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Who we are and what we do
Safe Travel Clinic respects your privacy and is committed to protecting your personal data. This privacy policy will inform you as to how we look after your personal data and sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us. Your visit to www.safetravelclinic.co.uk and our mobile app is collectively referred to as the “Site” and is subject to the terms set out in this privacy policy. Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it.
Health Technologies Limited (trading as “Safe Travel Clinic ”) is the data controller and responsible for your personal data (collectively referred to as “Safe Travel Clinic ”, “we”, “us” or “our” in this privacy policy). 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 email safetravelclinic@gmail.com
This policy is updated from time to time. The latest version updated on 21st May 2021 is published on this page. All updated versions of the policy will be published on this page.
Information we may collect 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 the identity has been removed (anonymous data). When you visit our Site or correspond with us by phone, e-mail or otherwise you may give us information that would be classed as personal data about you and others you are acting on behalf of. We may collect, use, store and transfer different kinds of personal data about you when you do so which we have grouped together follows:
Identity Data which includes your first name, last name, username or similar identifier, marital status, title, date of birth and gender. If you are booking a test for the ‘Test to Release’ scheme, we will collect and store your passport number in line with the UK government’s requirements of data collection for this scheme.
Contact Data which includes your address, email address and telephone numbers.
Demographic Data which includes your postcode, preferences and interests.
Health Data which includes information about your health including your medical history and/or current health status including but not limited to data regarding test results, diagnoses and medications.
Financial Data which includes your bank account and payment card details.
Transaction Data which includes details about payments to and from you and other details of products and services you have purchased from us.
Technical Data which 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 Site.
Profile Data which includes your username and password, requests for products and services made by you and feedback responses.
Usage Data which includes information about how you use our Site and services.
Marketing and Communications Data which includes your preferences in receiving marketing from us and our third parties and your communication preferences.
We also collect, use and share aggregated data such as statistical or demographic data for any purpose aggregated data may be derived from your personal data but is not considered personal data in law as this data 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. 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.
Keeping your data secure
We know that data security is important to you and it is therefore important to us. 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 in accordance with this policy 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. Our Site is scanned on a regular basis for security holes and known vulnerabilities in order to make your visit to our site as safe as possible.
Your personal information is contained behind secured networks and is only accessible by a limited number of persons who have special access rights to such systems, and are required to keep the information confidential. In addition, all sensitive/credit information you supply is encrypted via Secure Socket Layer (SSL) technology.
How we will collect your data
We use different methods to collect data from and about you including through:
Direct interactions. You may give us any of the categories of data identified above by filling in forms on our Site or by corresponding with us by phone, e-mail or otherwise. This includes personal data you provide when you:
· register to use our Site;
· make a request for our products or services;
· request marketing communications to be sent to you;
· give us some feedback.
Automated technologies or interactions. As you interact with our Site, we may automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, and other similar technologies. We may also receive Technical Data about you if you visit other Sites and apps employing our cookies. Please see our cookie policy below for further details.
Third parties or publically available sources. We may receive personal data about you from various third parties and public sources such as analytics providers, advertising networks and/or search information providers based inside and outside the EU including Google.
Contact, Financial and Transaction Data from providers of technical, payment and delivery services such as Stripe, Twilio and Google based inside and outside the EU.
Identity and Contact Data from data brokers or aggregators such as Google based inside and outside the EU.
Why we will use your data
The lawful basis for processing are set out Schedules 2 and 3 of the Data Protection Act 1998 and Article 6 of the General Data Protection Regulation (GDPR). We may process your personal data on 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 ground we are relying on to process your personal data where more than one ground has been set out below. At least one of these must apply whenever we process personal data:
Consent: you have given clear consent for us to process your personal data for a specific purpose.
Contract: the processing is necessary for a contract we have with you (for example, to process and provide the services and products you request from us and to manage our relationship with you), or because you have asked us to take specific steps before entering into a contract.
Legal obligation: the processing is necessary for us to comply with a legal or regulatory obligation (not including contractual obligations).
Vital interests: the processing is necessary to protect someone’s life.
Public task: the processing is necessary for us to perform a task in the public interest or for our official functions, and the task or function has a clear basis in law.
Legitimate interests: the processing is necessary for our legitimate interests (for example to administer and maintain our Site) or the legitimate interests of a third party unless there is a good reason to protect your personal data which overrides those legitimate interests. 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.
Healthcare provision: the processing of data concerning your health is necessary for us to provide you with our service being a medical consultation, diagnosis and healthcare treatment.
Click here to find out more about the types of lawful basis that we will rely on to process your personal data.
Generally we do not rely on consent as a legal basis for processing your personal data other than as described below. However, if we do ask for your consent (for example in processing data relating to your health) we will do so in order to comply with the principle that any processing must be lawful, fair and transparent. Please see our terms and conditions for more information on this.
In order to provide our services to you we will need to process personal data about your health. Whilst we will ask for your consent to process this data we do not rely on this consent as the lawful basis on which we may process your health data. We will also rely on one of the other lawful basis as set out above.
How we will use your data
Collecting data helps us to understand what you are looking for and for us to deliver improved products and services to you. Specifically, we may use data:
· To provide our services to you.
· For our own internal records.
· To improve our Site in order to better serve you.
· To improve the products and services we provide.
· To contact you in response to a specific enquiry.
· To customise the Site for you to allow us to deliver the type of content and product offerings which you are most interested in.
· To quickly process your transactions.
· To send you promotional emails about products, services, offers and other things we think might be relevant to you.
· To send you promotional mailings or to call you about products, services, offers and other things we think might be relevant to you.
· To contact you via email, telephone or mail for market research reasons.
· To ask for ratings and reviews of services or products.
· To follow up with you after correspondence (live chat, email or phone inquiries).
In each case we will use your data in accordance with this privacy policy.
Disclosing your personal data
We may have to share your personal data with the parties below in order to provide our services to you. 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. Examples of our third parties include:
· Sub-contractors for the performance of any contract we enter into with them or you;
· Accredited pharmacies,
· NHS bodies (including GPs),
· Service providers acting as processors who provide IT and system administration services.
· Professional advisers acting as processors or joint controllers including lawyers, bankers, auditors and insurers who provide consultancy, banking, legal, insurance and accounting services.
We do not transfer your personal data outside the European Economic Area (EEA).
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.
Marketing
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 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. We will get your express opt-in consent before we share your personal data with any company outside Safe Travel Clinic for marketing purposes.
You can ask us or third parties to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you or by Contacting us at any time.
Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a purchase of services or products from us.
How long we will keep your data
We will only retain your personal 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 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 requirements.
Details of retention periods for different aspects of your personal data.
In some circumstances we may 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.
Your legal rights
Under certain circumstances, you have rights under data protection laws in relation to your personal data. Please click on the links below to find out more about these rights:
· Request access to your personal data
· Request correction of your personal data
· Request erasure of your personal data
· Object to processing of your personal data
· Request restriction of processing your personal data
· Request transfer of your personal data
If you wish to exercise any of the rights set out above, please Contact us. Please note that, should you exercise your legal right to withdraw your consent, we refer you to the above in which we explain that we do not rely on your consent as the only lawful basis on which we will process your personal data.
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 of £10 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 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 may 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.
Cookies
A cookie is a small file placed on your computer’s hard drive. It enables our Site to identify your computer as you view different pages on our Site. Cookies allow Sites and applications to store your preferences in order to present content, options or functions that are specific to you. They also enable us to see information like how many people use the Site and what pages they tend to visit, so that we can offer better site experiences and tools in the future.
We have carefully chosen these cookies and have taken steps to ensure that your privacy is protected and respected at all times.
We may use cookies to:
· Analyse our web traffic using an analytics package.
Aggregated usage data helps us improve the Site structure, design, content and functions.
· Identify whether you are signed in to our Site.
A cookie allows us to check whether you are signed in to the site.
· Test content on our Site or app. For example
, 50% of our users might see one piece of content, the other 50% a different piece of content.
· Store information about your preferences.
The Site can then present you with information you will find more relevant and interesting. We may also use trusted third-party services that track this information on our behalf.
· To recognise when you return to our Site.
We may show your relevant content, or provide functionality you used previously.
Cookies do not provide us with access to your computer or any information about you, other than that which you choose to share with us. All cookies used by this Site are used in accordance with current UK and EU Cookie Law
You can use your web browser’s cookie settings to determine how our Site uses cookies. If you do not want our Site to store cookies on your computer or device, you should set your web browser to refuse cookies. However, please note that doing this may affect how our Site functions. Some pages and services may become unavailable to you. Unless you have changed your browser to refuse cookies, our Site will issue cookies when you visit it.
To learn more about cookies and how they are used, visit All About Cookies.
Google’s advertising requirements can be summed up by Google’s Advertising Principles. They are put in place to provide a positive experience for users. https://support.google.com/adwordspolicy/answer/1316548?hl=en
Google, as a third-party vendor, uses cookies to serve ads on our site. Google’s use of the DART cookie enables it to serve ads to our users based on previous visits to our site and other sites on the Internet. Users may opt-out of the use of the DART cookie by visiting the Google Ad and Content Network privacy policy.
We have implemented the following:
· Remarketing with Google AdSense
· Google Display Network Impression Reporting
· Demographics and Interests Reporting
· DoubleClick Platform Integration
We, along with third-party vendors such as Google, use first-party cookies (such as the Google Analytics cookies) and third-party cookies (such as the DoubleClick cookie) or other third-party identifiers together to compile data regarding user interactions with ad impressions and other ad service functions as they relate to our Site.
Users can set preferences for how Google advertises to you using the Google Ad Settings page. Alternatively, you can opt out by visiting the Network Advertising Initiative Opt Out page or by using the Google Analytics Opt Out Browser add on.
Safe Travel Clinic
First Floor, 45 Pickford Street, Birmingham, B5 5QH
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