Privacy Policy

 

BACKGROUND:

 

CLYNXX Limited understands that your privacy is important to you and that you care about how your personal data is used. We respect and value the privacy of everyone who visits this website, clynxx.uk “Our site” and will only collect and use personal data in ways that are described here, and in a way that is consistent with our obligations and your rights under the law.

 

Please read this Privacy Policy carefully and ensure that you understand it. By using this site your acceptance of this Privacy Policy is assumed.

 

1. Information About Us

Our Site is owned and operated by CLYNXX Limited, a limited company registered in England & Wales under company number 10333306.

Registered address: 86-90 Paul St, Shoreditch, LONDON EC2A 4NE

Data Protection Officer: Takudzwa Muswizu

Email address: info@clynxx.com

Telephone number: 0330 113 7894.

Postal address: 86-90 Paul St, Shoreditch, LONDON EC2A 4NE

We are regulated by the Information Commissioner’s Office

 

2. What Does This Policy Cover?

This Privacy Policy applies only to your use of Our Site. Our Site may contain links to other websites. Please note that we have no control over how your data is collected, stored, or used by other websites and we advise you to check the privacy policies of any such websites before providing any data to them.

 

3. What Is Personal Data?

Personal data is defined by the General Data Protection Regulation (EU Regulation 2016/679) (the “GDPR”) and the Data Protection Act 2018 (collectively, “the Data Protection Legislation”) as ‘any information relating to an identifiable person who can be directly or indirectly identified in particular by reference to an identifier’.

Personal data is, in simpler terms, any information about you that enables you to be identified. Personal data covers obvious information such as your name and contact details, but it also covers less obvious information such as identification numbers, electronic location data, and other online identifiers.

 

4. What Are My Rights?

Under the Data Protection Legislation, you have the following rights, which we will always work to uphold:

1. 1. 1. 1. The right to be informed about our collection and use of your personal data. This Privacy Policy should tell you everything you need to know, but you can always contact us to find out more or to ask any questions using the details in Part 12.
         2. The right to access the personal data we hold about you. Part 11 will tell you how to do this.
         3. The right to have your personal data rectified if any of your personal data held by us is inaccurate or incomplete. Please contact us using the details in Part 12 to find out more.
         4. The right to be forgotten, i.e. the right to ask us to delete or otherwise dispose of any of your personal data that we hold. Please contact us using the details in Part 12 to find out more.
         5. The right to restrict (i.e. prevent) the processing of your personal data.
         6. The right to object to us using your personal data for a particular purpose or purposes.
         7. The right to withdraw consent. This means that, if we are relying on your consent as the legal basis for using your personal data, you are free to withdraw that consent at any time.
         8. The right to data portability. This means that, if you have provided personal data to us directly, we are using it with your consent or for the performance of a contract, and that data is processed using automated means, you can ask us for a copy of that personal data to re-use with another service or business in many cases.
         1. Rights relating to automated decision-making and profiling. We do not use your personal data in this way.

For more information about our use of your personal data or exercising your rights as outlined above, please contact us using the details provided in Part 12.

It is important that your personal data is kept accurate and up-to-date. If any of the personal data we hold about you changes, please keep us informed as long as we have that data.

Further information about your rights can also be obtained from the Information Commissioner’s Office or your local Citizens Advice Bureau.

If you have any cause for complaint about our use of your personal data, you have the right to lodge a complaint with the Information Commissioner’s Office. We would welcome the opportunity to resolve your concerns ourselves, however, so please contact us first, using the details in Part 12.

 

5. What Data Do You Collect and How?

Depending upon your use of Our Site, we may collect and hold some or all of the personal and non-personal data set out in the table below, using the methods also set out in the table. We do not collect any data relating to criminal convictions and/or offences

 

Data Collected	How We Collect the Data
Patient and prescribers’ Identity Information including Name, Date of Birth, Gender, Ethnicity	Prescribers enter this information on to our site
Patient and prescribers’ Contact information including Address, Email, mobile and telephone number	Prescribers enter this information on to our site
Prescribers’ Business information including Regulatory Registration numbers,	Prescribers or their representatives send us this information.
Technical information including IP address, browser type, operating system.	Recorded automatically by our servers.

 

6. How Do You Use My Personal Data?

Under the Data Protection Legislation, we must always have a lawful basis for using personal data. The following table describes how we may use your personal data, and our lawful bases for doing so:

 

What We Do	What Data We Use	Our Lawful Basis
Registering you on Our Site. Prescribers Patients	Prescribers – Identity information and business information Patients – Identity information and Contact information	Prescribers – Consent Patients – Special Category Health Data Lawful basis (‘necessary… in the exercise of official authority vested in the controller’ (Article 6(1)(e)).12)
Supplying our services to you.	Prescribers – Identity information and business information Patients – Identity information and Contact information.	Prescribers – Consent Patients – Special Category Health Data Lawful basis (‘necessary… in the exercise of official authority vested in the controller’ (Article 6(1)(e)).12).
Managing payments for our services.	Prescribers – Contact and business information Patients – Contact information.	Prescribers – Consent Patients – Special Category Health Data Lawful basis (‘necessary… in the exercise of official authority vested in the controller’ (Article 6(1)(e)).12)..
Communicating with you.	Prescribers – Contact and business information Patients – Contact information.	Prescribers – Consent Patients – Special Category Health Data Lawful basis (‘necessary… in the exercise of official authority vested in the controller’ (Article 6(1)(e)).12)..
Supplying you with information by email and post that you have opted-in-to (you may opt-out at any time by letting us know or using the unsubscribe link in our emails.)	Prescribers – Contact information .	Prescribers – Consent .

 

With your permission and/or where permitted by law, we may also use your personal data for marketing purposes, which may include contacting you by email or telephone or post with information, news, and offers on our services. You will not be sent any unlawful marketing or spam. We will always work to fully protect your rights and comply with our obligations under the Data Protection Legislation and the Privacy and Electronic Communications (EC Directive) Regulations 2003, and you will always have the opportunity to opt-out. We will always obtain your express opt-in consent before sharing your personal data with third parties for marketing purposes and you will be able to opt-out at any time.

We will only use your personal data for the purpose(s) for which it was originally collected unless we reasonably believe that another purpose is compatible with that or those original purpose(s) and need to use your personal data for that purpose. If we do use your personal data in this way and you wish us to explain how the new purpose is compatible with the original, please contact us using the details in Part 12.

If we need to use your personal data for a purpose that is unrelated to, or incompatible with, the purpose(s) for which it was originally collected, we will inform you and explain the legal basis which allows us to do so.

In some circumstances, where permitted or required by law, we may process your personal data without your knowledge or consent. This will only be done within the bounds of the Data Protection Legislation and your legal rights.

 

7. How Long Will You Keep My Personal Data?

We will not keep your personal data for any longer than is necessary in light of the reason(s) for which it was first collected. Your personal data will therefore be kept for the following periods (or, where there is no fixed period, the following factors will be used to determine how long it is kept): All data is kept on our servers indefinitely. Prescribers and patients (or their representatives) may consult us to discuss retention of this data. The BMA suggests that data be stored to a minimum of at least the death of the patient however sees no circumstance why electronic data of this nature must be destroyed. Each case will be dealt with on an individual basis. Payment information will be destroyed at regular intervals no longer than 5 years from last use.

 

 

8. How and Where Do You Store or Transfer My Personal Data?

We will only store or transfer your personal data within the UK. This means that it will be fully protected under the Data Protection Legislation.

 

AND

 

We may transfer some of your personal data within the European Economic Area (the “EEA”). The EEA consists of all EU member states, plus Norway, Iceland, and Liechtenstein. This means that your personal data will be fully protected under the Data Protection Legislation, GDPR, and/or to equivalent standards by law. This is only on occasions where your data needs to be transferred to fulfil our services that are provided to you by companies based in this region. An example of such a case is if you require a medicine to be dispensed by a company in this region.

 

AND

Where we transfer your data to a third party based in the US, the data may be protected if they are part of the EU-US Privacy Shield. This requires that third party to provide data protection to standards similar to those in Europe. More information is available from the European Commission.

Please contact us using the details below in Part 12 for further information about the particular data protection mechanisms used by us when transferring your personal data to a third country.

The security of your personal data is essential to us, and to protect your data, we take a number of important measures, including the following:

• limiting access to your personal data to those employees, agents, contractors, and other third parties with a legitimate need to know and ensuring that they are subject to duties of confidentiality;
• procedures for dealing with data breaches (the accidental or unlawful destruction, loss, alteration, unauthorised disclosure of, or access to, your personal data) including notifying you and/or the Information Commissioner’s Office where we are legally required to do so;
• Our organisation follows NCSC guidance on cyber security on Small & medium sized organisations alongside performing regular mock response 'exercise-in-a-box' as detailed here https://www.ncsc.gov.uk/information/exercise-in-a-box.
• Taking additional technological security measures
• Anonymising or pseudonymising data where possible
• Consulting a security expert

 

9. Do You Share My Personal Data?

We will not share any of your personal data with any third parties for any purposes, subject to the following exceptions.

If we sell, transfer, or merge parts of our business or assets, your personal data may be transferred to a third party. Any new owner of our business may continue to use your personal data in the same way(s) that we have used it, as specified in this Privacy Policy.

In some limited circumstances, we may be legally required to share certain personal data, which might include yours, if we are involved in legal proceedings or complying with legal obligations, a court order, or the instructions of a government authority.

 

We may sometimes contract with the following third parties to supply certain services.

 

Recipient	Activity Carried Out	Sector	Location
Payment processor. (Data processor)	To collect payments on our behalf.	Financial.	UK and USA
Electronic signature generator (Data processor)	Independent signing of documents ensuring that documents integrity is maintained following signing by Dr	Technology	UK and USA

 

If any of your personal data is shared with a third party, as described above, we will take steps to ensure that your personal data is handled safely, securely, and in accordance with your rights, our obligations, and the third party’s obligations under the law, as described above in Part 8.

If any personal data is transferred outside of the EEA, we will take suitable steps in order to ensure that your personal data is treated just as safely and securely as it would be within the UK and under the Data Protection Legislation, as explained above in Part 8.

 

10. Can I Withhold Information?

You may access certain areas of Our Site without providing any personal data at all. However, to use all features and functions available on Our Site you may be required to submit or allow for the collection of certain data.

 

11. How Can I Access My Personal Data?

If you want to know what personal data we have about you, you can ask us for details of that personal data and for a copy of it (where any such personal data is held). This is known as a “subject access request”.

All subject access requests should be made in writing and sent to the email or postal addresses shown in Part 12. To make this as easy as possible for you, a Subject Access Request Form is available for you to use. You do not have to use this form, but it is the easiest way to tell us everything we need to know to respond to your request as quickly as possible.]

There is not normally any charge for a subject access request. If your request is ‘manifestly unfounded or excessive’ (for example, if you make repetitive requests) a fee may be charged to cover our administrative costs in responding.

We  will respond to your subject access request within 28 days and, in any case, not more than one month of receiving it. Normally, we aim to provide a complete response, including a copy of your personal data within that time. In some cases, however, particularly if your request is more complex, more time may be required up to a maximum of three months from the date we receive your request. You will be kept fully informed of our progress.

 

12. How Do I Contact You?

To contact us about anything to do with your personal data and data protection, including to make a subject access request, please use the following details (for the attention of Data Protection Officer):

Email address: info@clynxx.com

Telephone number: 0330 113 7894

Postal Address: 86-90 Paul St, Shoreditch, LONDON EC2A 4NE

 

13. Changes to this Privacy Policy

We may change this Privacy Notice from time to time. This may be necessary, for example, if the law changes, or if we change our business in a way that affects personal data protection.

Any changes will be immediately posted on Our Site and you will be deemed to have accepted the terms of the Privacy Policy on your first use of Our Site following the alterations. We recommend that you check this page regularly to keep up-to-date. This Privacy Policy was last updated on the 10^th of May 2020.