PRIVACY STATEMENT

THE WELLBEING COMPANY CORNWALL T/A Rapid Health Test, a company registered in England and Wales under number 07544454 whose registered address is at Kent House, St Clements Road, Truro, TR1 1EQ hereinafter referred to as ‘Rapid Health Test’ ‘We’, ‘Us’ or ‘Our’), have created this privacy statement (‘Statement’) in order to reflect the transparency requirements expected of Us by law and Our own ethics. In this Statement, references to ‘You’, ‘Your’ and ‘Customer’ are references to Customers who uses the Site and the services at RapidHealthTest.com.

Your privacy is extremely important and We are only too happy to comply with the law and provide You with clear and transparent information about how We use Your PD. We only process it for the purposes outlined and We process as little of it as possible. Our aim is not to be intrusive and We undertake not to ask You irrelevant or unnecessary questions. We will try Our best to keep Your PD accurate and up-to-date but do try to help Us with this too please! We also have robust measures and procedures in place to minimise the risk of unauthorised access and to keep it secure. Also, We only share it with third parties where We have a right to do so and where we are satisfied that the third party shall treat it with the same or higher levels of respect.

This document outlines how We process Your when You use Our Site or otherwise communicate with us including by email or telephone. We are committed to respecting Your privacy and protecting Your PD. For the purpose of the Data Protection Legislation, We are the Data Controller (ICO registration number: ZA747968).

For all matters relating to privacy and data protection, please contact Dr Stolte by email to [email protected] or by telephone to 01872 227509

We are regulated by the General Medical Council (GMC) and the Care Quality Commission (CQC)

This Statement incorporates Our Cookie Policy and Service Terms. Unless otherwise stated, any defined terms in here shall have the meaning set out in the Service Terms

We might make changes to this Statement but if We do, We will, where appropriate, notify You by email, or, when You next log in, the amended version (and specific terms) will be displayed on-screen and You may be required to read and accept them to continue.

● How do We process Your Personal Data?

● How do We use Your Personal Data to communicate with You?

● Who has access to Your Personal Data and where is it stored?

● What are Your rights under Data Protection Legislation?

● How can You submit a query or a complaint?

● Do We use cookies?

● Changes to this Statement

● Definitions & Interpretations

1. HOW DO WE PROCESS YOUR PERSONAL DATA?

1.1 PERSONAL DATA YOU PROVIDE TO US VOLUNTARILY: In order for Us to provide You with Our Services, We need to process some of Your PD. We understand that Your PD belongs to You and You provide it to Us on trust that We will use it lawfully i.e. appropriately, proportionately, only in respect of the stated purpose and We will only hold on to it for as short a time as possible. Most important of all, We must have a valid lawful basis for processing Your PD and where We are processing Special Category Data, We also need to identify an additional condition for processing this type of data. Rather than have lots of paragraphs of text where all these transparency requirements are scattered throughout this Statement, We hope You find having most of it all in one eyeshot in Our tables easier to navigate:

Personal Data (‘PD’)	Source	Purpose	Lawful Basis for general processing as set out in Article 6 GDPR	Condition for special category processing	Retention
name, DOB, phone number, postal address, email address	Customer	To provide you with the self-testing kits you have ordered from Rapid Health Test To send you Marketing Communications unless you have opted out of communications	Contract Legitimate Interest	For Medical Diagnosis as set out in Article 9(3)(h) GDPR	In line with BMA guidelines, we are required to keep your details on record for the foreseeable future. For Marketing Comms please see 2.2
Your name, email, telephone number and query details	Customer	To respond to requests for feedback, information and support from existing customers	Legitimate Interests	N/A	In line with BMA guidelines, we are required to keep your details on record for the foreseeable future.
Technical Data (as defined)	Customer	To monitor the effectiveness of the Site and Our Marketing Communications/ Non-Marketing Communications	Legitimate Interests	N/A	See our Cookie Consent Management Platform
Your name, email address	Potential Customer	To provide you with Marketing Communications	Consent	N/A	As long as you are either subscribed to our email marketing platform or on our suppression list. See 2.2 for more information.
Financial/ Accounting Transactions	Customer	To record sales/ purchases made in the business	Legal/ Statutory Obligation	N/A	6 years from the end of the relevant tax year

1.2 We are a growing business and We do want to be of value to You during Our relationship so if We ever require further PD from You or if We would like to use Your PD for a different purpose, then We will always provide You with additional information about this at the point that You are invited to make use of these additional services.

1.3 OUR RETENTION RIGHTS: How long We keep Your PD depends on the context in which You provide it and the purpose for which We use it. See the last column in the table above. Do note that We need to retain sufficient information about You in compliance with certain legal or statutory requirements, for example, in the event of a legal or insurance claim in the future so that We can identify You.

1.4 Where We state that We rely on consent to process Your PD for a particular purpose, You have the right to withdraw Your consent at any time. This will not affect the lawfulness of processing carried out by Us which was based on consent before its withdrawal.

1.5 TECHNICAL DATA WE MAY PROCESS WHEN YOU USE OUR SERVICES: This typically relates to Technical Data involving the use of cookies and other technologies. This data is typically processed via the use of first party cookies, or third party cookies (e.g. where We use third party services by way of plugins or other software licensed to Us by a third party e.g. analytics related to the use of Our own Site OR cookies set by operators of a third party service such as social media and file sharing networks e.g. Twitter and Facebook). The types of data obtained about You may include Your e.g. visits to the Site; page views, downloads, navigation and exit; IP address; geographical location; browser type and version; operating system; referral source; length of Your visit (‘Technical Data’). This enables Your online activity to be tracked and for advertisements to be targeted to You (subject to Your cookie consent management preference settings). To learn more, please see Our Cookie Policy.

2. HOW DO WE USE YOUR PERSONAL DATA TO COMMUNICATE WITH YOU?

2.1 NON-MARKETING COMMUNICATIONS: You acknowledge that, Your PD may be used by Us (or a Service Provider on Our behalf) to contact You when necessary in connection with Your use of the Site and to access Our Services as follows:

Non-Marketing Communication	Method of receipt	Lawful Basis for general processing as set out in Article 6 GDPR
Confirmation of Purchase, product despatch.	email, text	Contract
Requests for information	telephone, email, text, LiveChat	Contract
Results of testing.	telephone, email, text, LiveChat	Contract

2.2 MARKETING COMMUNICATIONS: From time to time and with Your lawful (express or implied) permission, We may send you Marketing Communications (and monitor whether You have opened the communication and clicked on any included links which will enable Us to understand Your level of engagement/ interest in the communication We are sending to You).

Marketing Communication	Method of receipt	Lawful Basis for general processing as set out in Article 6 GDPR	How can you opt out?
newsletter with/ or information or offers regarding upcoming promotions, services or surveys	email	Consent for prospective customers or Legitimate Interest for Customers	You will be able to log in to Your account with at any time to amend Your preference. You can also amend Your preference by clicking on the link at the bottom of any email communication.

2.3 MARKETING COMMUNICATIONS FROM US : If You agree to receiving any of the above Marketing Communications but later change Your mind, You can opt out at any point, by amending Your account preferences on the Site. Alternatively, You can use the ‘unsubscribe’ link at the end of any electronic communication received by You or simply respond to Our prompt in all of Our communications to You. If you opt out of Our communications, We will retain Your PD on our suppression list so that We comply with Your wishes not to be contacted again.

2.4 LEGITIMATE INTERESTS TO PROCESS YOUR PERSONAL DATA: We may process PD about You where We rely on “legitimate interests” as Our lawful basis. Where this is the case, We will have carried out an assessment to determine that We have valid and lawful rights to do so. Despite this, if it bothers You, You have the right to object to any of the processing We undertake by completing Our Data Subject Rights Request Form.

2.5 PROFILING: We may from time to time use publicly available demographic information to determine who We target for specific events or marketing campaigns so as to avoid contacting individuals unnecessarily. You have the right not to be subject to a decision based solely on automatic processing (Article 22). We undertake profiling when You have visited Our Site or Facebook Page. Where this is a result of cookie activity, You can manage this via Your cookie preferences via Our Cookie Preference Management Tool.

2.6 RESEARCH & STATISTICS: We may use communications information to compile anonymous statistical reports showing information like the number and type of query and how each has been resolved. Occasionally We will use information provided to develop case studies for learning and development purposes. We will be very careful to ensure that any information that could re-identify a person is removed or changed to preserve anonymity.

2.7 OTHER WEBSITES OR APPLICATIONS & THEIR POLICIES: The Site may contain links to other websites or applications. We are not responsible for the privacy practices or policies or for the content of such websites or applications of such third parties, so You should be careful to read and understand those policies independently.

►Social media plugins: On Our Site, We have included social media plugins that You can use to share certain content over social networks. To protect Your privacy, We offer You these social plugins as so-called “2-click buttons.” The “2-click solution” prevents data (e.g. Your IP address) from being transmitted to social networks such as Facebook or Twitter as soon as You open Our Site. For this purpose, the buttons are deactivated by default and are only activated by clicking the social plugins for the first time. After activation, the plugins also collect PD such as Your IP address and send it to the servers of the respective provider where it is stored. In addition, activated social plugins set a cookie with a unique identifier when loading the relevant website. This also allows providers to create profiles of Your usage behaviour. The data will be used to show You personalised advertising, as well as for market and opinion research purposes. PD transfer is independent of whether You have an account with the plugin provider and are logged in there. If You are logged in with the plugin provider, Your data collected with Us will be assigned to Your existing account with the plugin provider. We have no exact information about the concrete use of the data nor about the storage period. Please read the privacy policy of the respective providers. We have integrated the plugins of the following providers on Our Site:

· Facebook (Facebook Inc., USA, Data protection declaration: https://www.facebook.com/policy.php)

· Twitter (Twitter Inc., USA; Data protection declaration: https://twitter.com/privacy/)

· Pinterest (Pinterest Inc., USA; Data protection declaration: https://de.about.pinterest.com/privacy/)

· Instagram (Instagram Inc., USA Data protection declaration; https://help.instagram.com/402411646841720

· LinkedIn (LinkedIn Ireland Unlimited Company; https://www.linkedin.com/legal/privacy-policy)

3. WHO HAS ACCESS TO YOUR DATA & WHERE IS IT STORED?

3.1 THIRD PARTIES:

We may engage or collaborate with a Third Party for a variety of different reasons. This may be in relation to the performance of Our business and daily operational functions on Our behalf to enable Us to fulfil Our Services only (including making improvements to Our Services). Where it is necessary to share Your PD, We will limit the PD that We share to the minimum required to provide the Service and the Data Processor (or Data Controller) will only be able to use it for the specific purposes for which it was shared. If We stop using the service of a Data Processor, We ensure Your PD is deleted or securely returned to Us.

From time to time, We may transfer Your PD to a related company, agent or contractor (also known as a Joint Data Controller) e.g. where We collaborate on a joint project together.

The last column relates to where the PD goes and what safeguards are in place in the recipient territory where it is transferred/ stored. It will be one or more of the following:

WHERE?	INFO AROUND SAFEGAURDS
United Kingdom	We may store some or all of the PD in the United Kingdom only. Should We need to transfer Your PD outside of the UK or EEA in the future, it will be in compliance with the GDPR requirements for external transfer and all details will be added to Our Statement.
Within the EEA	We may store some or all of the PD in the EEA. Should We need to transfer Your PD outside of the EEA in the future, it will be in compliance with the GDPR requirements for external transfer and all details will be added to Our Statement.
Outside EEA	We may store some or all of the PD in a country outside of the UK and EEA. We will not transfer Your PD to any Third Parties based in other countries outside the EEA unless there is a European Commission adequacy decision, Binding Corporate Rules or the EU Commission approved Standard Contractual Clauses are in place.

If You would like more information about any of the transfer safeguards We implement please contact Us using the details as set out at Clause 5 of this Statement.

What type of PD is shared with Third Parties by Us?	What is Our role? DC or DP	What is the Third Party’s specific name? OR category of Third Parties?	Third Party Role: JDC or IDC or DP	What is the Purpose of sharing the PD?	What Lawful Basis do We rely on to transfer the PD?	Where is the PD transferred to? What safeguards are in place?
All PD related to the purpose	DC	ReCoVa Platform	DP	Testing and organisation of samples. You will be invited to create an Account with ReCoVa who will process your details and provide the Lab with a Pseudonymised Test.	Contract	This Third Party is based in the UK and their website details are here.
All PD related to the purpose	DC	Public Health England	DC	Covid Test Results (both negative and positive) along with the relevant PD are required by law to be passed to PHE.	Legal Obligation	PHE are in the UK and we are legally obliged to share Covid test results with them. You can read their Privacy Notice here.
All PD related to the purpose	DC	Marketing Consultants	DP	Assisting with website, content, email and social media marketing	Contract	Our Marketing Consultants are based in the UK and we have a signed DPA
All PD related to the purpose	DC	Accountant	DC	accounting	Legal/ Statutory obligation	Our Accountant is based in the UK
All PD related to the purpose	DC	Payment Providers	DC	So that you are able to make payment on Our Platform. In order to take Your payment, Stripe and PayPal will collect Your PD according to their terms.	Contract	Stripe and PayPal are global companies with data centres in the US. Stripe relies on Standard Contractual Clauses at present to safeguard PD transfers. Please see their Privacy Notice for more information https://stripe.com/en-gb/privacy
All PD related to the purpose	DC	Legal Advisors & Legal Authorities/ Enforcement bodies	DC	to enforce the terms under which You transact or communicate with Us/ to assist law enforcement	Legal/ Statutory obligation & Contract	Our legal advisors are based in the UK/EU
All PD related to the purpose	DC	Google LLC https://drive.google.com/drive/	DP	To store documents in GoogleDrive	Contract	This third party is relying on Standard Contractual Clauses while We await further guidelines when We may transition to an alternative transfer mechanism Google Privacy Statement
All PD related to the purpose	DC	iRejuvenation	DP	To act as a CRM to store and process customer personal data	Contract	IIRejuvenation is based in the EU.
Name and email	DC	Get Repsonse Email Marketing Platform	DP	Direct electronic mailings & consent management including creation of suppression lists to ensure a Customer who objects to processing is excluded in the future.	Consent or Legitimate Interest	Get Response is located in the EU. You can read their privacy notice here.
Name, contact details and any other PD that is placed on Facebook by You and made accessible to Us	DC	FaceBook	JDC	So that the Data Subject can be a part of the Facebook Page community. More information can be found on Facebook here.	Consent Where You share Your own Special Category Data rely on the additional condition that the PD is manifestly made public (We are defining ‘public’ as in the Facebook Audience and this is in accordance with Facebook’s Ts & Cs) (Article 9(2)(e) GDPR)	This third party is relying on Standard Contractual Clauses while We await further guidelines when We may transition to an alternative transfer mechanism. Facebook Privacy Statement

3.2 Transfer of Personal Data in the Event of the Sale of Rapid Health Test or its Assets

In the event that Rapid Health Test is sold or transfers some of its assets to another party, Your PD could be one of the transferred assets. If Your PD is transferred, its use will remain subject to this Statement. Your PD will be passed on to a successor in the event of a liquidation or administration.

4. WHAT ARE YOUR RIGHTS UNDER DATA PROTECTION LEGISLATION?

4.1 You have a number of rights that You can exercise free of charge and on request in certain circumstances, however, if Your requests are obviously unfounded or excessive, We reserve the right to charge a reasonable fee or to refuse to act. You have the right:

· to be informed about the collection and use of Your PD. This is what this Statement fulfils;

· to access Your PD and supplementary information (‘DSAR’);

· to have inaccurate PD corrected, or completed (if it is incomplete);

· to have Your PD erased;

· to restrict Our processing of Your PD;

· to receive a copy of any PD You have provided to Us, in a machine-readable format, or have this information ported to a third party;

· to object AT ANY TIME to processing of Your PD for direct marketing purposes;

· to object in certain other situations to the continued processing of Your PD.

For more information on these rights and when you can exercise them, see the Information Commissioner’s Guide

4.2 If You wish to exercise any of these rights, please complete Our Data Subject Rights Request Form. We will respond to You within one month from when We receive Your request, unless the complexity and number of requests We receive means that we need more time. If We do need more time (up to two further months), We will tell You why within the first month.

5. HOW CAN YOU SUBMIT A QUERY OR A COMPLAINT?

QUERY: We are happy to provide any additional information or explanation needed in respect of Our processing activities upon request. For all matters relating to privacy and data protection, please contact us at [email protected].

COMPLAINT: We try to meet the highest standards when processing Your PD. For this reason, We take any complaints We receive about this very seriously and We encourage You to bring it to Our attention. While We hope to be able to resolve any concerns You have about the way that We are processing Your PD, You have the right to lodge a complaint with the Information Commissioner’s Office (ICO) (or with the supervisory authority of the European Member State where You work, normally live or where the alleged infringement of data protection laws occurred) if You believe that Your PD has been processed in a way that does not comply with the Data Protection Legislation or have any wider concerns about Our compliance. You can do so by calling the ICO helpline on 0303 123 1113 or via their website here.

6. DO WE USE COOKIES?

For information about cookies and how they are used on the Site, please visit Our Cookie Consent Preference Management Centre accompanied by Our Cookie Policy.

7. CHANGES TO THIS STATEMENT

We keep Our Statement under regular review. This Statement was last updated on 17 November 2020.

8. DEFINITIONS & INTERPRETATIONS

Data Processor or DP: means a natural or legal person, public authority, agency or other body which processes PD on behalf of the Data Controller (Article 4(8));Data Controller or DC or JDC or IDC: means the natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of PD (Article 4(7));

Data Protection Legislation: means, as applicable to either Party:

(a) the General Data Protection Regulation 27 April 2016;

(b) the Data Protection Act 2018;

(d) any other applicable law relating to the processing, privacy and/or use of PD, as applicable;

(e) any laws which implement any such laws; and,

(f) any laws that replace, extend, re-enact, consolidate or amend any of the foregoing.

Data Subject Access Request or ‘DSAR’: refers to right of access as further described in Clause 4.

EEA: refers to the European Economic Area which consists of all EU member states, plus Norway, Iceland, Liechtenstein.

Electronic Mail: includes but is not limited to email, text, video, voicemail, picture and answerphone messages (including push notifications).

General Data Protection Regulation or GDPR: the General Data Protection Regulation ((EU) 2016/679). PD is subject to the legal safeguards specified in the Data Protection Legislation including the GDPR.

Marketing Communication(s): refers to any communication whether by an Electronic Mail method or otherwise that We send to You (either directly or via a Service Provider) which may include but are not necessarily limited to relevant newsletters and magazines, information about opportunities, products, services and events and relevant information.

Non-Marketing Communication(s): refers to any communication which is functional/ administrative only as distinct from Marketing Communications.

Personal Data or PD: has the meaning set out in the Data Protection Legislation and shall include Special Category Data (as applicable).

Service Provider(s): refers to a Third Party with whom We work with from time to time as a necessary part of providing Our Services and with whom We may need to share Your PD.

Services: refers to Our Services We may provide to You.

Special Category Data: has the meaning set out in the Data Protection Legislation.

Technical Data: refers to that at Clause 1.5 which is capable of being considered PD.

Third Party: refers to a Data Processor or Data Controller with whom We may need to share Your PD. This includes Service Providers.

Contains public sector information from https://ico.org.uk licensed under the Open Government Licence v3.0 [[https://www.nationalarchives.gov.uk/doc/open-government-licence/version/3/]].

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