Consent to installation of the App

Under data protection laws, we are required to provide you with certain information about who we are, how we process your personal data and for what purposes, and your rights in relation to your personal data. This information is provided in this policy and it is important that you read that information.

Before installation of this App, please indicate your consent to our processing of your personal data (including your name, contact details, financial and device information) as described in the policy.

YES I consent to the installation of the App for the purposes of booking and receiving virtual medical consultation via video conference call.

NO I do not consent to the installation of the App.

How you can withdraw consent

Once you provide consent by selecting “YES”, you may change your mind and withdraw consent at any time by contacting us at Admin@countymedical.co.uk but that will not affect the lawfulness of any processing carried out before you withdraw your consent.

Consent to processing Location Data

YES I consent to processing of my Location Data ([including details of my current location disclosed by GPS technology so that location-enabled Services are activated to assist with locating a nearby consultant).

NO I do not consent to processing of my Location Data and location-enabled Services are disabled in my settings.

Introduction

This policy (together with our end-user licence agreement as set out at Licance Terms and Conditions (EULA) and any additional terms of use incorporated by reference into the EULA, together our Terms of Use) applies to your use of:

• County Medical mobile application software (App), once you have downloaded a copy of the App onto your mobile telephone or handheld device (Device).
• Any of the services accessible through the App (Services) this policy sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us. This App is not intended for children and we do not knowingly collect data .relating to children. Please read the following carefully to understand our practices regarding your personal data and how we will treat it.

This policy is provided in a layered format so you can click through to the specific areas set out below.

Important information and who we are

County Medical Services Limited (Company No. 13733150) is the controller and is responsible for your personal data (collectively referred to as “County Medical”, “we, “us” or “our” in this policy).

We have appointed a data protection officer. who is responsible for overseeing questions in relation to this privacy policy. If you have any questions about this privacy policy, please contact the data privacy officer using the details set out below.

Contact details

If you have any questions about this privacy policy, please contact them using the details set out below. Our full details are:

• Full name of legal entity: County Medical Services Limited

• Company Number: 13733150
• Email address: Admin@countymedical.co.uk
• Postal address: 93 Tabernacle Street, London, EC2A 4BA
• ICO Registration Number: ZB276577

You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK regulator for data protection issues.

Changes to the privacy policy and your duty to inform us of changes

We keep our privacy policy under regular review. Historic versions can be obtained by contacting us.

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 our relationship with you.

Third party links

Our App may link with 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 App, we encourage you to read the privacy policy of every website you visit.

The data we collect about you

We may collect, use, store and transfer different kinds of personal data about you as follows:

• Identity Data. first name, last name, maiden name, username or similar identifier, marital status, title, date of birth, gender.
• Contact Data. billing address, email address and telephone numbers.
• Transaction Data: includes details about payments to and from you and details of in-App purchases.
• Device Data: includes the type of mobile device you use, a unique device identifier (for example, your Device’s IMEI number, the MAC address of the Device’s wireless network interface, or the mobile phone number used by the Device), mobile network information, your mobile operating system, the type of mobile browser you use and time zone setting.
• Profile Data: includes user authentication details, in-App purchase history, your interests, preferences, feedback and survey responses.
• Usage Data: includes details of your use of any of our Apps including, but not limited to, traffic data and other communication data, whether this is required for our own billing purposes or otherwise and the e
• Marketing and Communications Data: includes your preferences in receiving marketing from us and our third parties and your communication preferences.
• Location Data: includes your current location disclosed by GPS technology.

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 as this data will not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific App 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.

Under the GDPR there is some personal information that is so sensitive that it gets extra protection this is known as special categories of personal data. As we provide medical services we do collect special categories of personal data this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, information about your health (including your medical history), and genetic and biometric data.

When we are using special categories of personal data we must also meet certain conditions.

We have set out further below under the heading special categories of personal data which sets out the conditions we are relying on when we use your personal information.

Why we process Special Categories of Personal Data

We process special categories of personal data for the following purposes:

• To provide you with our services,
• To comply with our legal obligations;
• To comply with our regulatory obligations such as the Care Quality Commission; and
• For your own protection or the protection of the general public.

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 perform the contract we have or are trying to enter into with you (for example, to provide you with services).

How is your personal data collected?

We will collect and process the following data about you:

• Information you give us. This is information (including Identity, Contact, Financial, and Marketing and Communications Data) you consent to giving us about you by filling in forms on the App, or by corresponding with us (for example, by email or chat). It includes information you provide when you register to use the App, download or register an App, subscribe to any of our services, search for an App or service, make an in-App purchase, and when you report a problem with an App or our services. If you contact us, we will keep a record of that correspondence.
• Information we collect about you and your device. Each time you use one of our Apps we will automatically collect personal data including Device, Content and Usage Data. We collect this data using cookies and other similar technologies. Please see our Cookie Policy for further details.
• Location Data. We also use GPS technology to determine your current location. Some of our location-enabled Services require your personal data for the feature to work. If you wish to use the particular feature, you will be asked to consent to your data being used for this purpose. You can withdraw your consent at any time by [disabling Location Data in your settings.
• Information we receive from other sources including third parties. We will receive personal data about you from various third parties as set out below:
  
  • Device Data from the following parties: analytics providers such as Google based outside the UK; and search information providers such as Google based outside the UK.
  • Contact, Financial and Transaction Data from providers of technical, payment services such as STRIPE based outside the UK.

How we use your personal data

We will only use your personal data when the law allows us to do so. Most commonly we will use your personal data in the following circumstances:

• Where you have consented before the processing.
• Where we need to perform a contract we are about to enter or have entered 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.

Outlined below is more about the types of lawful basis that we will rely on to process your personal data.

Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service 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 obligation means processing your personal data where it is necessary for compliance with a legal obligation that we are subject to.

Generally, we do not rely on consent as a legal basis for processing your personal data although we will get your consent before sending third party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us.

We will get your express opt-in consent before we share your personal data with any third party for marketing purposes.

Purposes for which we will use your personal data

We can Process special categories of personal data only if we have a legal ground for processing and one of the specific processing conditions relating to special categories of personal data applies. We will identify and document the legal ground and specific processing condition relied on for each processing activity.

When collecting special categories of personal data from Data Subjects, either directly from Data Subjects or indirectly (for example from a third party or publicly available source), we will provide Data Subjects with a Privacy Notice setting out all the information required by the UK GDPR in a privacy notice which is concise, transparent, intelligible, easily accessible and in clear plain language which can be easily understood.

Cookies

We use cookies and/or other tracking technologies to distinguish you from other users of the App, the distribution platform (Appstore) and to remember your preferences. This helps us to provide you with a good experience when you use the App and also allows us to improve the App. For detailed information on the cookies we use, the purposes for which we use them and how you can exercise your choices regarding our use of your cookies, see our Cookie Policy.

Disclosures of your personal data

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

• Internal third parties. Other companies in our group acting as joint controllers or processors and who are based in the UK and provide administration services and undertake leadership reporting.
• External third parties such as:
  
  • Service providers acting as processors based in the UK and Ireland who provide IT and system administration services.
  • Professional advisers acting as processors or joint controllers including lawyers, bankers, auditors and insurers based in UK who provide consultancy, banking, legal, insurance and accounting services.
  • HM Revenue and Customs, regulators and other authorities acting as processors or joint controllers based in the UK who require reporting of processing activities in certain circumstances.
  • Self-employed consultants acting as processors or joint controllers based in the UK who provide professional medical advice during the virtual consultation with you.
  • To pharmacies, laboratories, hospitals and other healthcare organisations acting as processors or joint controllers based in the UK who provide prescriptions or other support services.
• Specific third parties such as:
  
  • Technical Data from the following parties: Google, Amazon and Twilio based inside the EEA;
  • Contact, Financial and Transaction Data from providers of technical, payment and delivery services such as Stripe and/or other Payment Gateways based inside the EEA. ,/li>
• 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 policy.

International transfers

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

Accountability principle

We are responsible for, and able to demonstrate compliance with these principles. Our data protection officer is responsible for ensuring that we are compliant with these principles.

We will:

• Ensure that records are kept of all personal data processing activities, and that these are provided to the Information Commissioner on request.
• Carry out a data privacy impact assessment for any high-risk personal data processing to understand how processing may affect you and consult the Information Commissioner if appropriate.
• Ensure that our data protection officer is appointed to provide independent advice and monitoring of personal data handling, and that the data protection officer has access to report to the highest management level.
• Have internal processes to ensure that personal data is only collected, used or handled in a way that is compliant with data protection law.

Data security

All information you provide to us is stored on our secure servers. Any payment transactions carried out by us or our chosen third-party provider of payment processing services will be encrypted. Where we have given you (or where you have chosen) a password that enables you to access certain parts of Our App, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.

Once we have received your information, we will use strict procedures and security features to try to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way.

We will collect and store personal data on your Device using and other technology.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator when we are legally required to do so.

We take the security of special categories of personal data very seriously. We have administrative, physical and technical safeguards in place to protect personal data against unlawful or unauthorised processing, or accidental loss or damage. We will ensure, where special categories of personal data is processed that:

• The processing is recorded, and the record sets out, where possible, a suitable time period for the safe and permanent erasure of the different categories of data in accordance with our data retention provisions below.
• Where we no longer require special categories of personal data for the purpose for which it was collected, we will delete it or render it permanently anonymous as soon as possible.
• Where records are destroyed we will ensure that they are safely and permanently disposed of.

Data retention

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, insurance, 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.

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, regulatory, tax, accounting or other requirements.

By law we have to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for eight years after they cease being customers for. We are also required to keep any medical records for a minimum of eight years after you cease being a customer.

In some circumstances you can ask us to delete your data: see Your legal rights below for further information.

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.

In the event that you do not use the App for a period of one year then we will treat the account as expired and your personal data may be deleted.

Your legal rights

Under certain circumstances you have the following rights under data protection laws in relation to your personal data.

You have the right to:

• Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
• Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
• Request erasure of your personal data. This enables you to ask us to delete or remove personal data 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 data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
• Object to processing of your personal data 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 as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
• Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios:
  
  • if you want us to establish the data’s accuracy;
  • where our use of the data is unlawful but you do not want us to erase it;
  • where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or
  • you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
• Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
• 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.

If you wish to exercise any of the rights set out above, please contact us.

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 could 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 could 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.