Barrie Dear Limited (“Dears Pharmacy”, “we”, “us”, “our” ) are committed to protecting and respecting your privacy. This policy (together with our Terms of Website Use and any other documents referred to on it) sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us. Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it.  For the purpose of the UK General Data Protection Regulation (“UK GDPR”) the data controller is Dears Pharmacy, 645 Ferry Road, Edinburgh, EH4 2TX. We are registered as a data controller with the Information Commissioner’s Office and our registration number is ZA355491.

INFORMATION WE MAY COLLECT FROM YOU

We may collect and process the following data about you:

• Information that you provide by filling in forms on our site www.dearspharmacy.co.uk (our site). This includes information provided at the time of registering to acquire goods on our site, or requesting further services. We may also ask you for information when you report a problem with our site.
• If you contact us, we may keep a record of that correspondence.
• We may also ask you to complete surveys that we use for research purposes, although you do not have to respond to them.
• Details of transactions you carry out through our site and of the fulfilment of your orders.
• Details of your visits to our site including, but not limited to, traffic data, location data, weblogs and other communication data, whether this is required for our own billing purposes or otherwise and the resources that you access.
• Your marketing and communications preferences.

HOW INFORMATION IS COLLECTED

The information we hold will either have been provided directly by you (e.g. as you interact with us) or be collected by automated technologies as you interact with our website. As you interact with our website, we will automatically collect technical data about your browsing actions and patterns. We may collect information about your computer, including where available your IP address, operating system and browser type, for system administration and to report aggregate information to our advertisers. This is statistical data about our users’ browsing actions and patterns, and does not identify any individual. We collect this personal data by using cookies and other similar technologies. Please see our cookie policy for further details.

PURPOSE FOR PROCESSING

We have set out below a description of all the ways we plan to use your information, and which the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate. We may process your information for more than one lawful ground depending on the specific purpose for which we are using your information.

SHARING PERSONAL INFORMATION

We may use your data, or permit selected third parties to use your data, to provide you with information about goods and services which may be of interest to you and we or they may contact you about these by post or telephone. We will only contact you by electronic means (e-mail or SMS) with information about goods and services similar to those which were the subject of a previous sale to you. Where we permit selected third parties to use your data, we (or they) will contact you by electronic means only if you have consented to this. If you do not want us to use your data in this way, or to pass your details on to third parties for marketing purposes, please contact us through our Contact us page available by clicking here. We do not disclose information about identifiable individuals, but we may provide them with aggregate information about our users (for example, we may inform them that 500 men aged under 30 have clicked on their advertisement on any given day). We may also use such aggregate information to help advertisers reach the kind of audience they want to target (for example, women in SW1). We may make use of the personal data we have collected from you to enable us to comply with our advertisers’ wishes by displaying their advertisement to that target audience.

Our relationships with third party service providers are governed by contractual provisions with us and they only have access to personal information to perform the described purposes and may not use it for other purposes.

WHERE WE STORE YOUR PERSONAL DATA

The personal information that we collect is stored within the UK and European Economic Area (EEA). However, there may be some circumstances where it is necessary to transfer and store personal information at a destination outside the EEA. It may also be processed by staff operating outside the UK and EEA who work for us or for one of our suppliers. Such staff maybe engaged in, among other things, the fulfilment of your order, the processing of your payment details and the provision of support services. By submitting your personal data, you agree to this transfer, storing or processing. We will take all steps reasonably necessary to ensure that your data treated in accordance with and subject to the requirements of the UK GDPR. All information you provide to us is stored on our secure servers. Any payment transactions will be encrypted using SSL technology. Where we have given you (or where you have chosen) a password which enables you to access certain parts of our site, you are responsible for keeping this password confidential. We ask you not to share a password with anyone. Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our site; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access.

HOW LONG WE KEEP IT FOR

We will only retain personal information 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.

DISCLOSURE OF YOUR INFORMATION

We may disclose your personal information to any member of our group, which means our subsidiaries, our ultimate holding company and its subsidiaries, as defined in section 1159 of the UK Companies Act 2006. We may disclose your personal information to third parties

In the event that we sell or buy any business or assets, in which case we may disclose your personal data to the prospective seller or buyer of such business or assets.

• If Dears Pharmacy or substantially all of its assets are acquired by a third party, in which case personal data held by it about its customers will be one of the transferred assets.
• If we are under a duty to disclose or share your personal data in order to comply with any legal obligation, or in order to enforce or apply our Terms of Website Use and other agreements; or
• to protect the rights, property, or safety of Dears Pharmacy, our customers, or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction

YOUR RIGHTS

Under the UK GDPR and Data Protection Act 2018, you have the following rights:

• Right of access – You have the right of access to information we hold about or concerning you.
• Right of rectification or erasure – If you feel that any data that we hold about you is inaccurate you have the right to ask us to correct or rectify it.  You also have a right to ask us to erase information about you where you can demonstrate that the data we hold is no longer needed by us, or if you withdraw the consent upon which our processing is based, or if you feel that we are unlawfully processing your data.
• Right to restriction of processing – In certain circumstances, you have a right to request that we refrain from processing your data.
• Right of portability – In certain circumstances, you have a right to receive any personal data that you have provided to us in order to transfer it onto another data controller.
• Right to object – In certain circumstances, you have a right to object to our processing of your personal data.
• Right to withdraw consent -In the circumstances where you may have provided consent to the collection, processing, and transfer of personal information for a specific purpose has been provided, you have the right to withdraw consent for that specific processing at any time.

To exercise any of these rights, please contact Dears Pharmacy’s Data Protection Officer using the contact details below.

info@dearspharmacy.co.uk

Our site may, from time to time, contain links to and from the websites of our partner networks, advertisers and affiliates. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies. Please check these policies before you submit any personal data to these websites.

CHANGES TO OUR PRIVACY POLICY

Any changes we may make to our privacy policy in the future will be posted on this page. This privacy policy was last updated in November 2022.

CONTACT

Questions, comments, and requests regarding this privacy notice are welcomed and should be provided through our ABOUT page.

If you have a concern about the way we are collecting or using personal information, we would ask that you raise your concern with us in the first instance by using the contact details above.

You also have a right to lodge a complaint with the Information Commissioner’s Office (ICO) should you feel that we have not handled your information in line with legislative and regulatory requirements. They can be contacted at:

The Information Commissioner’s Office – Scotland
Queen Elizabeth House
Sibbald Walk
Edinburgh
EH8 8FT

Telephone: 0303 123 1115

Email: Scotland@ico.org.uk

or

Information Commissioner’s Office
Wycliffe House
Water Lane
Wilmslow
Cheshire
SK9 5AF
Telephone: 0303 123 1113

Website: www.ico.org.uk

DEARS PLUS MEMBERSHIP

Information we may collect from you

If you purchase or use a Dears Plus membership, we may also collect and process membership-related information, including:

• your name;
• email address;
• telephone number;
• billing details;
• Membership ID;
• order or payment reference;
• membership start date;
• membership expiry date;
• membership status;
• records of membership benefits used;
• records of included clinical services used, such as Dears Ear and Heart Check Scotland appointments, and the date and pharmacy location of each;
• relevant notes needed to administer the Membership.

We may use this information to manage your Membership, verify your entitlement to benefits, record the use of included services, prevent misuse, manage refunds or cancellations, and respond to membership-related queries.

Information about your health

Some membership information tells us something about your health. A record that you have used an included Dears Ear or Heart Check Scotland appointment is information about your health, as are the records we create when we provide that service to you.

Information about your health is “special category” data under the UK GDPR and is given additional protection. We only process it where, in addition to a lawful basis under Article 6, one of the further conditions in Article 9 applies.

We rely on Article 9(2)(h) of the UK GDPR — processing necessary for the provision of health care or treatment and the management of health care systems and services — together with the condition at paragraph 2 of Schedule 1 to the Data Protection Act 2018. This processing is carried out by, or under the responsibility of, professionals subject to a duty of confidentiality. We maintain an appropriate policy document explaining how we comply with the data protection principles when processing this information, and how long we retain it.

Purpose for processing

We may process membership information for the following purposes:

Membership service messages are different from marketing messages. Service messages are the messages we have to send you to administer your Membership — for example, your confirmation email and Membership ID, changes to your Membership, appointment arrangements, and messages about refunds, cancellations or administrative issues. We will send you these even if you have not opted into marketing, because we need to send them in order to provide the Membership you have bought.

Renewal reminders and membership offers are different. These invite you to buy from us again and we treat them as marketing. We may send them to you by email as an existing customer, but you can tell us to stop at any time, using the unsubscribe link in any message or by contacting us. We will not send them if you have told us you do not want them.

Sharing personal information

Add under “Sharing Personal Information” / “Disclosure of Your Information”.

Membership information may be accessed by authorised Dears Pharmacy staff and branches where necessary to verify membership status and apply membership benefits. Access to information about your health is limited to those who need it to provide or administer the service in question.

We use trusted service providers to help us operate the Membership — for example to host our systems, send transactional emails, maintain records, provide technical support or manage customer communications. Where these providers act on our instructions, they act as our processors: they may only use your personal information for the purposes we instruct, must handle it securely, and are bound by a written contract with us.

Our payment provider, Stripe, is different. Stripe processes your payment on our instructions, but it also uses payment and device information for its own purposes, including fraud prevention, payment security and meeting its own legal and regulatory obligations. For those purposes Stripe decides how and why your information is used, and acts as an independent controller rather than as our processor. Stripe’s own privacy policy explains how it handles your information.

Where we store your personal data

Membership information may be stored in our website systems, payment systems, email systems and secure internal records, including the Live Membership Register.

Access to membership records is limited to authorised staff who need the information to administer the Membership, verify benefits or support customers. Clinical records created when you use an included service are held in our clinical record systems and are subject to our clinical record-keeping and confidentiality obligations.

Some of our service providers store or process personal information outside the United Kingdom. Where they do, we make sure appropriate safeguards are in place, either because the country has been found by the UK Government to provide an adequate level of protection, or by using the International Data Transfer Agreement or the UK Addendum to the European Commission’s standard contractual clauses. You can ask us for details of the safeguards we use.

How long we keep it for

We keep membership information for the following periods:

At the end of these periods we securely delete or anonymise the information. We will not keep membership information for longer than necessary.

Your rights

You may ask us to access, correct or delete membership information we hold about you, and you may object to or ask us to restrict certain processing. Where we rely on our legitimate interests, you can object at any time, and you can ask us to stop sending you renewal reminders and membership offers at any time.

Some of these rights are qualified. We may need to keep certain information despite a request to delete it — for example transaction, membership or service redemption records that we are required to keep for audit, accounting, complaint handling, fraud prevention, clinical record-keeping or legal purposes. Where we cannot meet a request in full, we will explain why.

If you are unhappy with how we have handled your personal information you can complain to the Information Commissioner’s Office at ico.org.uk, although we would ask you to contact us first so that we have the chance to put things right.

Contact

Questions about membership data or privacy, and any request to exercise your rights, can be sent to:

info@dearspharmacy.co.uk

Membership administration queries can be sent to:

services@dearspharmacy.co.uk