We take your privacy and the security of your personal 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 your personal information. It also explains your rights in relation to your personal information and how to contact us or supervisory authorities in the event you have a complaint.
We collect, use and are responsible for certain personal information about you. When we do so we are subject to the UK’s Data Protection Act, its Privacy and Electronic Communications Regulations (PECR) and the General Data Protection Regulation, which applies across the European Union. We are responsible as ‘controller’ of that personal information for the purposes of those laws.
We have an up-to-date registration for the NHS Data Security and Protection Security Toolkit.We operate an ISO27001-aligned Information Security Management System.
We, us, our Phlo Technologies Ltd., a company incorporated in Scotland under company number SC496769 whose registered address is C/O Gillespie & Anderson, 147 Bath Street, Glasgow G2 4SN.
Our data protection officer.
James MacIver
Email: hello@phloconnect.com
Personal information: Any information relating to an identified or identifiable individual.
Special category personal information: Personal information revealing racial or ethnic origin, political opinions, religious beliefs, philosophical beliefs or trade union membership.Genetic and biometric data. Data concerning health, sex life or sexual orientation.
We may collect and use the following personal information about you:
· your name and contact information, including postal address, email address and telephone number;
· information about how you use our website, information technology (IT), communication and other systems; and
· your responses to surveys, competitions, and promotions.
Personal information is required to provide our services to you. If you do not provide personal information we ask for, it may delay or prevent us from providing services to you.
We collect most of this personal information directly from you—in person, by telephone, text or email and/or via our website . However, we may also collect information:
· from cookies on our website - for more information on our use of cookies, please see our cookie notice.
· via our IT systems, e.g. automated monitoring of our websites and other technical systems, such as our computer networks and connections.
Under data protection laws, we can only use your personal information if we have a proper reason for doing so, e.g.:
· to comply with our legal and regulatory obligations;
· for the performance of our contract with you or to take steps at your request before entering into a contract;
· for our legitimate interests or those of a third party; or
· where you have given consent.
A legitimate interest is when we have a business or commercial reason to use your information, so long as this is not overridden by your own rights and interests.
The table below explains what we use (process) your personal information for and our reasons for doing so:
What we use your personal
information for
Our reasons
To provide our services to you.
For the performance of our contract with you or to take steps at your request before entering a contract.
To prevent and detect fraud as against you.
For our legitimate interests or those of a third party i.e. to minimise fraud that could be damaging for us and for you.
Conduction checks to identify our users and verify their identity.
To comply with our legal and regulatory obligations
Gathering and providing information required by or relating to audits, enquiries, or investigations by regulatory bodies, including the NHS.
To comply with our legal and regulatory obligations e.g., the NHS has the power to ask pharmacists to provide copies of exemption certificates, or records of the prescribing history of pharmacists. We need to be able to respond to those requests.
Ensuring business policies are adhered to, e.g.,policies covering security and internet use.
For our legitimate interests and those of a third party, i.e., to make sure we are following our own internal procedures so we can deliver the best service to you.
Operational reasons, such as improving efficiency, training, and quality control.
For our legitimate interests or those of a third party i.e., to be as efficient as possible so we can provide the best service to you at the best price.
Ensuring the confidentiality of commercially sensitive information.
For our legitimate interests or those of a third party i.e., to protect trade secrets and other commercially valuable information. To comply with our legal and regulatory obligations.
Statistical analysis.
We analyse the data you give us to help us manage our business interests, e.g., in relation to our financial performance, user base, behaviours, product range or any other efficiency and performance measures.
You can consent to us processes your data for analytical purposes using our cookie management systems. Registered patients have access to our consent management system
Preventing unauthorised access and modifications to systems.
For our legitimate interests or those of a third party i.e. to prevent and detect and criminal activity that could be damaging for us and you.
To comply with our legal and regulatory obligations.
Updating and enhancing user records.
For the performance of our contract with you or to take steps at your request before entering a contract.
To comply with our legal and regulatory obligations.
For our legitimate interests or those of a third party i.e., making sure that we can keep in touch with our users about existing orders and new products.
Statutory Returns.
To comply with our legal and regulatory obligations
Ensuring safe work practices, staff administration and assessments.
To comply with our legal and regulatory obligations.
For our legitimate interests or those of a third party e.g., to make sure we are following our own internal procedures and work efficiently to deliver the best service to you
Marketing our services.
We use the data you give us to promote our services:
-existing and former users.
-Third parties who have previously expressed an interest in our services.
-Third parties who we have had no previous dealings.
Newsletter subscribers and patients can unsubscribe from emails using unsubscribe links in our emails and test messages.
Registered customers have access to our consent management system
External audits and quality checks e.g., for ISO or Investors in People accreditation and the audit of our accounts.
Four our legitimate interests or those of a third party, i.e., to maintain our accreditations so we can demonstrate we can operate at the highest standards.
To comply with our legal and statutory obligations.
We may use your personal information to send you updates by email about our services, including exclusive offers, promotions or new services.
We have a legitimate interest in processing your personal information for operational purposes.
We request your consent by accepting our cookie notices for us to process your data for statistical, analytical, marketing and promotional purposes (see above ‘How and why we use your personal information’).
You have the right to opt-out of receiving promotional communications at any time by:
· contacting us at hello@phloconnect.com
We may ask you to confirm or update your marketing preferences if you instruct us to provide further services in the future, or if there are changes in the law, regulation, or the structure of our business.
Our IT and Network management partner is:
· Digital Orchard IT, 10 York Place, Edinburgh, EH1 3EP
Other third parties we use to help us run our business, e.g. website hosts:
· Our marketing web site and newsletter subscription database is hosted by Webflow Inc, 398 11th Street, 2nd Floor, San Francisco, CA 94103.
· Our web analytics partner, Google (for Google Analytics) operates from Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland.
Our online marketing partners use their systems to record you clicking on our adverts on their sites, leaving their domains and arriving at Phlo’s:
· Facebook Ireland, 4 Grand Canal Square, Dublin, Ireland Dublin 2.
· LinkedIn Ireland, Wilton Place, Dublin, Ireland.
· Twitter International Company, One Cumberland Place, Fenian Street, Dublin 2, D02 AX07 Ireland.
· YouTube is a subsidiary of Google with offices at Google Ireland Limited, with offices at Gordon House, Barrow Street, Dublin 4, Ireland.
· Taboola Inc, 16 Madison Square West, 7th Floor, New York, New York 10010.
We use CloudFlare services operated by Cloudflare, Inc., located at 101 Townsend St., San Francisco, California 94107 to route network traffic.
Our financial accountants, Gillespie & Anderson, 147 Bath St, Glasgow G2 4SN and advisers Johnston Carmichael at 227 W George St, Glasgow G2 2NDOur legal advisers, Addleshaw Goddard, Exchange Tower, 19 Canning St, Edinburgh EH3 8EH.
Our regulators, the General Pharmaceutical Council at 25 Canada Square, Canary Wharf, London E14 5LQ and the Information Commissioners Office at Wycliffe House, Water Lane, Wilmslow SK9 5AF.NHS England (known formally as the NHS Commissioning Board) and reachable at NHS England, PO Box 16738, Redditch, B97 9PT.
We only allow our service providers to handle your personal information if we are satisfied they take appropriate measures to protect your personal information. We also impose contractual obligations on service providers to ensure they can only use your personal information to provide services to us and to you.
We may also share personal information with external auditors, e.g. in relation to ISO or Investors in People accreditation processes and the audit of our accounts.
We may disclose and exchange information with law enforcement agencies and regulatory bodies to comply with our legal and regulatory obligations.
We may also need to share some personal information with other parties, such as potential buyers of some or all of our business or during a re-structuring. Usually, personal information will be redacted but this may not always be possible. The recipient of the information will be bound by confidentiality obligations.
Information may be held at our offices and those of our pharmacy, third-party system providers and agencies, service providers, representatives and agents as described above (see above: ‘Who we share your personal information with’). Your data is hosted in our pharmacy premises and offices in the United Kingdom and at data centre facilities in the United Kingdom and in the Republic of Ireland, except for Webflow and Postmark services, which are hosted in the United States of America under the EU-US Privacy Shield framework.
We will keep your personal information while you have an account with us or we are providing services to you. Thereafter, we will retain your personal information:
· to respond to any questions, complaints or claims made by you or on your behalf;
· to show that we treated you fairly; and
· to keep records required by law.
We will not retain your personal information for longer than necessary for the purposes set out in this policy. Different retention periods apply for different types of personal information.
To navigate data retention requires us to define the roles people can have when using Phlo’s applications and systems. We call these Data Subject roles:
Prospects: people who visit www.phloconnect.com and do not register an interest in our service
Leads: people who visit www.phloconnect.com and provide contact details to find out more about our service.
Phlo’s data retention periods across its systems are:
Data Subject
Retention Period
Why we retain data
Prospects
730 Days
For analysis of data to define, target and refine marketing segments and campaigns and to recognise previous visits and interactions.
Leads
730 Days
To establish initial date of contact during sales and contract agreement processes. Plus capturing leads that have gone cold so as to avoid any outbound contact in the future.
You have the following rights, which you can exercise free of charge:
Access
The right to be provided with a copy of your personal information (the right of access).
Rectification
The right to require us to correct any mistakes in your personal information.
To be forgotten
The right to require us to delete your personal information in certain situations.
Restriction of processing
The right to require us to restrict processing of your personal information - in certain circumstances, e.g. if you contest the accuracy of the data.
Data portability
The right to receive personal information 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
The right to object:
- at any time to your personal information being processed for direct marketing (including profiling);
- in certain other situations to our continued processing of your personal information e.g. processing carried out for the purpose of our legitimate interests.
Not to be subject to automated individual decision-making
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.
For further information on each of those rights, including the circumstances in which they apply, please contact us, or see the Guidance from the UK Information Commissioner’s Office (ICO) on individuals’ rights under the Data Protection Act.
If you would like to exercise any of those rights, please:
· email, call or write to us - see below: ‘How to contact us’; and
· let us have enough information to identify you (e.g. your full name, address and user or reference number);
· let us have proof of your identity and address (a copy of your driving licence or passport and a recent utility or credit card bill); and
· let us know what right you want to exercise and the information to which your request relates.
We have appropriate security measures to prevent personal information from being accidentally lost or used or accessed unlawfully. We limit access to your personal information to those who have a genuine business need to access it. Those processing your information will do so only in an authorised manner and are subject to a duty of confidentiality.
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.
If you want detailed information from Get Safe Online on how to protect your information and your computers and devices against fraud, identity theft, viruses and many other online problems, please visit www.getsafeonline.org. Get Safe Online is supported by HM Government and leading businesses.
We hope that we can resolve any query or concern you may raise about our use of your information.
Should you be unable to resolve directly with us, the Data Protection Act gives you right to lodge a complaint with a supervisory authority. The supervisory authority in the UK is the Information Commissioner who may be contacted directly at https://ico.org.uk/concerns or telephone: 0303 123 1113.
We may change this privacy notice from time to time. If our privacy policy changes in such a way that your data would be processed by a new data processor, we'll get in touch by email to inform you.
Please contact us by post, email or telephone if you have any questions about this privacy policy or the information, we hold about you.
Our contact details are:
Address: Phlo Technologies Ltd, Clockwise Offices, 77 Renfrew St, G2 3BZ.
Registered office at c/o Gillespie & Anderson, 147 Bath Street, Glasgow, G2 4SN.
Email: hello@phloconnect.com
Telephone: 0141 255 0751
