Privacy Policy | Maculara

This document (the “Privacy Policy”, the “Policy” or the “SOP”) describes the protocol for the management of privacy at Maculara.

Who we are and what we do

Maculara 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.macualra.com (the “Site”) is subject to the terms set out in this privacy policy. Please read this privacy policy carefully to understand our views and practices regarding your personal data and how we will treat it.

Maculara (“we”, “us” or “our”) is the data controller and is responsible for your personal data.

This privacy policy is updated from time to time.

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, email 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 as follows:

Identity Data which includes your first name, last name, username or similar identifier, marital status, title, date of birth and gender.
Contact Data which includes your billing address, delivery address, home address, email address and telephone numbers.
Health Data which includes any 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 for any accounts set up to access our products and services, purchases or orders made by you, and feedback responses.
Usage Data which includes information about how you use our Site, products 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 does not directly or indirectly reveal your identity and so is not personal data in law. 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.

In order to provide you with our healthcare services, we may also collect Special Categories of Personal Data (as defined in the General Data Protection Regulation (GDPR) about you. This may include details about your race or ethnicity, religious beliefs, sex life or sexual orientation. We may also collect information about any criminal convictions and offences where we are under a legal or regulatory obligation to do so.

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 product or service you have ordered from, us but we will notify you if this is the case at the time.

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.

Keeping your data secure

We know that data security is important to you. It is also 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, under the authorisation of senior management. 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 in place appropriate Technical and Organisational Measures to ensure a level of security appropriate to the storage of personal and sensitive data that our patients provide. We also take reasonable steps to ensure any third-party processing data on our behalf complies with the appropriate rules and regulations with regard to system security and data confidentiality.

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 in person or by phone, email or otherwise. This includes personal data you provide when you:
- register to use our Site;
- fill in our forms in person or over the telephone;
- 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 websites and apps employing our cookies. Please see our cookie policy below for further details.
Third parties or publicly 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 EEA.
Contact, Financial and Transaction Data (if applicable) from providers of technical, payment and delivery services.

Why we will use your data

The lawful bases for processing personal data are set out in 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. Please note that we do not rely on your consent as the lawful basis for processing including your personal data (including Special Category Data). This is because we are legally and ethically required to maintain certain records even if your consent is withdrawn (eg. where we are required to maintain records by regulators or insurers). Where we do ask for your consent (eg. to use our services and for marketing purposes to keep you informed of our services), we will do so to comply with the requirement to process personal data fairly, lawfully and transparently.
Contract: the processing is necessary for a contract we have with you (for example, to process and deliver goods or services to you 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 (including to improve your patient experience, for capacity management and 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).
We also need to satisfy specific conditions for using your health data. We rely upon the following ground in this regard:
Healthcare provision: the processing of data concerning your health is necessary for us to provide you with a medical diagnosis and/or healthcare treatment.

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, and when they are processing personal data on our behalf 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;
Service providers acting as processors who provide IT, system administration appointments and medical diagnostic services;
Professional advisers including lawyers, bankers, auditors and insurers who provide consultancy, banking, legal, insurance and accounting services;
Also, in accordance with law and regulation, we may be required to disclose your personal data with other medical practitioners such as the General Medical Council.

We do not transfer your personal data outside the European Economic Area (EEA).

Our Site uses cookies to distinguish you from other users of our Site. This helps us to provide you with a good experience when you browse and also allows us to improve our Site.

By continuing to browse the Site, you are agreeing to our use of cookies.

A cookie is a small file of letters and numbers stored on your browser or the hard drive of your computer in order to enhance your experience and to provide functionality on the website.

We use the following cookies:

Strictly necessary cookies. These are cookies that are required for the operation of our Site. They include, for example, cookies that enable you to log into secure areas of our Site, which could include your personal records and online payment services.
Analytical/performance cookies. These allow us to recognise and count the number of visitors and to see how visitors move around our Site when they are using it. This helps us to improve the way our Site works, for example, by ensuring that users are finding what they are looking for easily.
Functionality cookies. These are used to recognise you when you return to our Site. This enables us to personalise our content for you, greet you by name and remember your preferences (which could include your choice of language or region).

We may also use:

Targeting cookies. These cookies record your visit to our Site, the pages you have visited and the links you have followed. We will use this information to make our Site and any content displayed on it more relevant to your interests.

Please note that third parties (including, for example, providers of external services like web traffic analysis services) may also use cookies, over which we have no control.

You may block cookies by activating the relevant settings on your browser. However, if you use your browser settings to block all cookies (including essential cookies) you may not be able to access all or parts of our Site.

Except for essential cookies, all cookies will expire after no more than 30 days.

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 would like 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.

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Last updated 14th January 2024