At MedExpress Enterprises Ltd we are committed to safeguarding and
preserving the privacy of our visitors. These ‘key points’ summarise some
Information we collect
When you visit our website, we automatically collect and save your IP
Where you volunteer this information (i.e. by filling in an online form
to use our services), we will also save your name, delivery address,
email address, date of birth, telephone number, GP address, patient
notes, consultation notes, payment records and details of the medicines
you have ordered.
Use of your information
We use Your Data:
To provide our services to you (namely, medical consultations for
prescription medications) and to comply with regulatory requirements.
To send you details of our goods and services, or those of other
companies within our group, but only if you give us permission to do so.
We share Your Data:
With other third parties where this is necessary to deliver the
With other business entities within the MedExpress group.
With other third parties to send you details of their goods and
services, but only if you give us permission to do so.
Some of the information we collect is medical data. This information is
always treated confidentially. We will never disclose medical data unless
legally required or permitted to do so. It will not be used by us for
marketing purposes unless you give us your express permission.
MedExpress Enterprises Ltd (registered number 8805262), whose registered
office is at 37 Sun Street, 2nd Floor, London, England, EC2M 2PL
(“MedExpress”, we” “us” or “our”) knows that you care how information about
you (“Your Data”) is used and shared and we appreciate your trust in us to
do that carefully and sensibly. We respect your privacy and are committed
to protecting Your Data.
At MedExpress we are committed to safeguarding and preserving the privacy
of our customers and website visitors.
conditions (“Website Terms”), as set out here. This Policy explains
what happens to any personal information that you provide to us, or that we
collect from you whilst you visit our site.
We do update this Policy from time to time so please do review this Policy
Important information about who we are
MedExpress is a controller and responsible for all personal data it
receives and holds. We have appointed a data protection leader (“DPL”) who
is responsible for overseeing questions in relation to this Policy. If you
have any questions about this Policy, including any requests to exercise
your legal rights, please contact the DPL using the details set out below:
Full name of legal entity:
MedExpress Enterprises Ltd
Name or title of DPL:
37 Sun Street, EC2M 2PL
0208 123 0508
If you have any queries, concerns or complaints about the use of Your Data
by us, please raise them with the DPL. If this does not resolve the problem
to your satisfaction, or, if you prefer to raise the issue with somebody
else, then please speak to Dwayne D’Souza who will deal with your
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. 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 Policy and your duty to inform us of the changes
This version was last updated in May 2018.
It is important that the personal data we hold about you is accurate and
current. Please keep us informed if Your Data changes during your
relationship with us.
Information We Collect
If you register with us, we will collect personal data or personal
information from 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 a person’s identity has been removed
We may collect, use, store and transfer different kinds of data about you
which we have categorised as follows:
includes first name, last name, date of birth and gender.
includes delivery address email address and telephone numbers.
includes bank account, payment records and payment card details.
includes your patient medical records, GP details, patient notes,
consultation notes and details of medicines you have ordered and order
history. This category of data constitutes sensitive personal data for the purposes of data
protection legislation. This will only be collected where you have
expressly provided your consent to provide us with this data through
any online forms and medical questionnaires you complete and send to
us, telephone conversations and secure messaging with us, as well as
through photo assessments.
Marketing and Communications Data
includes your preferences in receiving marketing from us and our third
parties and your communication preferences.
We also collect and use Aggregated Data such as
statistical or demographic data for internal purposes. Aggregated Data may
be derived from Your Data but is not personal data as it does not directly
or indirectly reveal your identity. For example, we may aggregate
information about how you use our website and services to calculate the
percentage of users accessing a specific website feature, but this is
anonymised. However, if we combine or connect Aggregated Data with Your
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
How is Your Data collected?
We use different methods to collect data from and about you, including
Automated technologies or interactions
If you interact with our website, we may automatically collect data about
your equipment, browsing actions and patterns. When you visit our website,
we automatically collect information about your use of our site including
details of your visits such as pages viewed and the resources that you
access. Such information may include Aggregated Data, traffic data,
location data and other communication data. For more information about the
You may give us your Identity, Contact, Medical and Financial Data by
filling in forms, or by corresponding with us by post, phone, email or
otherwise. This includes personal data you provide when you:
make an online enquiry;
completing forms and medical questionnaires on our website. This includes
information provided at the time of registering to use our site,
subscribing to our service, consultations for treatments, posting material
or requesting further services;
make an online payment;
subscribe to our services or publications;
request marketing material to be sent to you;
provide us with feedback.
Your Medical Data is treated confidentiality, which means that none of our
staff can access it unless they are a healthcare professional (or owe a
similar duty of confidentiality). We will never disclose Medical Data
without your consent unless legally required or permitted to do so.
Your Medical Data will not be used by us to send you information about our
products and services (i.e. for marketing purposes) unless you give us your
express consent to use your Medical Data this way.
You can set your browser to refuse all or some browser cookies, or to alert
please note that some parts of this website may become inaccessible or not
function properly. For more information about the cookies we use, please
Use of Your Information
We will only use the information that we collect from you as follows:
To enable us to provide our health services to you
To enable us to comply with regulatory requirements
To communicate with you in the event that there is a query or problem
with your order
To inform you of any changes to our website, services or goods and
For record keeping purposes
To track and analyse activity on our website
We will only contact you for marketing purposes where you have given us
your express consent to contact you for this purpose. Once you have given
us your permission to contact you for marketing purposes, we may use Your
Data for one or more of the following:
To provide information to you that you request from us relating to our
products or services.
To provide information to you relating to other products that may be of
interest to you.
To allow selected third parties to use Your Data to enable them to
provide you with information regarding unrelated goods and services,
which we believe may interest you.
You may change your mind and withdraw your permission for us to contact you
for marketing purposes at any time by emailing us at email@example.com. This will
not affect your use of our services.
Use of your Medical Data for marketing purposes
Where you have given us your express permission in advance (separately to
permitting us to send you more general marketing material), we may also use
your Medical Data to send you specialist information about our products and
services. For example, if a customer told us that they suffer from asthma
and asked us to send them marketing material about asthma related goods and
services, we may do so. This information would never be shared with third
parties to enable them to send you information regarding their goods and
You can change your mind and withdraw your permission for us to use your
Medical Data for marketing purposes at any time by emailing us at
firstname.lastname@example.org. This will not affect your use of our services.
Change of purpose
We will only use Your 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 email email@example.com. Should we
need to use Your 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 Data without your knowledge or
consent, in compliance with the above rules, where this is required or
permitted by law.
Storing Your Personal Data
We have put in place appropriate security measures to prevent Your Data
from being accidentally lost, used or accessed in an unauthorised way,
altered or disclosed. In addition, we limit access to Your Data to those
employees, agents, contractors and other third parties who have a business
need to know. They will only process Your Data on our instructions and they
are subject to a duty of confidentiality.
We have put in place procedures to deal with any suspected personal data
breach and will notify you and any applicable regulator of a breach where
we are legally required to do so.
Please note that sending information via the internet is not totally secure
and on occasion such information can be intercepted. We cannot guarantee
the security of personal information that you choose to send us
electronically and sending such information is entirely at your own risk.
We will only retain Your Data for as long as necessary to fulfil the
purposes we collected it for, including for the purposes of satisfying any
legal, accounting, or reporting requirements.
To determine the appropriate retention period for Your Data, we consider
the amount, nature, and sensitivity of the personal data, the potential
risk of harm from unauthorised use or disclosure of Your Data, the purposes
for which we process Your Data and whether we can achieve those purposes
through other means, and the applicable legal requirements.
During the provision of our services to you we will retain Your Data to
provide our goods or services to you.
We are required by law to retain specific categories of Your Data for
certain periods after we stop providing our goods or services to you. We
are registered with the General Pharmaceutical Council with registration
number 9010254. We are therefore required to store any Medical Data,
Identity Data and Contact Data submitted to us to comply with our legal
Please note that we may keep Your Data for longer than the periods stated
above if it is necessary. However, this will be assessed on a case by case
basis. If we determine that it is necessary to keep Your Data for longer
than the periods listed above, we will confirm this to you in writing when
we have finished providing our goods and services to you and explain why it
Disclosing Your Data
As set out above, we may disclose Your Data to third parties, in accordance
with this Policy, in the following circumstances:
We may share your Identity, Contact and Financial Data with our External
Third Parties (as set out below) to enable us to provide our services (for
example, we may provide your postal address to a courier or we may share
your name, address and age with a third-party service provider in order to
verify your age and identity). The External Third Parties we work with
To process your online payment.
Feefo and Trustpilot
To assist with our review link and to send you messages,
such as emails containing invoices or notifications
To react and respond to your enquiries directly.
To monitor and identify usability website issues.
Livechat and Facebook Messenger
To allow you to interact with third-party live chat
platforms directly from the pages of our website, for
contacting and being contacted by our support service. This
information is anonymised, so you cannot be identified.
We send anonymous surveys about your medical treatment
using SurveyMonkey for clinical governance. This type of
service allows you to interact with third-party online
survey platforms directly from the pages of our website.
Amazon SES email servers
We send marketing emails to you if you have consented to
receive marketing material. We send emails using the Amazon
SES email servers. Emails are customized using your order
If you register with our mailing list or sign up to our
newsletter, your email address will be added to our
marketing contact list through Mailchimp.
We record telephone calls for monitoring and training
purposes which is kept for one month. This is used by the
patient and MedExpress in the event of a dispute, and in
order to manage and regulate the performance of our staff.
We may share your Identity, Contact, Financial and Medical Data with your
GP or any other third party, where you have provided your express consent
for us to share Your Data with them.
Please note that we will never share your Medical Data without your
We may share Marketing and Communications Data where you have provided your
express consent for us to share such with third parties for marketing
We may also share Your Data:
with our internal third parties including the business entities within
the MedExpress Group (which includes Dermatica Ltd and Beauty Bear Ltd).
where we are legally required or permitted by law to disclose Your Data,
for example with National Health Service Providers or regulatory bodies.
In the event of a joint venture, collaboration, financing, sale, merger
or reorganisation of the company. If a change happens to our business, then
the new owners may use Your Data in the same way as set out in this Policy.
To further fraud protection and reduce the risk of fraud (for example, to
comply with anti-money laundering regulations).
In addition to the disclosures set out in “Disclosing Your Data”
above, some of our third parties are based outside the European Union so
their processing of Your Data will involve a transfer of data outside the
European Union. Whenever we transfer Your Data out of the European Union,
we ensure a similar degree of protection is afforded to it by ensuring at
least one of the following safeguards is implemented:
We will only transfer Your Data to countries that have been deemed to
provide an adequate level of protection for personal data by the European
Where we use certain service providers, we may use specific contracts
approved by the European Commission which give personal data the same
protection it has in Europe.
Where we use providers based in the US, we may transfer data to them if
they are part of the EU-US Privacy Shield Framework which requires them to
provide similar protection to personal data shared between the Europe and
Please email firstname.lastname@example.org if you
want further information on the specific mechanism used by us when
transferring Your Data outside the European Union.
Third Party Links
On occasion we include links to third-party websites, plug-ins and
applications on this website. 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 and/or policies. When you leave our website, we
Your legal rights
In certain circumstances, you have the following rights under data
protection laws in relation to Your Data. You have the right to:
Request access to Your Data
(commonly known as a “data subject access request”). This enables you to
receive a copy of the Your 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 Data
. This enables you to ask us to delete or remove Your 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 Data where you have successfully exercised
your right to object to processing (see below), where we may have processed
Your Data unlawfully or where we are required to erase Your 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 Data
where we are relying on a legitimate interest (or those of a third party)
and there is something about your 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 Data for direct marketing purposes. In some cases, we may
demonstrate that we have compelling legitimate grounds to process Your Data
which override your rights and freedoms.
Request restriction of processing of Your Data
. This enables you to ask us to suspend the processing of Your Data in the
if you want us to establish the data’s accuracy;
where our use of Your Data is unlawful, but you do not want us to erase
where you need us to hold Your 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 and/or legal grounds to use it.
Request the transfer of Your Data
to you or to a third party. We will provide to you, or a third party you
have chosen, Your 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 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. Please note that we may not be able
to comply with this request where we have a legal obligation to keep Your
If you wish to exercise any of the rights set out above, please email email@example.com or
telephone 0208 123 0508 and ask to speak to the DPL.
Data subject access request
You will not have to pay a fee to access Your Data (or to exercise any of
the other rights set out above). However, we may charge a reasonable fee if
your request is clearly unfounded, repetitive or excessive. Alternatively,
we may 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 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 may take us longer than a month if your request is particularly complex
or you have made several requests. In this case, we will notify you and
keep you updated.
Please do not hesitate to contact us regarding any matter relating to this
Policy at firstname.lastname@example.org.