Last Updated: 11th November 2024

 

Please read this privacy notice (‘Notice’) to understand how Millbrook Healthcare Group Ltd looks after your Personal Data.

 

We have set this Notice out in a layered format so you can click quickly navigate to the specific areas set out below.

 

1 – WHO WE ARE AND WHAT THIS PRIVACY NOTICE COVERS

 

What This Privacy Notice Covers

 

This notice covers how we process your Personal Data when you use our website.

 

If you would like to understand how we process your personal data as a customer of one of our services, please click the relevant link below:

 

 

Who Are we?

 

We are Millbrook Healthcare Group (MHC). We provide health related services on behalf of NHS Trusts, local authorities and social services. Our registered office is at Nutsey Lane, Calmore Industrial Estate, Totton, Southampton, Hampshire, SO40 3XJ. MHC group is both a Controller and Processor of your data and is responsible for keeping your data safe (collectively referred to as “MHC”, “we”, “us” or “our” in this privacy policy).

 

Our data protection officer (DPO) is responsible for overseeing questions in relation to this privacy notice. If you have any questions about this privacy policy, including any requests to exercise rights, please email [email protected].

 

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). It’s our priority to ensure you are satisfied with our data processing practices. If you do find you have a complaint, we would appreciate the chance to try and resolve any issues you have before you approach the ICO.

 

2 – PERSONAL DATA WE COLLECT ABOUT YOU

 

We collect various types of data from you which can be grouped broadly as follows:

 

  • Identity Data: includes your first name, last name, address.
  • Contact Information: includes your email and contact number.
  • Payment Information: includes your payment details and transaction information for your purchases.
  • Feedback information: includes any feedback you provide us.
  • Profile Data: includes your username, password, and purchases. 
  • VAT Exemption Health Data: includes any health data you provide us for your VAT exemption.
  • Technical Data: includes your operating system type, web browser type, Internet Protocol (IP) address, device type, time zone, geo location and browser plug-in types and version that you provide to us when you visit our website
  • Usage Data: includes information about how you interact and navigate through our website. This includes information such as which links you have clicked on, which pages or content you have viewed, whether you have opened our email, and other similar information and statistics.

 

3 – HOW WE COLLECT YOUR PERSONAL DATA

 

We use different methods to collect data from and about you including through:

 

– Direct interactions: We collect your Identity, Contact, Payment, Feedback, and Profile information when you:

  • make a purchase on our website;
  • create an account on our website;
  • contact us via our website contact form;
  • send us feedback via our website.

 

– Website Interactions: We automatically collect your Technical and Usage when you:

  • land on our website and accept our cookies.
  • interact with different pages and elements our website;

 

Some of this information is captured using cookies, log files, and pixels. For further information about how these technologies work, please see Section 5. 

 

External Sources: We receive some of your Technical and Usage Data from third parties such as Google, Facebook and Bing which we use to for website analytics and to deliver online advertising to you. Please see Section 5 for more details.

 

4 – HOW WE USE YOUR PERSONAL DATA

 

The table below explains how we use your data and the lawful basis relied on to use your data.

 

How we use your Personal Data

Type of data

Lawful basis

To process your purchase of goods from our web store.

(a) Identity

(b) Contact

(c) Payment

(d) Profile

(a) Performance of a contract with you*

We and our payment processing provider(s) handle payment and financial information in a manner compliant with applicable laws, regulations and security standards such as PCI DSS.

To delivery your purchased goods to your address.

(a) Identity

(b) Contact

(a) Performance of a contract with you*

To respond to any enquiries you send us via our contact form.

(a) Identity

(b) Contact

(c) Call

(a) Necessary for our legitimate interests (to provide quality service to our customers and improve our business services)

To respond to any feedback you provide us when you include your contact information. We use your feedback to improve our service.

(a) Identity

(b) Contact

(a) Necessary for our legitimate interests (to improve the quality of our service)

To process your VAT exemption (where applicable) which includes sharing your data with HMRC (where applicable) to demonstrate your VAT exemption.

(a) Identity

(b) Health

(a) Performance of a contract with you

(b) Explicit Consent

To record calls you make to our customer service team. We record customer service calls for staff training and quality assurance purposes.

(a) Identity

(b) Call

(a) Necessary for our legitimate interests (to ensure quality customers service, staff training purposes, and as a record of our conversation)

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

(a) All Data Categories

(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 and measure the effectiveness of our marketing strategy which includes:

  • delivering relevant advertisements to you
  • understanding how you engage and interact with our website and advertisements to better improve the effectiveness of the advertising we serve to you and to optimise customer website experience

(a) Usage

(b) Technical

(a) Consent (we rely on your consent to place any non-essential cookies on your browser)

(b) Necessary for our legitimate interests (to inform and improve the effectiveness of our customer engagement strategy)

In the event Millbrook Healthcare Group Ltd or its assets are acquired by or merged with another company including through bankruptcy, we will share your Personal Data with any of our legal successors.

We will also disclose your Personal Data to third parties:

(a) when required by applicable law;

(b) in response to legal proceedings;

(c) in response to a request from a competent law enforcement agency;

(d) to protect our rights, privacy, safety or property, or the public; or

(e) to enforce the terms of any agreement or the terms of our Website.

(a) All data categories

(a) Necessary to comply with a legal obligation

(b) Necessary for our legitimate interests (to protect our assets and staff)

*If you fail to provide the data necessary for us to enter into a contract with you, we may not be able to provide you our services. We will notify you of this at the time if this is the case.

 

5 – AUTOMATED TECHNOLOGIES

 

We collect some of your data via automated technologies which is broken down into the following categories:

 

Cookies. A cookie is a small text file that is stored on your browser that collects your Technical and Usage data. You can set your browser to refuse all or some cookies that websites would like to store on your browser. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly.

 

Log Files. We collect information in the form of log files that record website activity and gather statistics about your browsing habits. These entries are generated automatically, and help us to troubleshoot errors, improve performance and maintain the security of our website.

 

Web Beacons. Web beacons (also known as “web bugs”) are small strings of code that deliver a graphic image on a web page or in an email for the purpose of transferring data back to us. The information collected via web beacons will include information such as IP Address, as well as information about how you respond to an email campaign (e.g. at what time the email was opened, which links you click on in the email, etc.). We use web beacon information for a variety of purposes, including but not limited to, site traffic reporting, unique visitor counts, advertising, email auditing and reporting, and personalisation.

 

For more information on these automated technologies, please read our cookie policy.

 

6 – DISCLOSURES OF YOUR PERSONAL DATA

 

We share your Personal Data with the following categories of third-party providers to deliver our services:

 

Services Providers:

These are external companies that we use to help us run our day-to-day service function which includes order fulfilment providers, payment processing providers, fraud detection and identity verification providers, website operation and hosting providers, customer relationship management providers and IT system administration providers.

 

Professional Service Advisers:

These are professional service advisers who help us meet our legal and regulatory compliance requirements which include auditors (financial and cyber security), legal practitioners, banks and insurers.

 

Ad Network Providers:

These are external providers we use to help us deliver online ads to you and ananlyse our website traffic. Ad network provides include Google, Facebook and Bing.

 

Under Our Instruction. All providers, and their selected staff, are only allowed to access and use your Personal Data on our behalf for the specific tasks that they’ve been requested to carry out, based on our instructions, and are required to keep your Personal Data confidential and secure.

 

The only exception is if we are required by law to disclose your Personal Data such as to HMRC for auditing purposes.

 

No sale of personal information to third parties.

We do not and will not sell your Personal Data to third parties in any situation unless it is within the context of a merger and acquisition.

 

7 – INTERNATIONAL TRANSFERS

 

We do not transfer any of your data outside of the UK. All service user data is stored securely on our private cloud storage hosted in the UK.

 

8 – DATA SECURITY

 

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties on a need-to-know basis only. They will only process your personal data on our instructions and are subject to a duty of confidentiality.

 

9 – DATA RETENTION

 

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties on a need-to-know basis only. They will only process your personal data on our instructions and are subject to a duty of confidentiality.

 

Our retention periods are maintained in-line with the NHS Records Management Code of Practice and any applicable legal, regulatory, tax, accounting or other statutory requirements we are required to meet.

 

10 – YOUR LEGAL RIGHTS

 

Under certain circumstances, you have the following rights in relation to your Personal Data:

 

Request access to 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.

 

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 Personal Data. 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.

 

Object to processing of your Personal Data where we are relying on legitimate interests (or those of a third party) and there is something about your particular 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 Personal Data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.

 

Request restriction of processing of your Personal Data. This enables you to ask us to suspend the processing of your Personal Data in the following scenarios:

  • If you want us to establish the data’s accuracy.
  • Where our use of the data is unlawful but you do not want us to erase it.
  • Where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims.
  • You have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.

 

Request the transfer of your Personal Data to you or to a third party. We will provide to you, or a third party you have chosen, your Personal 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 Personal 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 you our services and may need to end the contract between us. We will advise you if this is the case at the time you withdraw your consent.

If you wish to exercise any of the rights set out above, please contact us at: [email protected]

 

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.

 

11 – COMPLAINTS

 

The complaints team are available to assist you with any comments, concerns and complaints. The team act independently of any of the services we provide ensuring your concerns are thoroughly investigated and responded to in a timely manner. If you wish to make a complaint or provide feedback, please contact us at: [email protected]

Do I qualify for VAT Exemption?

If you are disabled or have a long-term illness, you won’t be charged VAT on products designed or adapted for your own personal or domestic use.

 

If you are entitled to a VAT exemption, you can register for this at checkout. The VAT will then be removed form your total. If you are unsure whether you are entitled or not, please read our VAT Exemption Terms & Conditions.