Under data protection laws, we are required to provide you with certain information about who we are, how we process your personal data and for what purposes, and your rights in relation to your personal data. This information is provided in this policy and it is important that you read that information.
Before installation of this App, please indicate your consent to our processing of your personal data (including your name, contact details, financial and device information) as described in the policy.
YES I consent to the installation of the App for the purposes of booking and receiving virtual medical consultation via video conference call.
NO I do not consent to the installation of the App.
Once you provide consent by selecting "YES", you may change your mind and withdraw consent at any time by contacting us at Admin@countymedical.co.uk but that will not affect the lawfulness of any processing carried out before you withdraw your consent.
YES I consent to processing of my Location Data ([including details of my current location disclosed by GPS technology so that location-enabled Services are activated to assist with locating a nearby consultant).
NO I do not consent to processing of my Location Data and location-enabled Services are disabled in my settings.
This policy (together with our end-user licence agreement as set out at Licance Terms and Conditions (EULA) and any additional terms of use incorporated by reference into the EULA, together our Terms of Use) applies to your use of:
This policy is provided in a layered format so you can click through to the specific areas set out below.
County Medical Services Limited (Company No. 13733150) is the controller and is responsible for your personal data (collectively referred to as “County Medical”, "we, "us" or "our" in this policy).
We have appointed a data protection officer. who is responsible for overseeing questions in relation to this privacy policy. If you have any questions about this privacy policy, please contact the data privacy officer using the details set out below.
If you have any questions about this privacy policy, please contact them using the details set out below. Our full details are:
We keep our privacy policy under regular review. Historic versions can be obtained by contacting us.
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 our relationship with you.
Our App may link with third-party websites, plug-ins and applications. 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. When you leave our App, we encourage you to read the privacy policy of every website you visit.
We may collect, use, store and transfer different kinds of personal data about you as follows:
We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. 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. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific App feature. 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.
Under the GDPR there is some personal information that is so sensitive that it gets extra protection this is known as special categories of personal data. As we provide medical services we do collect special categories of personal data this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, information about your health (including your medical history), and genetic and biometric data.
When we are using special categories of personal data we must also meet certain conditions.
We have set out further below under the heading special categories of personal data which sets out the conditions we are relying on when we use your personal information.
We process special categories of personal data for the following purposes:
Where we need to collect personal data by law, or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with services).
We will collect and process the following data about you:
We will only use your personal data when the law allows us to do so. Most commonly we will use your personal data in the following circumstances:
Outlined below is more about the types of lawful basis that we will rely on to process your personal data.
Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.
Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.
Comply with a legal obligation means processing your personal data where it is necessary for compliance with a legal obligation that we are subject to.
Generally, we do not rely on consent as a legal basis for processing your personal data although we will get your consent before sending third party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us.
We will get your express opt-in consent before we share your personal data with any third party for marketing purposes.
| Purpose/activity | Type of data | Lawful basis for processing |
|---|---|---|
| To install the App and register you as a new App user | Identity Contact Financial Device |
Your consent |
| To process in-App purchases and deliver Services including managing payments and collecting money owed to us | Identity Contact Financial Transaction Device Marketing and Communications Location |
Your consent Performance of a contract with you Necessary for our legitimate interests (to recover debts due to us) |
| To manage our relationship with you including notifying you of changes to the App or any Services | Identity Contact Financial Profile Marketing and Communications |
Your consent Performance of a contract with you Necessary for our legitimate interests (to keep records updated and to analyse how customers use our products/Services) Necessary to comply with legal obligations (to inform you of any changes to our terms and conditions) |
| To administer and protect our business and this App including troubleshooting, data analysis and system testing | Identity Contact Device |
Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security) |
We can Process special categories of personal data only if we have a legal ground for processing and one of the specific processing conditions relating to special categories of personal data applies. We will identify and document the legal ground and specific processing condition relied on for each processing activity.
When collecting special categories of personal data from Data Subjects, either directly from Data Subjects or indirectly (for example from a third party or publicly available source), we will provide Data Subjects with a Privacy Notice setting out all the information required by the UK GDPR in a privacy notice which is concise, transparent, intelligible, easily accessible and in clear plain language which can be easily understood.
| Purpose/activity | Lawful Processing basis | Processing condition for Special Categories of Personal Data |
|---|---|---|
| To provide you with our services. |
Data concerning health
Compliance with a legal obligation (Article 6 (1)(c)) or necessary for the performance of a contract with the Data Subject (Article 6(1)(b)). |
Necessary for the purposes of performing or exercising obligations or rights which are imposed or conferred by law on us. |
| To comply with a legal obligation, like a court order requiring us to release information. |
Data concerning health
Compliance with a legal obligation (Article 6 (1)(c)). |
Necessary for the purposes of performing or exercising obligations or rights which are imposed or conferred by law on us. |
| To deal with disputes and legal claims against us or our agents. |
Data concerning health
Compliance with a legal obligation (Article 6 (1)(c)) or legitimate interests (we have a legitimate interest in being able to deal with disputes and legal claims) (Article 6(1)(f)). |
Necessary for the purposes of performing or exercising obligations or rights which are imposed or conferred by law on us. |
| To provide information to healthcare bodies. |
Data concerning health
Compliance with a legal obligation (Article 6 (1)(c)) or necessary for the performance of a task carried out in the public interest (Article 6(1)(e)). |
Necessary for the purposes of performing or exercising obligations or rights which are imposed or conferred by law on us. |
| To let you know more about the services that we offer. |
Data concerning health
Compliance with a legal obligation (Article 6 (1)(c)) or necessary for the performance of a task carried out in the public interest (Article 6(1)(e)). |
Necessary for the purposes of performing or exercising obligations or rights which are imposed or conferred by law on us. |
| To co-operate with regulators, like the CQC. |
Data concerning health
Compliance with a legal obligation (Article 6 (1)(c)) or necessary for the performance of a task carried out in the public interest (Article 6(1)(e)). |
Necessary for the purposes of performing or exercising obligations or rights which are imposed or conferred by law on us. |
| To provide pharmacies and other consultants when issuing prescriptions. |
Data concerning health
Compliance with a legal obligation (Article 6 (1)(c)) or necessary for the performance of a task carried out in the public interest (Article 6(1)(e)). |
Necessary for the purposes of performing or exercising obligations or rights which are imposed or conferred by law on us. |
We use cookies and/or other tracking technologies to distinguish you from other users of the App, the distribution platform (Appstore) and to remember your preferences. This helps us to provide you with a good experience when you use the App and also allows us to improve the App. For detailed information on the cookies we use, the purposes for which we use them and how you can exercise your choices regarding our use of your cookies, see our Cookie Policy.
We may share your personal data with the parties set out below for the purposes set out in the table above.
We do not transfer your personal data outside the UK or the European Economic Area (EEA).
We are responsible for, and able to demonstrate compliance with these principles. Our data protection officer is responsible for ensuring that we are compliant with these principles.
We will:
All information you provide to us is stored on our secure servers. Any payment transactions carried out by us or our chosen third-party provider of payment processing services will be encrypted. Where we have given you (or where you have chosen) a password that enables you to access certain parts of Our App, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.
Once we have received your information, we will use strict procedures and security features to try to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way.
We will collect and store personal data on your Device using and other technology.
We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator when we are legally required to do so.
We take the security of special categories of personal data very seriously. We have administrative, physical and technical safeguards in place to protect personal data against unlawful or unauthorised processing, or accidental loss or damage. We will ensure, where special categories of personal data is processed that:
We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, insurance, 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.
By law we have to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for eight years after they cease being customers for. We are also required to keep any medical records for a minimum of eight years after you cease being a customer.
In some circumstances you can ask us to delete your data: see Your legal rights below for further information.
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 the event that you do not use the App for a period of one year then we will treat the account as expired and your personal data may be deleted.
Under certain circumstances you have the following rights under data protection laws in relation to your personal data.
You have the right to:
If you wish to exercise any of the rights set out above, please contact us.
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.
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.
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.