers. 

We may retain personal information about you for statistical purposes. Where information is retained for statistical purposes, it will always be anonymised, meaning that you will not be identifiable from that information.

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, regulatory, tax, accounting or other requirements.

If you engage our health consultation services, we will hold your personal data for as long as necessary to support the services we are providing to you, for example so we can continue to provide assistance or resolve an ongoing issue, and generally for a period of 8 years thereafter. If you do not access our services and no communication has been made for more than 8 years (and the information is not required to resolve an ongoing issue) we will generally delete personal data we hold about you. 

• Your legal rights

Under certain circumstances, you have rights under data protection laws in relation to your personal data. Please click here and see the Glossary below to find out more about these rights.

1. The right to be informed
2. The right of access
3. The right to rectification
4. The right to erasure
5. The right to restrict processing
6. The right to data portability
7. The right to object
8. Rights in relation to automated decision making and profiling.

If you wish to exercise any of the rights set out above, or for more information on your rights and how to use them, please contact us. 

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 could 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 could 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. In the case of subject access requests, normally, we aim to provide a complete response, including a copy of your personal data within one month. 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 we receive your request. You will be kept fully informed of our progress.

• Glossary

LAWFUL BASIS

Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.

Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.

Comply with a legal obligation means processing your personal data where it is necessary for compliance with a legal obligation that we are subject to.

YOUR LEGAL RIGHTS

You have the right to:

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.

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 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. 

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.

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: 

• If you want us to establish the data’s accuracy.
• Where our use of the data is unlawful but you do not want us to erase it.
• 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. 
• You have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it. 

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. 

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.