This Privacy Policy sets out the terms upon which Fox Pharma Ltd (We/Us) processes your personal information through your use of this platform, JECT, and any data you may provide if you contact us regarding our services or the JECT platform.
We take the protection of your personal data very seriously and strictly adhere to the rules laid out by data protection laws and the General Data Protection Regulation (GDPR-EU and GDPR-UK)
We collect your personal data for one of the following purposes:
Where legitimate interest is identified as a lawful basis, we will undertake a legitimate interest assessment which is a three-part test covering:
The purpose test - to identify the legitimate interest
Necessity test - to consider if the processing is necessary for the purpose identified
Balancing test - considering the individual's interests, rights or freedoms and whether these override the legitimate interests identified.
We only collect and use personal information about you when the law allows us to. Most commonly, we use it where:
We collect personal information from you, for example, if you register to our website, add your details, request information, call us or use any of our services. The categories of personal information that we may collect, store and use about you include:
We also collect your data through our JECT platform, via the clinics themselves. They may add personal data pertaining to you on the platform. Please refer to their privacy notice for further details on how the clinics process personal data.
When you collect personal data on behalf of a patient/client and then provide us with that information to forward the data to fulfil a prescription, you are making a declaration that the personal information you have collected and submitted to us has been carried out lawfully under the Data Protection Act 2018.
We pride ourselves on ensuring that your personal data is only retained for the period that we need it for, or in accordance with laws, regulations and professional obligations that we are subject to. All personal information collect has a defined retention period, which is in-line with our retention policy. If you would like to find out how long your information is being retained, please see "additional information", section 16 of this policy.
We take the responsibility for protecting your privacy very seriously and we will ensure your data is secured in accordance with our obligations under the Data Protection laws. We have in place technical and organisational measures to ensure personal information is secured and to prevent your personal data from being accessed in an unauthorised way, altered or disclosed. We have in place a robust access control policy which limits access to your personal data to those employees, contractors and other third parties who only have a business need to know. The processing of your personal data will only take place subject to our instruction.
We have policies and procedures to handle any potential data security breaches and data subjects, third parties and any applicable regulators will be notified where we are legally required to do so.
We have ensured that all employees have had information security and data protection training. If you would like more details of the security we have in place, please see "additional information", section 16 of this policy.
We do not knowingly collect information on children. If we have collected personal information on a child, please contact us immediately using the details in section 16, so we can remove this information without any undue delay.
In this Section, we have summarised the rights that you have under General Data Protection Regulation. Some of the rights are complex, and not all the details have been included in our summaries. Accordingly, you should read the relevant laws and guidance from the regulatory authorities for a full explanation of these rights.
Your principal rights under General Data Protection Regulation are:
The right to object
You can exercise this right if
If you have any question about these rights, please see "additional information", section 16 of this policy.
Where you have given consent for processing, or explicit consent in relation to the processing of special category data, you have the right to withdraw this consent at any time, but this will not affect the lawfulness of processing based on consent before its withdrawal. You can withdraw this consent via email on gdpr@foxgroupint.com or write to FAO Data Privacy, Fox Group International, 5300 Cinnabar Court, Daresbury Park, Warrington, Cheshire, WA4 4GE.
Where we need to collect personal data by law or in order to process your instructions or perform a contract we have with you and you fail to provide that data when requested, we may not be able to carry out your instructions or perform the contract we have or are trying to enter into with you. In this case, we may have to cancel our engagement or contract you have with us, but we will notify you if this is the case at the time.
We do not collect cookies.
Your personal data is not used in any automated decision making (a decision made solely by automated means without any human involvement) or profiling (automated processing of personal data to evaluate certain conditions about an individual).
Where we make an automated decision which has a legal or substantially similar effect, you have the right to speak to us and we may then review the decision, provide a more detailed explanation and assess if the automated decision was made correctly.
Fox Pharma Ltd may disclose your personal data, listed in section 4 to some third parties to help us deliver our services/products. All third parties are contractually bound to protect the personal data we provide to them. We may use several or all of the following categories of recipients:
In this section, we provide information about the circumstances in which your personal data may be transferred and stored in countries outside the UK.
We may share personal information to third parties outside of the UK. Any personal information transferred will only be processed on our instruction and we ensure that information security at the highest standard would be used to protect any personal information as required by the Data Protection laws.
Where personal data is transferred outside of the UK to a country without an adequacy decision, we will ensure appropriate safeguards are in place prior to the transfer. These could include:
International Data Transfer Agreement
An exception as defined in Article 49 of the UK GDPR
For more information about transfers and safeguarding measures, please contact us using the information in section 16.
We take any complaints about our collection and use of personal information very seriously.
If you think that our collection or use of personal information is unfair, misleading, or inappropriate, or have any other concern about our data processing, please raise this with us in the first instance.
To make a complaint, please contact us via email on gdpr@foxgroupint.com or write to FAO Data Privacy, Fox Group International, 5300 Cinnabar Court, Daresbury Park, Warrington, Cheshire, WA4 4GE.
You can also complain to the ICO if you are unhappy with how we have used your data.
The ICO's address:
Information Commissioner's Office
Wycliffe House
Water Lane
Wilmslow
Cheshire
SK9 5AF
Helpline number: 0303 123 1113
ICO website: https://www.ico.org.uk
Your trust is important to us. Please contact us if you have any questions about our privacy policy or information we hold about you or the basis upon which we process such information:
You can contact us at gdpr@foxgroupint.com or write to FAO Data Privacy, Fox Group International, 5300 Cinnabar Court, Daresbury Park, Warrington, Cheshire, WA4 4GE.
We keep this Policy under regular review. This Policy was last updated on 29/05/2024
We reserve the right to update this privacy notice at any time, and we will provide you with a new privacy notice when we make any substantial updates. We may also notify you in other ways from time to time about the processing of your personal information.