Privacy Policy

Welcome to the Healthcare Support Hub Ltd’s privacy policy.

Healthcare Support Hub Ltd 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 when you visit our website (regardless of where you visit it from) and tell you about your privacy rights and how the law
protects you.

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

1. IMPORTANT INFORMATION AND WHO WE ARE
2. THE DATA WE COLLECT ABOUT YOU
3. HOW IS YOUR PERSONAL DATA COLLECTED?
4. HOW WE USE YOUR PERSONAL DATA
5. DISCLOSURES OF YOUR PERSONAL DATA
6. INTERNATIONAL TRANSFERS
7. DATA SECURITY
8. DATA RETENTION
9. YOUR LEGAL RIGHTS

1. IMPORTANT INFORMATION AND WHO WE ARE

PURPOSE OF THIS PRIVACY POLICY

This privacy policy aims to give you information on how Healthcare Support Hub Ltd collects and processes your personal data through your use of this website, including any data you may provide through this website when you select to download a guide or redeem an offer pack.

This website is not intended for children and we do not knowingly collect data relating to children.

It is important that you read this privacy policy together with any other privacy policy or fair processing policy we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy policy supplements other notices and privacy policies and is not intended to override them.

CONTROLLER

Healthcare Support Hub Ltd is the controller and responsible for your personal data (collectively referred to as Healthcare Support Hub Ltd, “we”, “us” or “our” in this privacy policy).

We have appointed a data protection officer (DPO) who is responsible for overseeing questions in relation to this privacy policy. If you have any questions about this privacy policy, including any requests to exercise your legal rights, please contact the DPO using the details set out below.

CONTACT DETAILS

If you have any questions about this privacy policy or our privacy practices, please contact our DPO in
the following ways:

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 (www.ico.org.uk) at https://ico.org.uk/make-a-complaint or by telephone: 0303 123 1113. We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.

CHANGES TO THE PRIVACY POLICY AND YOUR DUTY TO INFORM US OF CHANGES

We keep our privacy policy under regular review.

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.

THIRD-PARTY LINKS

We may also collect information that Your browser sends whenever You visit our Service or when You access the Service by or through a mobile device.

2. THE DATA WE COLLECT ABOUT 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).

The personal data we collect about you depends on the particular activities carried out through our website. We may collect, use, store and transfer the following personal data about you:

your name, address and contact information, including email address and telephone number
whether you are an adult
your activities on, and use of, our website
your contact history
technical data such as your internet protocol (IP) address, 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 website
information about how you use our website and technology systems
your responses to surveys and promotions
information about providers to you of medical devices and patient care
marketing and communications data which include your preferences in receiving marketing from us and your communication preferences.

We also collect, use and share aggregated data such as statistical or demographic data for any purpose. For example, we may aggregate information about how you use our website, products and services to calculate the percentage of users accessing a specific website feature. 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. 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.

SPECIAL CATEGORY PERSONAL DATA

Certain personal data we collect is treated as a special category to which additional protections apply under data protection law (Special Category Data). As part of our collection of data an inference will be made as to your health.

We do not collect any Special Category Data about you other than certain information about your health. More specifically we do not collect details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, and genetic and biometric data. Nor do we collect any information about criminal convictions and offences.

Where we process such Special Category Data, we will also ensure we are permitted to do so under data protection laws. We collect and use this personal data for the purposes described in the section ‘How we use your personal data’ below.

3. HOW IS YOUR PERSONAL DATA COLLECTED?

We collect personal data from you:

directly, when you enter or send us information, such as when you download a guide or redeeming an offer pack from a third party, and
indirectly, such as your browsing activity while on our website; as you interact with our website, we will automatically collect technical data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies. Please see our cookie policy [LINK] for further details.
We will receive personal data about you from various third parties as set out below:
Technical data from the following parties:
(a) analytics providers such as Google based outside the UK;
(b) advertising and social media networks based inside and/or outside the UK; and
(c) search information providers based inside and/or outside the UK.

4. HOW WE USE YOUR PERSONAL DATA

Under data protection law, we can only use your personal data if we have a proper reason, eg:

A legitimate interest is when we have a business or commercial reason to use your personal data, so long as this is not overridden by your own rights and interests. We will carry out an assessment when relying on legitimate interests, to balance our interests against your own. You can obtain details of this assessment by contacting us (see ‘How to contact us’ in “Your Legal Rights” section below).

We will rely on explicit consent as a legal basis for processing any Special Category Data and we will get your consent before sending direct marketing communications to you via email. You have the right to withdraw consent to marketing at any time by contacting us.

PURPOSES FOR WHICH WE WILL USE YOUR PERSONAL DATA

We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

If, and to the extent, the type of data processed in accordance with the table below involves any Special Category Data, in additional to any other lawful bases identified in the table below, we will also rely on explicit consent when relevant.

Note that we may process your personal data for 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 in the table below.

What we use your personal data for

Type of data

Our reasons/lawful basis for
processing including basis of
legitimate interest

Providing general health related information and offer complimentary items from third parties providers of medical devices and patient care

(a) your name, address and
contact information, including email address and telephone number

(b) whether you are an adult

(a) Your consent to provide

marketing services to third parties;
general health related
information (e.g. guides)

(b) necessary for our or third party legitimate interests (i.e. to realise or grow the value in our business and assets)

To manage our relationship with you which will include:
(a) notifications not related to marketing, including about changes to our terms or policies
or other important notices

(b) asking you to leave a review or take a survey

(a) your name, address and contact information, including email address and telephone number

(a) necessary to comply with a legal obligation

(b) necessary for our legitimate interests (to keep our records updated and to study how website users use our website)

To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)

(a) your name, address and contact information, including email address and telephone number

(b) technical data such as your internet protocol (IP) address, 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 website

(a) necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise)

(b) necessary to comply with a
legal obligation

To deliver relevant website content to you and measure or understand the effectiveness of our website

(a) your name, address and contact information, including email address and telephone number

(b) your activities on, and use of, our website

(d) technical data such as your internet protocol (IP) address, 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 website

(e) information about how you use our website and technology systems

(f) your responses to surveys and promotions

(g) marketing and communications data which include your preferences in
receiving marketing from us and your communication preferences

necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform our
marketing strategy)

To use data analytics or to share your personal data with advertising and social media networks and search information providers to improve our website, marketing and user experiences and to grow our business and inform our
marketing strategy.

(a) your name, address and contact information, including email address and telephone number

(b) your activities on, and use of, our website

(e) information about how you use our website and technology systems

necessary for our legitimate interests (to define types of users of our website, to keep our website updated and relevant, to develop our business and to inform our marketing strategy)

Disclosures and other activities necessary to comply with legal and regulatory obligations that apply to our business, e.g. to record and demonstrate evidence of your consent where relevant

(a) your name, address and contact information, including email address and telephone number

(b) whether you are an adult

to comply with our legal and regulatory obligations

To share your personal data with third parties that will or may take control or ownership of some or all of our business (and professional advisors acting on our or their behalf) in connection with a significant corporate transaction or restructuring, including a merger, acquisition, asset sale, initial public offering or in the event of our insolvency.

In such cases information will be anonymised where possible and only shared where necessary

(a) your name, address and contact information, including email address and telephone number

Depending on the circumstances:

to comply with our legal and regulatory obligations
in other cases, for our legitimate interests, ie to protect, realise or grow the value in our business and assets

To make suggestions and recommendations to you about goods or services that may be of interest to you

(a) your name, address and contact information, including email address and telephone number;

(b) your activities on, and use of, our website;

(c) technical data such as your internet protocol (IP) address, 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 website;

(d) information about how you use our website and technology systems

Necessary for our legitimate interests (to develop our products/services and grow our business)

HOW AND WHY WE USE YOUR PERSONAL DATA-SHARING

See ‘Disclosures of Your Personal Data’ and ‘International Transfers’ sections for further information on the steps we will take to protect your personal data where we need to share it with others .

MARKETING

We will use your personal data to send you updates (by email) about our website.

We may use your personal data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you (we call this marketing). We have a legitimate interest in using your personal data for marketing purposes (see above ‘How We Use Your Personal Data’). This means we do not need your consent to send you marketing information. If we change our marketing approach in the future so that consent is needed, we will ask for this separately and clearly.

You have the right to opt out of receiving marketing communications at any time by:

contacting us at help@stomahub.co.uk; or

using the ‘unsubscribe’ link in emails.

We may ask you to confirm or update your marketing preferences if there are changes in the law, regulation, or the structure of our business.

We will always treat your personal data with the utmost respect and never sell or share it with other organisations without your explicit consent.

For more information on your right to object at any time to your personal data being used for marketing purposes, see ‘Your Legal Rights’ section below.

THIRD PARTY MARKETING

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

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 wish to get 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.

5. 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:

(a) Service Providers and other third parties acting as processors who are based in the United Kingdom and provide IT and system administration services to us.
(b) Providers of data analytics services, advertising and social media networks and search information providers who are based in the United Kingdom and provide information to us for the purposes of allowing us to improve our website, marketing and user experiences and to grow our business and inform our marketing strategy.
(c) Professional advisers acting as processors or joint controllers including lawyers and the DPO based in the United Kingdom who provide consultancy and legal services.
(d) Regulators and other authorities acting as processors or joint controllers based in the United Kingdom who require reporting of processing activities in certain circumstances
(e) Third parties providers of medical devices and patient care acting as controllers who are based in the UK and to whom we provide marketing services to.
(f) 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.

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. 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 and explicit consent when required.

FURTHER INFORMATION

If you would like more information about who we share our data with and why, please contact us (see ‘How to contact us’ in “Your Legal Rights” section below).

6. INTERNATIONAL TRANSFERS

Many third parties we share your data with are based outside the UK so their processing of your personal data will involve a transfer of data outside the UK.

Whenever we transfer your personal data out of the UK, we ensure a similar degree of protection is
afforded to it by ensuring at least one of the following safeguards is implemented:

Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the United Kingdom.

Any changes to the destinations to which we send personal data or in the transfer mechanisms we rely on to transfer personal data internationally will be notified to you in accordance with the section on ‘Changes to the privacy policy’ in Important Information and Who We Are above.

FURTHER INFORMATION

If you would like further information about data transferred outside the UK and EEA, please contact us OR our Data Protection Officer (see ‘How to contact us’ in “Your Legal Rights” section below).

7. DATA SECURITY

You may exercise Your rights of access, rectification, cancellation and opposition by contacting Us. Please note that we may ask You to verify Your identity before responding to such requests. If You make a request, We will try our best to respond to You as soon as possible.

You have the right to complain to a Data Protection Authority about Our collection and use of Your Personal Data. For more information, if You are in the European Economic Area (EEA), please contact Your local data protection authority in the EEA.

8. DATA RETENTION

We will not keep your personal data for longer than we need it for the purpose for which it is used. For example, we won’t keep the delivery address you have provided in order to redeem an offer pack for longer than as required for the third party provider of medical devices and patient care to post the offer pack to you.

Other reasons for keeping said data could be to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, 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.

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 any case, following the end of the relevant retention period, we will delete or anonymise your personal data.

9. YOUR LEGAL RIGHTS

You generally have the following rights, which you can usually exercise free of charge:

Access to a copy of 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.

Correction (also known as rectification)

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.

Erasure (also known as the right to be forgotten)

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.

Restriction of use

The right to require us to restrict use of your personal data in certain circumstances, e.g. if you contest the accuracy of the data

Data portability

The right to receive the personal data you provided to us, in a structured, commonly used and machine-readable format and/or transmit that data to a third party. 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.

To object to use

The right to object:

at any time to your personal data being used for direct marketing (including profiling)
in certain other situations to our continued use of your personal data, e.g. where we use your personal data for our legitimate interests unless there are compelling legitimate grounds for the processing to continue or the processing
is required for the establishment, exercise or defence of legal claims

Not to be subject to decisions without human involvement

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
We do not make any such decisions based on data collected by our website

The right to withdraw consents

If you have provided us with a consent to use your personal data you have a right to withdraw that consent easily at any time. You may withdraw consents by emailing help@stomahub.co.uk

Withdrawing a consent will not affect the lawfulness of our use of your personal data in reliance on that consent before it was withdrawn.

If you withdraw your consent, we may not be able to provide certain information or offers to you. We will advise you if this is the case at the time you withdraw your consent.

For further information on each of those rights, including the circumstances in which they do and do not apply, please contact us (see ‘How to contact us’ below). You may also find it helpful to refer to the guidance from the UK’s Information Commissioner on your rights under the UK GDPR.

If you would like to exercise any of those rights, please email, call or write to us—see below: ‘How to contact us’. When contacting us please:

provide enough information to identify yourself i.e. your full name and email and any additional identity information we may reasonably request from you, and

let us know which right(s) you want to exercise and the information to which your request relates.

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.

HOW TO CONTACT US

You can contact us and/or our Data Protection Officer by post, email or telephone if you have any questions about this privacy policy or the information we hold about you, to exercise a right under data protection law or to make a complaint.

Our contact details are shown below:

Healthcare Support Hub Ltd

8 Tavistock Street, Leamington Spa, CV32 5PL

help@stomahub.co.uk

Phone number: 0330 043 6727

DPO

8 Tavistock Street, Leamington Spa, CV32 5PL

dpo@stomahub.co.uk

Phone number: 0330 043 6727

DO YOU NEED EXTRA HELP?

If you would like this policy in another format (for example audio, large print, braille) please contact us (see ‘How to contact us’ above).