Privacy Policy

1. WHO WE ARE
1.1 Royal Devon and Exeter NHS Foundation Trust is the controller and responsible for your personal data (referred to as "we", "us" or "our" in this privacy policy).
1.2 We have appointed a data protection officer (DPO) 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 us using the details in Clause 2.


2. HOW TO CONTACT US
2.1 If you have any questions about this privacy policy or our data protection practices, please contact our DPO using the details below:
2.1.1 FAO: Data Protection Officer, Information Governance Team, Wonford Hospital, Barrack Road, Exeter EX2 5DW
2.1.2 E-Mail: rde-tr.dataprotectionofficer@nhs.net


3. PURPOSE OF THIS PRIVACY POLICY
3.1 This privacy policy aims to give you information on how we collect and process your personal data through your use of this website, including any data you may provide when you purchase a test.
3.2 Our tests are only available to individuals over the age of 18 and therefore we do not knowingly collect data relating to minors.
3.3 It is important that you read this privacy policy together with our Terms and Conditions.

4. THE DATA WE COLLECT ABOUT YOU
4.1 We may collect various types of personal data to allow us to provide you with the services (tests) you request as well as to enable you to use this website. Personal data means any information about an individual from which that person can be identified whether directly or indirectly (for instance by combining it with other information held about you). It does not include data where you cannot be identified from it (anonymous data).
4.2 We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:
4.2.1 Identity Data including first name, last name, username or similar identifier, marital status, title, date of birth and gender;
4.2.2 Contact Data including billing address, delivery address, email address and telephone numbers;
4.2.3 Financial Data including bank account and payment card details;
4.2.4 Transaction Data including details about payments to and from you and other details of services you have purchased from us;
4.2.5 Technical Data including 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;
4.2.6 Profile Data including your username and password, purchases or orders made by you, your interests, preferences and feedback;
4.2.7 Usage Data including information about how you use our website and services; and
4.2.8 Marketing and Communications Data including whether you have agreed to receive marketing from us and your communication preferences.
4.3 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 if it does 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. From time to time, we may also hold statistical or demographic data about you from which you cannot be identified directly but which could identify you if combined with other information we hold. In those circumstances, this is treated personal data and will be used in accordance with this privacy policy.
4.4 Due to the nature of the services we also collect special categories of personal data, sometimes referred to as sensitive personal data, and which includes details about your race or ethnicity, sexual orientation, information about your health, and genetic and biometric data.
4.5 If you choose not to provide us with personal data or sensitive personal data we may not be able to carry out the services. 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 the testing services to you). 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. When you order a test from us we will notify you of what personal data we need to collect to carry out the test and whether this data is required or optional. If you have any questions regarding the data that we collect and why we need to collect it please contact us using the details contained in Clause 2.

5. PURPOSES FOR WHICH WE WILL USE YOUR PERSONAL DATA
5.1 We have set out below a description of all the ways we plan to use your personal data. By law, we are required to identify a specific justification to be able to use your personal data, known as a 'legal basis'. We set out below which particular legal bases we rely on to use your data. One such legal basis is the pursuit of legitimate interests, and we have also identified what our specific legitimate interests are where appropriate. We may process your personal data for more than one legal basis depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal basis we are relying on to process your personal data where more than one basis has been set out in the table below.

Purpose

Type of data

Lawful basis for processing including basis of legitimate interest

To register you as a new customer as create your account Identity and Contact Performance of a contract for services (tests) with you
To process and deliver your order including payments Identity, Contact, Financial and Transaction Performance of a contract for services (tests) with you and any recovery of sums due to us
To process your test and analyse the results Identity, Contact, and special categories of personal data Performance of a contract for services (tests) with you
To manage our relationship with you which will include notifying you about changes to our terms and conditions or privacy policy Identity, Contact and Marketing and Communications Performance of a contract for services (tests) with you and to comply with a legal obligation
To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data) Identity, Contact and Technical Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and comply with our legal obligations


5.2 Marketing. We will provide you with choices regarding certain personal data uses, particularly around marketing and advertising.
5.2.1 You can ask us to stop sending you marketing messages at any time by contacting us at any time.
5.2.2 Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of your order(s) with us and so we will continue to use your personal data where we have a legitimate purpose to do so in accordance with this privacy policy.
5.3 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 .
5.4 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.

6. HOW WE COLLECT YOUR PERSONAL DATA
6.1 We use different methods to collect data about you, including:
6.1.1 Directly: You may provide us with your personal data e.g. Identity or Financial data by filling in forms or by corresponding with us by post, phone, e-mail or otherwise. This includes personal data you provide when you:
6.1.1.1 make an order on our website
6.1.1.2 create an account on our website
6.1.1.3 give us feedback or contact us
6.1.1.4 [subscribe to our newsletter or updates];
6.1.2 Digital 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, server logs and other similar technologies. Please see our Cookie Policy for further details.
6.1.3 Third parties: We will receive personal data about you from various third parties and public sources as set out below:
6.1.3.1 analytics providers
6.1.3.2 Contact, Financial and Transaction data from providers of technical, payment and delivery services
6.2 We do not knowingly collect data about minors (children under the age of 18) as minors are not permitted to use the services provided on this website. If we believe that you are a minor we will reject your order and erase your data unless we are otherwise required to retain it by law.

7. DISCLOSING YOUR PERSONAL DATA
7.1 We will not share any of your personal data with any third party
7.2 We will share personal data with law enforcement or other authorities if required by applicable law.

8. INTERNATIONAL TRANSFERS
8.1 We do not transfer your personal data outside of the European Economic Area.

9. DATA SECURITY
9.1 We have put in place appropriate technical and 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.
9.2 We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator(s) of a breach where we are legally required to do so.

10. DATA RETENTION
10.1 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. 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. Data will be destroyed or erased from our systems when it is no longer required.
10.2 In some circumstances you can ask us to delete your data: see: your legal rights below for further information.
10.3 In some circumstances we will anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.

11. YOUR LEGAL RIGHTS
11.1 Under the data protection legislation you have a number of important rights, those include the right to:
11.1.1 request access to any personal data we hold about you;
11.1.2 prevent the processing of your data for direct-marketing purposes;
11.1.3 ask to have inaccurate data held about you amended;
11.1.4 prevent processing that is likely to cause unwarranted substantial damage or distress to you or anyone else;
11.1.5 object to any decision that significantly affects you being taken solely by a computer or other automated process;
11.1.6 withdraw any consent to the use your personal data;
11.1.7 require us to delete personal data concerning you in certain situations
11.1.8 raise any concerns about the way in which we handle your personal data with the UK regulatory for data protection, the Information Commissioner's Office. You can contact the Information Commission via www.ico.org.uk
11.2 If you wish to exercise any of the rights set out above, please our Data Protection Officer using the details set out in Clause 2 above.
11.3 You will not usually 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.
11.4 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, for instance to clarify the parameters of your request so that we provide you with the information you need.
11.5 We are required to respond to all legitimate requests within one month in most circumstances. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests, and in which case we are permitted to take up to a further two months to respond to your request. In those cases, we will notify you and keep you updated.

12. CHANGES TO OUR PRIVACY POLICY AND YOUR DUTY TO INFORM US OF CHANGES
12.1 We keep our privacy policy under regular review. This version was last updated on [DATE].
12.2 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.
12.3 You should always check this privacy policy prior to making an order with us, even if you have ordered previously.

13. THIRD PARTY LINKS
13.1 This website may include links to third-party websites, plug-ins and applications. 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. When you leave our website, we encourage you to read the privacy policy of every website you visit.

 

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