Introduction

Welcome to the PillPacPlus privacy notice.
 
PillPacPlus respects your privacy and is committed to protecting your personal data. This privacy notice will inform you as to how we look after your personal data when you visit our website (regardless of where you visit it from) and tell you about your privacy rights and how the law protects you.
 
Please also use the Glossary to understand the meaning of some of the terms used in this privacy notice.

Purpose of this privacy notice

This privacy notice aims to give you information on how PillPacPlus collects and processes your personal data through your use of this website, including any data you may provide through this website when you sign up to register with us, purchase a product or service or contact us with a query.
 
It is important that you read this privacy notice together with any other privacy notice or fair processing notice 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 notice supplements the other notices and is not intended to override them.

Controller

PillPacPlus is the controller and responsible for your personal data (also referred to as “we”, “us” or “our” in this privacy notice).
 
We have appointed a data privacy manager who is responsible for overseeing questions in relation to this privacy notice. If you have any questions about this privacy notice, including any requests to exercise your legal rights please contact the data privacy manager using the details set out below.

Contact Details

Our full details are:
 
Full name of legal entity: Pill Pack + Ltd, trading as PillPacPlus. 
 
Name or title of data privacy manager: info@pillpacplus.com
 
Email address: info@pillpacplus.com
 
Postal address: PillPacPlus Head Office/Central Pharmacy, Unit 9, 20 Antrim Road, Ballymena, Co. Antrim, BT42 2BJ
 
Telephone number: +44 (0) 28 2565 7856
 
You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority 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 notice and your duty to inform us of changes

This version was last updated on 27/07/2018.
 
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. 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. 

The data we collect about 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).
 
We may collect, use, store and transfer different kinds of personal data about you which we have grouped together follows:
 

  •  Identity Data includes first name, maiden name, last name, username or similar identifier, marital status, title, date of birth and gender.
  • Contact Data includes billing address, delivery address, email address and telephone numbers.
  • Financial Data includes bank account and payment card details.
  • Transaction Data includes details about payments to and from you and other details of products and services you have purchased from us.
  • 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.
  • Profile Data includes your username and password, purchases or orders made by you, your interests, preferences, feedback and survey responses.
  • Usage Data includes information about how you use our website, products and services.
  •  Marketing and Communications Data 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, or the number of PillPacPlus patients in a particular geographical area. 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 notice.

 
Special Category Data 

“Special Category” data means certain types of sensitive data.  We may collect the following special category data about you:

⦁    Health data – if you fill in a form on the website to register as a PillPacPlus patient, you will be asked for details of your GP.  If you contact us to sign up as a PillPacPlus customer, you will be contacted by a pharmacist who may gather health information from you in order to register you as a PillPacPlus customer.
 

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 provide you with the goods or services you require.  In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time. 
For example, in order to register as a PillPacPlus patient, we need to gather your contact details, so that we can communicate with you, and obtain the necessary information to register you as a PillPacPlus customer.    
 

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 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:
  • Register as a PillPacPlus patient;
  • Contact us in order to partner with us;
  • Apply for our products or services;
  • Create an account on our website;
  • Request marketing to be sent to you;
  • Enter a competition, promotion or survey; or
  • Give us some feedback.
  • Automated technologies or interactions. As you interact with our website, we may 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. We may also receive Technical Data about you if you visit other websites employing our cookies. Please see our cookie policy [LINK] for further details].
  • Third parties or publicly available sources. We may receive personal data about you from various third parties and public sources as set out below:
  •  Identity Data, Contact Data, and Health Data about you supplied by your relatives or carers.
  • Identity Data, Contact Data and Health Data supplied by your community pharmacy or GP.   
  • Technical Data from analytics providers such as Google based outside the EU;
  • Contact, Financial and Transaction Data from providers of technical, payment and delivery services such as Worldpay, Shopify and Stripe, based inside the EU.
     

How we use your personal data

We will only use your personal data when the law allows us to. 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.
  • Where we need to comply with a legal or regulatory obligation.
  • We will process your sensitive personal data (also known as special category data) such as health information, where necessary for the provision of health or social care or treatment.
     

- Purpose/Activity

To register you as a new customer, or partner.

- Type of data

  • Identity
  • Contact

- Lawful basis for processing including basis of legitimate interest

  •  Performance of a contract with you
  •  Necessary for our legitimate interests (to allow us to contact you, to grow our business)

- Purpose/Activity

To process and deliver your order including:

  • Manage payments, fees and charges
  • Collect and recover money owed to us

- Type of data

  • Identity
  • Contact
  • Financial
  • Transaction
  • Marketing and Communications

- Lawful basis for processing including basis of legitimate interest
(a) Performance of a contract with you
(b) Necessary for our legitimate interests (to recover money due to us)

- Purpose/Activity

To register you as a PillPacPlus patient.  

- Type of data

  • Identity
  • Contact
  • Marketing and Communications
  • Health Data  

- Lawful basis for processing including basis of legitimate interest

  • Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services)
  • We will process your health data such as your GP details, in order to provide you with health treatment and to manage our healthcare systems.
  • We will share your details with a Community Pharmacy with your explicit consent.  

- Purpose/Activity

To manage our relationship with you which will include:

  • Notifying you about changes to our terms or privacy policy
  • Asking you to leave a review or take a survey

- Type of data

  • Identity
  • Contact
  • Profile
  • Marketing and Communications

- Lawful basis for processing including basis of legitimate interest

  • Performance of a contract with you
  • Necessary to comply with a legal obligation
  • Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services)

- Purpose/Activity

To enable you to partake in a prize draw, competition or complete a survey

- Type of data

  • Identity
  • Contact
  •  Profile
  • Usage
  •  Marketing and Communications

- Lawful basis for processing including basis of legitimate interest

  • Necessary for our legitimate interests (to study how customers use our products/services, to develop them and grow our business)

- Purpose/Activity

To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)

- Type of data

  • Identity
  • Contact
  • Technical

- Lawful basis for processing including basis of legitimate interest

  • 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)
  • Necessary to comply with a legal obligation

- Purpose/Activity


To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you

- Type of data

  • Identity
  • Contact
  • Profile
  • Usage
  • Marketing and Communications
  • Technical

- Lawful basis for processing including basis of legitimate interest
 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)

- Purpose/Activity


To use data analytics to improve our website, products/services, marketing, customer relationships and experiences

- Type of data

  • Technical
  • Usage

- Lawful basis for processing including basis of legitimate interest
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)

- Purpose/Activity

To make suggestions and recommendations to you about goods or services that may be of interest to you

- Type of data

  • Identity
  • Contact
  • Technical
  • Usage
  • Profile

- Lawful basis for processing including basis of legitimate interest

  • Necessary for our legitimate interests (to develop our products/services and grow our business)


 

Marketing

We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising. We will not send you unsolicited marketing materials unless you have specifically opted-in to receive such materials.  

Promotional offers from us

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 other company for marketing purposes.

Opting Out

You can ask us or third parties to stop sending you marketing messages by contacting us 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 product/service purchase, warranty registration, product/service experience or other transactions.
 

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.
 
We may have to share your personal data with the parties set out below for the purposes set out in the table in paragraph 4 above.
 

  • Internal Third Parties as set out in the Glossary.
  • External Third Parties as set out in the Glossary.
  • Specific third parties – Squarespace, Stripe and Google
  • 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 notice.

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

Our website is hosted in the USA using Squarespace.  Squarespace will store name and email address details, and use Stripe to make payments.  When your data is transferred outside the EEA, we ensure that there are adequate protections in place.  Squarespace has self-certified to the EU-US Privacy Shield.  Stripe is used to make payments.  Stripe Payments Europe Limited is located in Ireland, but may transfer data to Stripe, Inc in the US.  Stripe has also self-certified to the EU Privacy Shield.  More information about the Privacy Shield and how it helps to protect your information can be found on the ICO website: www.ico.org.uk.   
 

Data Security
 
How long will you use my personal data for?  
 

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.
  
By law we have to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for six years after they cease being customers for tax purposes.
 
In some circumstances you can ask us to delete your data: see Request erasure below for further information.
 
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 information (commonly known as a "data subject access request"). This enables you to receive a copy of the personal information we hold about you and to check that we are lawfully processing it.
⦁    Request correction of the personal information that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected.
⦁    Request erasure of your personal information. This enables you to ask us to delete or remove personal information 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 information where you have exercised your right to object to processing (see below).
⦁    Object to processing of your personal information 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. You also have the right to object where we are processing your personal information for direct marketing purposes.
⦁    Request the restriction of processing of your personal information. This enables you to ask us to suspend the processing of personal information about you, for example if you want us to establish its accuracy or the reason for processing it.
⦁    Request the transfer of your personal information to another party.
⦁    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.
⦁    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 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.
 

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

Third parties  
   
External third parties

  •  If you have signed up to be a PillPacPlus Patient, with your agreement, we will share information with your GP and Community Pharmacy, where necessary to provide you with your prescription.  
  • Our website is hosted using Squarespace, based in the US, who store name and email address details only.
  • Stripe is used for online payments.  Stripe Payments Europe Limited is located in Ireland, but may transfer data to Stripe, Inc in the US.  
  • Service providers acting as processors based in US who provide IT services.
  • Professional advisers, acting as processors or joint controllers, including lawyers, bankers, auditors and insurers based in the UK who provide consultancy, banking, legal, insurance and accounting services.
  • HM Revenue & Customs, regulators and other authorities, acting as processors or joint controllers, based in the UK who require reporting of processing activities in certain circumstances.