Privacy Policy

Last updated: 18/11/2024

Medimob Screenings values your privacy and is dedicated to transparency regarding the data we collect when you visit and use www.screening.medimob.co.uk and our services. This Privacy Policy outlines the types of data we collect, how we use it, and your rights regarding your information. Please read this policy carefully to understand our practices regarding your data.

CONTACT DETAILS

We are Medimob Screenings, a trading name of Medimob Ltd (Company Registration Number 14224012). Our registered address is 167-169 Great Portland Street, London, England, W1W 5PF.

We are registered as a data controller with the Information Commissioner’s Office (ICO) under registration number ZB388442.

We have a registered Data Protection Officer (DPO), Antonio Vona, and she can be contacted at [email protected].

If you have any questions about this privacy notice, including any requests to exercise your legal rights, please contact us at [email protected].

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.

General Information

a. What is Personal Data?

Personal Data is any information relating to personal or material circumstances that relates to an identified or identifiable individual. This includes, for example, your name, date of birth, e-mail address, postal address, or telephone number as well as online identifiers such as your IP address. In contrast, information of a general nature that cannot be used to determine your identity is not Personal Data. This includes, for example, the number of users of a website.

b. What is Special Category Data?

Special category data is Personal Data that needs more protection because it is sensitive. This includes Personal Data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, genetic data, biometric data. As well as, data concerning health, a person’s sex life; and a person’s sexual orientation. In order to lawfully process Special Category Data, it is necessary to explicitly consent to the processing.

c. What is processing?

"Processing" means any operation or set of operations which is performed upon Personal Data, whether or not by automatic means. The term is broad and covers virtually any handling of data.

d. What law applies?

In principle, we will only use your Personal Data in accordance with the applicable data protection laws, in particular the UK’s Data Protection Act 2018 (“DPA”) and the EU's General Data Protection Regulation (“GDPR”).

f. What are the legal bases of processing?

We only process your Personal Data if we at least one of the following applies:

● you have given your consent,

● the data is necessary for the fulfilment of a contract / pre-contractual measures,

● the data is necessary for the fulfilment of a legal obligation or

● the data is necessary to protect our legitimate interests, provided that your interests are not overridden.

Data We Collect Automatically

a. Log data

Each time you visit our website, our system automatically records the following data from the visiting device and stores it in a so-called log file: i) Name of the retrieved file, ii) date and time of the visit, iii) amount of data transferred, iv) message about successful retrieval, type of browser and version used, v) IP address (identification of the user's device), vi) Operating system of the visiting device, vii) Internet service provider of the visiting device, viii) website from which you access our website, and ix) which of our website pages you are accessing. The legal basis for processing is our legitimate interest.

b. Hosting

To provide our website, we use the services of AWS who process all data to be processed in connection with the operation of our website on our behalf. The legal basis for the data processing is our legitimate interest in providing our website.

c. Content Management System

We use the Content Management System (CMS) of WordPress, a service provided by Automattic Inc to publish and maintain the created and edited Content and texts on our website. This means that all content and texts submitted to us by users for publication is transferred to WordPress. In addition to texts, this also includes, for example your data in our forms. The legal basis for this processing is our legitimate interest

d. Google Fonts

We use Google Fonts by Google LLC and Google Ireland Ltd on our website to display external fonts. To enable the display of certain fonts on our website, a connection to the Google server in the USA is established when our website is accessed. The connection to Google established when you call up our website enables Google to determine which website sent your request and to which IP address the display of the font is to be transmitted. This represents a legitimate interest.

e. Font Awesome

We integrate Font Awesome of Fonticons Inc, whereby the user's data is used solely for the purpose of displaying the fonts in the user's browser. The integration is based on our legitimate interest.

f. Cookies

We use so-called cookies on our website. Cookies are pieces of information that are transmitted from our web server or third-party web servers to your web browser and stored there for later retrieval. Cookies may be small files or other types of information storage. There are different types of cookies: i) Essential Cookies. Essential cookies are cookies to provide a correct and user-friendly website; and ii) Non-essential Cookies. Non-essential Cookies are any cookies that do not fall within the definition of essential cookies, such as cookies used to analyse your behaviour on a website (“analytical” cookies) or cookies used to display advertisements to you (“advertising” cookies). For further information on the Cookies we use, please refer to our Cookie Policy. The legal basis for processing is our legitimate interest and your consent.

g. Cookie consent

Our website uses the cookie consent tool CookieLawInfo of CookieYes to obtain your consent to the storage of certain cookies on your end device or to the use of certain technologies and to document this consent. When you enter our website, the following personal data is transferred to CookieYes:

● Your consent(s) or revocation of your consent(s)

● Your IP address

● Information about your browser

● Information about your terminal device

● Time of your visit to the website

Data We Collect Directly

a. General

We may ask you for Personal Data when you:

● use our website and services,

● participate online or otherwise in marketing and advertising activities,

● subscribe to Medimob`s marketing and promotional emails or other materials,

● interact with us on third-party social networking sites (subject to the terms of use and privacy policies of said third parties), or

● contact us.

In order to provide you with a more consistent and personalised user experience in your interactions with Medimob, data collected through one source may also be linked to other data collected by Medimob through other sources. This may include data that helps us identify you when you access our website through several different devices.

b. Contacting us

In addition to your name, company name, and e-mail address, IP address or telephone number, if provided, we usually collect the context of your message which may also include certain Personal Data. The Personal Data collected when contacting us is to handle your request and the legal basis is both your consent and Contract.

c. When using our services

We process the data of our users in order to be able to provide our contractual services as well as to ensure the security of our services and to be able to develop it further. This includes in particular our support, correspondence with you, invoicing, fulfilment of our accounting and tax obligations. Your data will not be used by us for automated decision making or profiling. Accordingly, the data is processed on the basis of fulfilling our contractual obligations as well as to fulfil our legal obligations.

We ensure that access by our staff members to your data is only available on a need-to-know basis, restricted to specific individuals, and is logged and audited. We communicate our privacy and security guidelines to our staff members and enforce privacy and protection safeguards strictly.

Please note: When using our services as a healthcare practitioner, you become the data controller and we become the data processor in accordance with Part 3 Chapter 4 of the DPA and Chapter 4 of the GDPR. Where we process your Personal Data as data processor or in other words on behalf of you, we will process the Personal Data involved in your use of our chat services in accordance with your instructions and shall use it only for the purposes agreed between you and us. For further information please contact us.

d. Administration, financial accounting, office organisation, contact management

We process data in the context of administrative tasks as well as organisation of our business, and compliance with legal obligations, such as archiving. In this regard, we process the same data that we process in the course of providing our contractual services. The processing bases are our legal obligations and our legitimate interest.

e. Payment Data

If you pay through our website your payment data will be processed via our payment service provider Stripe. Payment data will solely be processed through Stripe and we have no access to any Payment Data you may submit. The legal basis for the provision of a payment system is the establishment and implementation of the user contract for the use of the service.

f. Data management and customer support

For optimal data management and customer support, we may store the data related to your use of our services with us in our proprietary customer relationship management system. This data processing is based on our legitimate interest in providing our customer service.

g. Newsletter

If you have consented to receive our newsletter, we will use your email address and, if applicable, your name to send you information about us, our books and publications, promotions, and news. You can revoke your consent to receive the newsletter or to the creation of personalised user profiles at any time with effect for the future. You will find the unsubscribe link at the end of each newsletter. The revocation leads to the deletion of the collected user data. Our newsletter is sent as part of processing on our behalf by Mailchimp (Intuit Inc) to whom we pass on your email address for this purpose.

Marketing

Insofar as you have given us your consent to process your Personal Data for marketing and advertising purposes, we are entitled to contact you for these purposes via the communication channels you have given your consent to.

You may give us your consent in a number of ways including by selecting a box on a form where we seek your permission, or sometimes your consent is implied from your interactions or contractual relationship. Where your consent is implied, it is on the basis that you would have a reasonable expectation of receiving marketing communication based on your interactions or contractual relationship with us.

Our Marketing generally takes the form of e-mail but may also include other less traditional or emerging channels. These forms of contact will be managed by us, or by our contracted service providers. Every directly addressed marketing sent by us or on our behalf will include a means by which you may unsubscribe or opt out.

Principles of Processing Personal Data

a. Storage and Retention

We will retain your Personal Data as necessary in connection with the purposes described in this Privacy Policy, and in accordance with the UK`s retention periods if applicable. In the course of our business operations, your data is generally transferred to our IONOS server.

b. Security

Our website uses SSL or TLS encryption to ensure the security of data processing and to protect the transmission of confidential content, such as orders, login data or contact requests that you send to us. We have also implemented numerous security measures (“technical and organisational measures”) for example encryption or need to know access, to ensure the most complete protection of Personal Data processed through this website.

Nevertheless, internet-based data transmissions can always have security gaps, so that absolute protection cannot be guaranteed. And databases or data sets that include Personal Data may be breached inadvertently or through wrongful intrusion. Upon becoming aware of a data breach, we will notify all affected individuals whose Personal Data may have been compromised as expeditiously as possible after which the breach was discovered.

c. Special Category Data

Unless specifically required when using our services and explicit consent is obtained for that service, we do not process special category data.

d. Minors

We do not request Personal Data from minors and children and do not knowingly collect such data or pass it on to third parties.

e. Automated decision-making

Automated decision-making is the process of making a decision by automated means without any human involvement. Automated decision-making does not take place.

f. Do Not Sell

We do not sell your Personal Data.

g. Sharing and Disclosure

We will not disclose or otherwise distribute your Personal Data to third parties unless this is i) necessary for the performance of our services, ii) you have consented to the disclosure, iii) or if we are legally obliged to do so e.g., by court order or if this is necessary to support criminal or legal investigations or other legal investigations or other legal proceedings; or proceedings at home or abroad or to fulfil our legitimate interests.

h. International Transfer

We may transfer your Personal Data to other companies and/or staff members as necessary for the purposes described in this Privacy Policy. In order to provide adequate protection for your Personal Data when it is transferred, we have contractual arrangements regarding such transfers. We take all reasonable technical and organisational measures to protect the Personal Data we transfer.

Your Rights and Privileges

Under the DPA and GDPR, you can exercise the following rights:

● Right to information

● Right to rectification

● Right to object to processing

● Right to deletion

● Right to data portability

● Right of objection

● Right to withdraw consent

● Right to complain to a supervisory authority

● Right not to be subject to a decision based solely on automated processing.

If you have any questions about the nature of the Personal Data we hold about you, or if you wish to exercise any of your rights, please contact us.

a. Updating your information

If you believe that the information we hold about you is inaccurate or that we are no longer entitled to use it and want to request its rectification, deletion, or object to its processing, please do so by contacting us.

b. Withdrawing your consent

You can revoke consents you have given at any time by contacting us. The legality of the data processing carried out until the revocation remains unaffected by the revocation.

c. Access Request

In the event that you wish to make a Data Subject Access Request, you may inform us in writing of the same. We will respond to requests regarding access and correction as soon as reasonably possible. Should we not be able to respond to your request within thirty (30) days after receiving your request, we will inform you in writing within thirty (30) days of the time by which we will be able to respond to your request. If we are unable to provide you with any Personal Data or to make a correction requested by you, we shall generally inform you of the reasons why we are unable to do so (except where we are not required to do so under the respective legal regulations mentioned above).

d. Complaint to a supervisory authority

You have the right to complain about our processing of Personal Data to a supervisory authority responsible for data protection. The supervisory authority in the UK is: The Information Commissioner's Office (ICO) is located at Wycliffe House, Water Ln, Wilmslow SK9 5AF, UK www.ico.org.uk

Validity and questions

This Privacy Policy was last updated on the 18th of November, 2023, and is the current and valid version. However, we want to point out that from time to time due to actual or legal changes a revision to this policy may be necessary. If you have any data protection questions, please feel free to contact us.