Medicom Healthcare | Privacy Notice

November 2023

Our updated Privacy Policy version 2.0 provides updated information on our lawful basis for processing your data, how we use your data, what data we share with others, why we share that data and where we transfer your data to outside the UK.

This website, medicomhealthcare.co.uk (our website) is provided by Medicom Healthcare Limited (‘we’, ‘our’ or ‘us’). We are the controller of personal data obtained via our website, meaning we are the organisation legally responsible for deciding how and for what purposes it is used.

We take your privacy very seriously. Please read this privacy policy carefully as it contains important information on who we are and how and why we collect, store, use and share any information relating to you (your personal data) in connection with your use of our website. It also explains your rights in relation to your personal data and how to contact us or a relevant regulator in the event you have a complaint.

We collect, use and are responsible for certain personal data about you. When we do so we are subject to the UK General Data Protection Regulation (UK GDPR).

This version of our privacy policy is primarily written for adults, including parents and guardians of child users.

What this policy applies to

This privacy policy relates to your use of our website only.

Throughout our website we may link to other websites owned and operated by certain trusted third parties. Those third party websites may gather information about you in accordance with their own separate privacy policies. For privacy information relating to those third party websites, please consult their privacy policies.

Personal data we collect about you

We will collect and use the following personal data about you:

• your name, email address and company name (if applicable)

• any other information which you may voluntarily provide to us in your message when you complete the General Enquiries form on the Contact Us page and submit it to us or any other information you send to us any of our email address listed on our website. For example, this might include your date of birth, physical address, telephone number and health information if you choose to volunteer this information

We collect and use personal data for the purposes described in the section ‘How and why we use your personal data’ below.

How your personal data is collected

We collect personal data from you directly when you submit information via the General Enquiries form on the Contact Us page or via an email to any of our email addresses listed on our website.

How and why we use your personal data

Under data protection law, we can only use your personal data if we have a proper reason, e.g.:

• where you have given consent

• to comply with our legal and regulatory obligations

• for our legitimate interests or those of a third party

A legitimate interest is when we have a business or commercial reason to use your personal data, so long as this is not overridden by your own rights and interests. We will carry out an assessment when relying on legitimate interests, to balance our interests against your own. You can obtain details of this assessment by contacting us (see ‘How to contact us’ below).

The table below explains what we use your personal data for and why.

What we use your personal data for	Our reasons
To process and consider any request you submit via the General Enquiries form on the Contact Us page or via an email to any of our email addresses listed on our website	To respond/answer your request as efficiently as possible and accurately
Disclosures and other activities necessary to comply with legal and regulatory obligations that apply, for example, to notify the relevant authorities of any adverse event and to record and demonstrate evidence of your consents where relevant	To comply with our legal and regulatory obligations

What we use your personal data for

Our reasons

To process and consider any request you submit via the General Enquiries form on the Contact Us page or via an email to any of our email addresses listed on our website

To respond/answer your request as efficiently as possible and accurately

Disclosures and other activities necessary to comply with legal and regulatory obligations that apply, for example, to notify the relevant authorities of any adverse event and to record and demonstrate evidence of your consents where relevant

To comply with our legal and regulatory obligations

How and why we use your personal data—in more detail

More details about how we use your personal data and why are set out in the table below.

Purpose	Processing operation	Lawful basis relied on under UK GDPR	Relevant categories of personal data
To process and consider any request you submit via the General Enquiries form on the Contact Us page or via an email to any of our email addresses listed on our website	Addressing and sending communications to our relevant staff in order to determine an answer to your enquiry and to communicate the answer/response back to you	Your consent (Article 6(1)(a)) and/or our legitimate interests (Article 6(1)(f)), which is to be as efficient as we can so we can deliver the best service to you	— your name, email address and company name (if applicable) — any other personal data which you may voluntarily provide to us in your communications which might include medical and health information
To assess whether any information you provide may be considered an adverse event relating to the use of one of our products and if it is, to report as required to our management and the relevant authorities	Reviewing and analysing the information required including providing it to our third party pharmacovigilance assessor and where necessary reporting it to our management and the relevant authorities	Your consent (Article 6(1)(a)), compliance with a legal obligation to which we are subject (Article 6(1)(c)), processing is necessary in order to protect your vital interests or that of another natural person (Article 6(1)(d)) and/or processing is necessary for the performance of a task carried out in the public interest (Article 6(1)(e))	— your name, email address and company name (if applicable) — any other personal data which you may voluntarily provide to us in your communications which might include medical and health information

Purpose

Processing operation

Lawful basis relied on under UK GDPR

Relevant categories of personal data

To process and consider any request you submit via the General Enquiries form on the Contact Us page or via an email to any of our email addresses listed on our website

Addressing and sending communications to our relevant staff in order to determine an answer to your enquiry and to communicate the answer/response back to you

Your consent (Article 6(1)(a)) and/or our legitimate interests (Article 6(1)(f)), which is to be as efficient as we can so we can deliver the best service to you

— your name, email address and company name (if applicable)

— any other personal data which you may voluntarily provide to us in your communications which might include medical and health information

To assess whether any information you provide may be considered an adverse event relating to the use of one of our products and if it is, to report as required to our management and the relevant authorities

Reviewing and analysing the information required including providing it to our third party pharmacovigilance assessor and where necessary reporting it to our management and the relevant authorities

Your consent (Article 6(1)(a)), compliance with a legal obligation to which we are subject (Article 6(1)(c)), processing is necessary in order to protect your vital interests or that of another natural person (Article 6(1)(d)) and/or processing is necessary for the performance of a task carried out in the public interest (Article 6(1)(e))

— your name, email address and company name (if applicable)

— any other personal data which you may voluntarily provide to us in your communications which might include medical and health information

How and why we use your personal data—Special category personal data

Certain personal data we may collect is treated as a special category to which additional protections apply under data protection law:

• data concerning health

Given the nature of our products it is sometimes necessary for us to process data relating to these categories of personal data. Where we process such special category personal data, we will also ensure we are permitted to do so under data protection laws. To do so we will ensure that we have your explicit consent; it is necessary in order to protect your vital interests or that of another natural person; is necessary for the establishment, exercise or defence of legal claims; and/or it is necessary for reasons of public interest in the area of public health.

How and why we use your personal data—sharing

See ‘Who we share your personal data with’ for further information on the steps we will take to protect your personal data where we need to share it with others.

Who we share your personal data with

We routinely share personal data with:

• other third parties we use to help us run our business, e.g. our website host

We only allow those organisations to handle your personal data once we are satisfied they take appropriate measures to protect your personal data. We also impose contractual obligations on them to ensure they can only use your personal data to provide services to us and to you.

We or the third parties mentioned above occasionally also share personal data with:

• our external auditors, e.g. in relation to the audit of our accounts, in which case the recipient of the information will be bound by confidentiality obligations

• our professional advisors (such as lawyers and other advisors), in which case the recipient of the information will be bound by confidentiality obligations

• law enforcement agencies, courts, tribunals and regulatory bodies to comply with our legal and regulatory obligations

• other parties that have or may acquire control or ownership of our business (and our or their professional advisers) in connection with a significant corporate transaction or restructuring, including a merger, acquisition, asset sale, initial public offering or in the event of our insolvency—usually, information will be anonymised but this may not always be possible. The recipient of any of your personal data will be bound by confidentiality obligations

Who we share your personal data with—in more detail

More details about who we share your personal data with and why are set out in the table below.

Recipient	Processing operation (use) by recipient	Relevant categories of personal data transferred to recipient
Newfold Digital Inc., 5335 Gate Parkway, Jacksonville, Florida, FL 32256, USA	Hosting of our website	All data collected via the General Enquiries form on the Contact Us page
Medicom International Eyetech Private Limited, 968A ResCo-Work16, Level 9, Spaze I-Tech Park, A1 Tower, Sector 49, Gurgaon- Sohna Road Gurgaon HR 122018, India	Processing personal data submitted through the Enquiry Form on our website in order to respond to your enquiry	All data collected via the General Enquiries form on the Contact Us page or sent using the info@medicomhealthcare.com email address
Red Line Pharmacovigilance Limited, 2 Balfe Mews, Old Farm Park, Milton Keynes, Buckinghamshire, MK7 8QR, UK	Assessing whether any information you provide may be considered an adverse event relating to the use of one of our products and if it is, to report it to the relevant authorities	All data collected via the General Enquiries form on the Contact Us page or sent using the medinfo@medicomhealthcare.com email address

Who we share your personal data with—further information

If you would like more information about who we share our data with and why, please contact us (see ‘How to contact us’ below).

How long your personal data will be kept

We will not keep your personal data for longer than we need it for the purpose for which it is used. After the prescribed retention period, data will be moved to archiving.

Different retention periods apply for different types of personal data. Further details on this are available upon request.

Transferring your personal data out of the UK

Countries outside the UK have differing data protection laws, some of which may provide lower levels of protection of privacy.

It is sometimes necessary for us to transfer your personal data to countries outside the UK. In those cases, we will comply with applicable UK laws designed to ensure the privacy of your personal data.

Under data protection laws, we can only transfer your personal data to a country outside the UK where:

• there are appropriate safeguards in place, together with enforceable rights and effective legal remedies for you, or

• a specific exception applies under relevant data protection law.

Where we transfer your personal data outside the UK, we do so on the basis of an adequacy regulation or (where this is not available), on the basis of legally-approved standard data protection clauses recognised under Article 46(2) of the UK GDPR. In the event we cannot or choose not to continue to rely on either of those mechanisms at any time we will not transfer your personal data outside the UK unless we can do so on the basis of an alternative mechanism or exception provided by UK data protection law and reflected in an update to this policy.

Transferring your personal data out of the UK—in more detail

More details about the countries outside the UK to which your personal data is transferred are set out in the table below.

Recipient country	Recipient	Processing operation (use) by recipient	Lawful safeguard
USA	Newfold Digital Inc., 5335 Gate Parkway, Jacksonville, Florida, FL 32256, USA	Web hosting services by processing personal data submitted through the Enquiry Form on our website into an email which is sent to us in order to respond to your enquiry	Legally-approved standard data protection clauses for transfers from a controller to processor recognised or issued further to Article 46(2)
India	Medicom International Eyetech Private Limited, 968A ResCo-Work16, Level 9, Spaze I-Tech Park, A1 Tower, Sector 49, Gurgaon- Sohna Road Gurgaon HR 122018, India	Processing personal data submitted through the Enquiry Form on our website or sent using the info@medicomhealthcare.com email address in order to respond to your enquiry	Legally-approved standard data protection clauses for transfers from a controller to processor recognised or issued further to Article 46(2)

Transferring your personal data out of the UK and EEA —further information

If you would like further information about data transferred outside the UK, please contact us at dataprotection@medicomhealthcare.com

Cookies

A cookie is a small text file which is placed onto your device (e.g. computer, smartphone or other electronic device). We do not use cookies on our website.

Your rights

You generally have the following rights, which you can usually exercise free of charge:

Access to a copy of your personal data	The right to be provided with a copy of your personal data
Correction (also known as rectification)	The right to require us to correct any mistakes in your personal data
Erasure (also known as the right to be forgotten)	The right to require us to delete your personal data in certain situations
Restriction of use	The right to require us to restrict use of your personal data in certain circumstances, e.g. if you contest the accuracy of the data
Data portability	The right to receive the personal data you provided to us, in a structured, commonly used and machine-readable format and/or transmit that data to a third party in certain situations
To object to use	The right to object: ● at any time to your personal data being used for direct marketing (including profiling) ● in certain other situations to our continued use of your personal data, e.g. where we use your personal data for our legitimate interests unless there are compelling legitimate grounds for the processing to continue or the processing is required for the establishment, exercise or defence of legal claims
Not to be subject to decisions without human involvement	The right not to be subject to a decision based solely on automated processing (including profiling) that produces legal effects concerning you or similarly significantly affects you We do not make any such decisions based on data collected by our website
The right to withdraw consents	If you have provided us with a consent to use your personal data, you have a right to withdraw that consent easily at any time You may withdraw consents by emailing us at dataprotection@medicomhealthcare.com Withdrawing a consent will not affect the lawfulness of our use of your personal data in reliance on that consent before it was withdrawn

For further information on each of those rights, including the circumstances in which they do and do not apply, please contact us (see ‘How to contact us’ below). You may also find it helpful to refer to the guidance from the UK’s Information Commissioner on your rights under the UK GDPR.

Please email us at dataprotection@medicomhealthcare.com if you would like to exercise any of those rights. When contacting us please:

• provide enough information to identify yourself i.e. your full name and email address as well as any additional identity information we may reasonably request from you, and

• let us know which right(s) you want to exercise and the information to which your request relates.

Keeping your personal data secure

We have appropriate security measures to prevent personal data from being accidentally lost, or used or accessed unlawfully. We limit access to your personal data to those who have a genuine need to access it.

We also have procedures in place to deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected data security breach where we are legally required to do so.

How to complain

Please contact us if you have any queries or concerns about our use of your personal data. We hope we will be able to resolve any issues you may have.

You also have the right to lodge a complaint with:

• the Information Commissioner in the UK

• a relevant data protection supervisory authority in the EEA state of your habitual residence, place of work or of an alleged infringement of data protection laws in the EEA.

The UK’s Information Commissioner may be contacted using the details at https://ico.org.uk/make-a-complaint or by telephone: 0303 123 1113.

For a list of EEA data protection supervisory authorities and their contact details see here.

Changes to this privacy policy

We may change this privacy policy from time to time. When we make significant changes we will take steps to inform you, for example by including a prominent link to a description of those changes on our website for a reasonable period or by email.

How to contact us

You can contact us by email, telephone or post:

Email: dataprotection@medicomhealthcare.com

Telephone: +44 1489 574119

Address: Medicom Healthcare Limited, Gainsborough House, 59-60 Thames Street, Windsor, SL4 1TX, UK

Policy Version: 2.0