Apomedical Limited – Privacy Policy

Apomedical Limited ("we" or "us") is committed to the protection and respecting of your privacy.

This policy (together with our website terms of use (and any other documents we refer to in it)) outlines the basis on which we will process any personal data we collect from you, or that you provide to us. Please read this policy carefully to understand our practices and views regarding your personal data and how it will be treated. By visiting www.apomeds.com (“our site”), you are accepting and consenting to the practices that are described in this policy.

For the purpose of the Data Protection Act 2018, the EU General Data Protection Regulation or any other applicable legislation, the data controller is Apomedical Limited, a company registered in England with company number 11622278 with its registered office and physical address at Fifth Floor, 55 King Street, Manchester, United Kingdom, M2 4LQ.

Our data protection officer is Nataliia Perekhoda, who can be contacted at the above registered office address.

It should be noted that links from our site may take you to external websites that are not covered by this policy and we therefore recommend that you check the privacy policies of such external websites yourself before providing any personal information to such sites. We will not be responsible for the content, function or information collection policies of any such external websites.

Information we collect from you

We will collect and process the following data about you:

• Personal information you provide to us.

This is information about you that you give us by filling in any of the forms on our site or by corresponding with us whether by phone, email or otherwise. Such information includes the information you provide when you register to use our site, subscribe to our service, search for any products, place any orders on our site, participate in our discussion boards or other social media or interactive functions on our site, or enter a competition, promotion or survey, and when you report any problem with our site. The information you provide to us may include your name, address, email address and phone number, financial and credit card information, personal description and/or photograph.

• Special category data you provide to us.

This is sensitive information that you give to us by filling in any forms on our site or by corresponding with us by phone, email or otherwise. You will provide us with special category data when making a purchase on our site and completing our screening information as part of your consultation. Such sensitive information may include, but is not limited to, information relating to your health, genetics, ethnic origin, biometrics, sex life and/or sexual orientation.

• Information we collect about you.

Each time you visit our site, we will automatically collect the following information about you:

· technical information, which includes the internet protocol (IP) address used to connect your computer to the internet, login information, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform; and

· information about your visit, which includes the full Uniform Resource Locators (URL), clickstream to, through and from our site (including date and time), products you viewed or searched for on our site, page response times, any download errors, time spent on certain pages, page interaction information (such as scrolling, mouse-overs and clicks), methods used to browse away from the webpage, and any phone number used to call our customer service number.

• Information we receive from other sources about you.

This is information that we receive about you if you use any of the other websites operated by us or any of the other services provided by us. In this case, we will have informed you when the data was collected if we plan to internally share such data and combine it with data we have collected on our site. We will also have informed you of the purpose for which we will share and combine your data. We work closely with selected third parties (examples include our business partners, sub-contractors in technical, payment and delivery services, advertising networks, analytics providers, search information providers and credit reference agencies) and we will notify you when we receive information about you from such selected third parties and the purposes for which we plan to use that information.

This list is not a complete list and, in specific instances, we may need to collect additional data about you for the purposes set out in this policy.

Use of Cookies

We use cookies to distinguish you from other users of our site. This helps us to provide you with a good experience when you browse our site and assists us in making improvements to our site. By continuing to browse our site, you are agreeing to our use of cookies. For more information about how we use cookies on our site, please refer to our cookies policy.

We use information held about you in the following ways:

Personal information you provide to us

We will use this information:

• to carry out our obligations under any contracts that are entered into between you and us and to provide you with any information, products and services that you request from us;

• to provide you with information about other products and services that we offer that are similar to those that you have already purchased or made an enquiry about;

• to provide you, or permit selected third parties to provide you, with information about products or services we feel may be of interest to you. If you are an existing customer, we will only contact you electronically (i.e. by email or SMS) with information about products and services similar to those which were the subject of any previous sale or negotiations of any sale to you. If you are a new customer, and where we permit selected third parties to use your data, we (or they) will contact you by electronic means only with your consent. If you do not want us to use your data in this way or to pass your details on to selected third parties for marketing purposes, please tick the appropriate box situated on the order form on which your data is collected;

• to notify you about any changes to our service; and

• to confirm, using internal data analytics and other related marketing methods, that content from our site is presented in the most appropriate manner for you and for your computer or device.

Special Category Data

We rely upon your explicit consent to permit us to process your special category data, which is necessary for the purpose of preventative or occupational medicine, medical diagnosis and provision of health treatment, carried out in accordance with regulatory guidelines.

We will use this information to carry out our obligations under any contracts that are entered into between you and us and to provide you with the information, products and services that you request from us.

Information we collect about you

We will use this information:

• to administer our site and for internal operations, including for any troubleshooting, data analysis, testing, research, statistical and survey purposes;

• to improve our site to ensure that content is presented in the most appropriate manner for you and for your computer or device;

• to allow you to contribute to interactive features of our service, when you choose to do so;

• as part of our efforts to keep our site safe and secure;

• to assess or understand the effectiveness of any advertising that we provide to you and to others, and to deliver relevant advertising to you; and

• to make recommendations to you and other users of our site about products or services that may be of interest to you or them.

Automated decision-making and profiling may be used to tailor the information that we provide to you to your specific circumstances.

Who do we share your information with?

Details of whom we will share your data with and for what purpose is set out in our data record. Copies of our data record are available from our data protection officer.

Sharing your information within our company and partners

We share the information that you provide with our staff so that we can provide our products and services to you.

We may share the information that you provide to us with other partner companies and other websites that are operated by us. For example, if you place an order online, we may share information with the prescribing doctor to enable you to receive any prescription and also the pharmacy to arrange despatch of your prescribed medicine to you by post.

Sharing your information with third parties

We may share your information with selected third parties, these include:

• advertisers and advertising networks that require the data to select and provide appropriate adverts to you and to others. We do not disclose information to our advertisers about identifiable individuals, but have the right to provide them with aggregate information about users of our site. We may make use of the personal data that we have collected from you to enable us to comply with our advertisers’ requirements by displaying their advertisement to that target audience;

• search engine providers and analytics that assist us in the improvement, development and optimisation of our site; and

• credit reference agencies for us to assess your credit score where this is a condition of us entering into a contract with you.

In providing the service through our site, we engage with the following third parties:

• Related companies and business partners

• Third parties we use to help deliver our products and/or services to you, e.g. payment service providers, mail-order pharmacies. Please note that in respect to payment methods done via ‘paylater by invoice’ the following privacy policy shall also apply – Paysafe Paylater privacy policy

• Other third parties we use to help us run our business, e.g. digital marketing agencies or web hosting service providers;

• Third parties approved by you, e.g. social media websites you choose to link your account to or third party payment service providers;

• Law enforcement agencies in relation to any investigation to help prevent unlawful activity;

• Credit reference agencies;

• Our insurance companies

• Our banks; and

• Relevant regulators and authorities

There are certain exceptional circumstances in which we may disclose your information to other third parties. This would be where we believe that the disclosure is:

• required by law, or in order to comply with judicial proceedings, a court order or legal or regulatory proceedings;

• necessary to protect the safety of our employees, our property or the public;

• necessary to prevent or detect crime, including exchanging information with other companies or organisations for the purposes of fraud protection and credit risk reduction; and/or

• proportionate as part of a merger, business or asset sale.

If this happens, we will share your information with the prospective seller or buyer.

How long do we keep your personal information?

We will only store or retain your personal information for as long as we require it for the purposes for which it was collected. Where we provide you with any service, we will retain any information that you provide to us for at least as long as we continue to provide that service to you.

Where we store your personal data

The personal data that is collected from you will be transferred to, and stored at, a destination within the European Economic Area ("EEA"). It will also be processed by staff operating within the EEA who work either for us or for one of our suppliers. This includes staff who, among other things, are responsible for the fulfilment of your order, the processing of your payment details and the provision of support services to you. By submitting your personal data to our site, you agree to this transfer, storing or processing. We will take all steps reasonably necessary to ensure that the personal data provided to us is treated securely and in accordance with this privacy policy.

All personal information that you provide us with is stored on our secure servers. Any payment transactions will be encrypted using SSL technology. Where we have given you (or where you have created) a password which enables you to login to parts of our site, you are responsible for keeping this password confidential, safe and secure. We ask you not to share your password with anyone.

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 personal data that is transmitted to our site and any such transmission of your personal data is at your own risk. Once we have received your personal information, we will use strict procedures, measures and security features to try to prevent unauthorised access.

Your rights

You have the right to be informed

It is a legal obligation for us to provide you with concise, transparent, intelligible and easily accessible information about your personal information and how we use it. This policy has been written to do just that, but if you have any queries or require more detailed information, you can contact us using any of the methods set out in this privacy policy.

You have the right to access your personal data

You have the right to request us to confirm whether or not we hold any of your personal information. If we do, you have the right to have a copy of your personal information and to be informed of:

• Why we have been using your information

• What categories of information we have been using

• Who the information has been shared with

• How long we envisage holding your information for

In order to maintain the security of your information, we will have to confirm your identity before we provide you with a copy of the personal information we hold. The first copy of your information that you request from us will be given to you free of charge. If you require any additional copies, we may charge an administrative fee to cover the costs involved.

You have the right to correct any inaccurate or incomplete personal data

Where you have requested a copy of your personal information, you may notice that there are inaccuracies in these records, or that certain parts are not complete. If this is the case, you can contact us so that we can correct the records we hold on you.

You have the right to be forgotten

There may be times where it is no longer necessary for us to hold your personal information. Examples may include if:

• the information is no longer needed for the original purpose for which it was collected;

• you withdraw your consent for us to use the information (and we do not have any other legal reason to keep using it);

• you object to us using your information and we have no overriding reason to do so;

• we have used your information unlawfully; and/or

• we are subject to a legal requirement to delete the information.

In the above situations, you have the right to have your personal data deleted. If you consider one of these situations applies to you, please contact us.

You have the right to have a copy of your data transferred to you or a third party in a compatible format (data portability)

You have the right to obtain a copy of your personal data for your own purposes. This right allows you to move, copy or transfer your personal data more easily from one IT system to another in a secure and safe manner. If you would like to request a transfer of a copy of your personal data to you or another organisation in a structured, commonly used and machine-readable format, please let us know. We will not charge you for exercising this right.

You have the right to object to direct marketing

You can tell us at any time that you would not like us to use your personal information for direct marketing purposes. If you would not like to receive any direct marketing from us, please contact us or use the links which are presented in any of our marketing communications, and we will immediately stop sending direct marketing to you.

You have the right to object to us using your information for our own legitimate interests

From time to time, we use your personal information to achieve aims that will help us as well as you. This includes:

• when we tell you about any products or services that are similar to the ones that you have already purchased;

• when we use your information to improve our business; or

• when we contact you to interact, communicate or to let you know about any changes we are making.

Our intention is to always ensure that your rights and information are properly protected. If you consider our use of your personal data is not justified due to its impact on you or your rights, you have the right to object. Unless we have a compelling reason to continue, we must stop using your personal data for these purposes. Please contact us in order to exercise your right to object to our use of your data for the purposes above.

You have the right to restrict how we use your personal data

You have the right to request that we stop using your personal data in any way other than simply keeping a copy of it. This right is available where:

• you have informed us that the personal information we hold about you is inaccurate, and we have not yet been able to confirm this;

• you have objected to us using your personal information for our own legitimate interests and we are currently considering your objection;

• we have used your information in an unlawful way but you do not want us to delete the data we hold; or

• we no longer need to use the information, but you require it for a legal claim.

If you believe any of the above situations apply, please contact us.

You have rights related to automated decision making and profiling

Any automated decision making or profiling that we carry out is solely for the purpose of tailoring the information which is provided to you. Automated decision making or profiling will not be used to make any decisions which will have a legal effect upon you or otherwise significantly have an impact on you, and you have the right not to be subject to such decisions. If you have any concerns or queries about this right, please contact us.

Changes to our privacy policy

Any future changes that we make to our privacy policy will be posted on this page and, where appropriate, will be notified to you by email. Please check frequently to see any amendments to our privacy policy.

Complaints

If you would like to make a complaint about our collection or use of your personal data, please contact us in the first instance so that we may seek to resolve your complaint. You can do this by any of the following:

By post: Registered Address:

Apomedical Limited, Fifth Floor, 55 King Street, Manchester, United Kingdom, M2 4LQ

By email: support@apomeds.com

By phone: +43 681-84665606 Monday to Friday 0900 to 1700

You have the right to submit a complaint with the Information Commissioner’s Office (ICO), the statutory body which oversees data protection law in the UK. Please visit the ICO website https://ico.org.uk if you wish to submit a complaint to them.

This policy was most recently updated on 21 December 2018.