IPS Privacy Policy
1. Introduction
1.1 Welcome to IPS’s privacy notice.
1.2 We respect your privacy and are committed to protecting your personal data. This privacy notice will inform you as to how we look after your personal data we collect from you both when you visit our website (regardless of where you visit it from) and where we carry out services for you. This privacy notice tells you about your privacy rights and how the law protects you.
1.3 Please use the Glossary to understand the meaning of some of the terms used in this privacy notice.
2. Purpose of this Privacy Notice
2.1 This privacy notice aims to give you information on how IPS collects and processes personal data:
2.1.1 through a customer’s use of our website, including any data an individual may provide through our website;
2.1.2 when a customer purchases our services or contacts us in respect of our services either by telephone or through the website;
2.1.3 third parties with whom we deal in order to provide our services;
2.1.4 job applicants and our current employees; and
2.1.5 when you agree to us contacting you in respect of event s we will be attending or hosting.
2.2 We do not knowingly collect data relating to children and the use of children’s personal data is not included in this notice.
2.3 It is important that you read this privacy notice together with any other privacy notice or fair processing notice we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy notice supplements the other notices and is not intended to override them.
3. Controller
IPS, the trading name of Vertical Pharma Resources Ltd. Our trading name is IPS Specials. We are the controller and responsible for our personal data. All companies with the IPS name, for more information about IPS, please visit the about us page (collectively we will be referred to as “Company”, “we”, “us” or “our” in this privacy notice).
4. Contact Details
4.1 Our full details are:
Vertical Pharma Resources Limited. We are a company incorporated and registered in England and Wales under company number 06077026 and whose registered office is situated at 41 Central Avenue, West Molesey, Surrey, KT8 2QZ.
Email address: info@ipsspecials.com
4.2 You have the right to make a complaint at any time to the Information Commissioner’s Office (“ICO”), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.
5. Changes to the Privacy Notice
5.1 The data protection law in the UK will change on 25 May 2018. Although this privacy notice sets out most of your rights under the new laws, we may not yet be able to respond to some of your requests (for example, a request for the transfer of your personal data) until June 2018 as we are still working towards getting our systems ready for some of these changes.
5.2 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 your relationship with us.
6. Website Third-Party Links
Our website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections through our website 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.
The data we collect about you
6.1 Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).
6.2 We may collect, use, store and transfer different kinds of personal data about you which we have grouped together follows:
Identity Data includes first name, maiden name, last name, username or similar identifier, marital status, title, date of birth and gender.
Contact Data includes your email address and telephone numbers.
Financial Data includes [bank account and payment card details].
Transaction Data includes details of services you have received from the Company.
Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this website.
Profile Data includes preferences, feedback and survey responses.
Usage Data includes information about how you use our website.
Marketing and Communications Data includes your preferences in receiving marketing from us [and our third parties and your communication preferences].
6.3 We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website 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 notice.
6.4 Special Categories of Personal Data include details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data. We do not collect Special Categories other than information about health necessary for the performance of our obligations. We do not collect any information about criminal convictions and offences.
6.5 Information about your Health
6.6 When our customers (pharmacies or persons or organisations who are dispensers of medicines) use our services, we may ask for information about the health of the individual who requires our products. This may involve us processing data from NHS bodies such as your GP or hospitals supplied to us in order for us to legally provide our products to our customers. We understand the sensitivity of this information and will only use it to provide our customers with the required services and fulfil our legal obligations to our regulating bodies. We will never use information about an individual’s prescriptions for marketing, although we may use it to let our customers know about services we provide that might be useful and relevant. This information is held securely on our systems and used only for processing your order. We won’t use it for any other purpose. We may contact our customers by email about your online clinic order. Please note that if you send an email directly to our us from your own email account, its contents will not be encrypted and therefore cannot be guaranteed to be secure.
6.7 Information provided by other people on your behalf
For certain medicines we are required by law to ask for basic details about the individual for whom the medicine is prescribed, which may include health details. We ask our customers to please make sure they are happy for us to provide this personal information on their behalf and that they understand why we need to ask for it.
7. If you Fail to Provide Personal Data
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). In this case, we may have to cancel the service you require but we will notify you if this is the case at the time.
8. How is Personal Data Collected?
8.1 We use different methods to collect data from and about you including through:
8.2 Direct interactions. You may give us your Identity, Contact and Financial Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
8.2.1 request information about our services including proposals and quotations;
8.2.2 as part of our ordering processes including order forms;
8.2.3 subscribe to our service or publications;
8.2.4 request marketing to be sent to you;
8.2.5 complete a survey; or
8.2.6 give us some feedback.
8.3 Automated technologies or interactions. As you interact with our website, we may automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies. Please see our cookie policy on paragraph 23 below for further details.
8.4 Third parties. We may receive personal data about individuals requiring our products from our customers.
8.5 Technical Data from the following parties:
i) analytics providers such as Google based [outside/inside] the EU; and
ii) search information providers based inside the EU.
8.6 Identity and Contact Data from publicly available sources such as Companies House and the Electoral Register.
9. How We Use Your Personal Data
9.1 We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:
9.1.1 where we need to perform the contract we are about to enter into or have entered into with you.
9.1.2 where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests. Our legitimate interests are in performing services to you or promoting or furthering our services.
9.1.3 where we need to comply with a legal or regulatory obligation.
9.1.4 generally we do not rely on consent as a legal basis for processing your personal data but may do so for our communications to existing customers or business contacts as at 25 May 2018 where consent is required under the Privacy and Electronic Communications (EC Directive) Regulations 2003. You have the right to withdraw consent to marketing at any time by contacting us.
10. Purposes for Which We Will Use Your Personal Data
10.1 We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.
10.2 Note that we may process your personal data for more than one lawful basis depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal basis we are relying on to process your personal data where more than one basis has been set out in the table below.
