Privacy Policy

Privacy Policy: Key Points 
Introduction 
At Curely, we are committed to safeguarding and preserving the privacy of our visitors. These points summarise some of the more important provisions in our privacy policy. We also recommend that you read the full privacy policy. 

Information we collect 

• When you visit our website, we automatically collect and save your IP address.
• Where you volunteer this information (i.e. by filling in an online form to use our services), we will also save your name, delivery address, email address, date of birth, telephone number, GP address, patient notes, consultation notes, payment records and details of the medicines you have ordered.

Use of your information 
We use your personal information: 

• To provide our services to you (namely, medical consultations for prescription medications) and to comply with regulatory requirements.
• To send you details of our goods and services

We share your personal information: 

• With other third parties where this is necessary to deliver the services. 

Patient confidentiality 
Some of the information we collect is medical data. This information is always treated confidentially. We will never disclose medical data unless legally required or permitted to do so. It will not be used by us for marketing purposes unless you give us your express permission. 

Privacy Policy - The Details 
Introduction 
Samy Health Ltd (under the trading name of Curely), whose registered office is at 84 Hamilton Road, Motherwell, Scotland, ML1 3BY, United Kingdom ("Curely", we" "us" or "our") knows that you care how information about you ("Your Data") is used and shared and we appreciate your trust in us to do that carefully and sensibly. We respect your privacy and are committed to protecting Your Data. 
At Curely we are committed to safeguarding and preserving the privacy of our customers and website visitors. 
This Privacy Policy ("Policy") forms part of our website terms and conditions ("Website Terms"), as set out here. This Policy explains what happens to any personal information that you provide to us, or that we collect from you whilst you visit our site. 
We do update this Policy from time to time so please do review this Policy regularly. 
Important information about who we are.
Curely is a controller and responsible for all personal data it receives and holds. We have appointed a data protection leader ("DPL") who is responsible for overseeing questions in relation to this Policy. If you have any questions about this Policy, including any requests to exercise your legal rights, please contact the DPL using the details set out below:

Full name of legal entity: Samy Health Ltd 
Name or title of DPL: Yasir Jamil  
Email address: hello@curely.co.uk 
Postal address: 84 Hamilton Road, Motherwell, Scotland, ML1 3BY, United Kingdom  
Telephone number: 0200 111 1111  

If you have any queries, concerns or complaints about the use of Your Data by us, please raise them with the DPL. If this does not resolve the problem to your satisfaction, or, if you prefer to raise the issue with somebody else, then please speak to Yasir Jamil who will deal with your complaint.

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. We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.

Changes to the Policy and your duty to inform us of the changes 
This version was last updated in March 2023. 
It is important that the personal data we hold about you is accurate and current. Please keep us informed if Your Data changes during your relationship with us. 

Information We Collect 
If you register with us, we will collect personal data or personal information from you. Personal data or personal information means any information about an individual from which that person can be identified. It does not include data where a person's identity has been removed (anonymous data). 
We may collect, use, store and transfer different kinds of data about you which we have categorised as follows: 

• Identity Data includes first name, last name, date of birth and gender. 
• Contact Data includes delivery address email address and telephone numbers. 
• Financial Data includes bank account, payment records and payment card details. 
• Medical Data includes your patient medical records, Doctor details, patient notes, consultation notes and details of medicines you have ordered and order history. This category of data constitutes sensitive personal data for the purposes of data protection legislation. This will only be collected where you have expressly provided your consent to provide us with this data through any online forms and medical questionnaires you complete and send to us, telephone conversations and secure messaging with us, as well as through photo assessments. 
• Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences. 

We also collect and use Aggregated Data such as statistical or demographic data for internal purposes. Aggregated Data may be derived from Your Data but is not personal data as it does not directly or indirectly reveal your identity. For example, we may aggregate information about how you use our website and services to calculate the percentage of users accessing a specific website feature, but this is anonymised. However, if we combine or connect Aggregated Data with Your 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 Policy. 

How is Your Data collected? 
We use different methods to collect data from and about you, including through: 
Automated technologies or interactions If you interact with our website, we may automatically collect data about your equipment, browsing actions and patterns. When you visit our website, we automatically collect information about your use of our site including details of your visits such as pages viewed and the resources that you access. Such information may include Aggregated Data, traffic data, location data and other communication data. For more information about the cookies we use, please see our Cookie Policy. 

Direct interactions 
You may give us your Identity, Contact, Medical 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: 

• make an online enquiry; 
• completing forms and medical questionnaires on our website. This includes information provided at the time of registering to use our site, subscribing to our service, consultations for treatments, posting material or requesting further services; 
• make an online payment; 
• request marketing material to be sent to you; 
• provide us with feedback. 

Confidentiality 
Your Medical Data is treated confidentiality, which means that none of our staff can access it unless they are a healthcare professional (or owe a similar duty of confidentiality). We will never disclose Medical Data without your consent unless legally required or permitted to do so. 
Your Medical Data will not be used by us to send you information about our products and services (i.e. for marketing purposes) unless you give us your express consent to use your Medical Data this way. 

Use of Cookies 
You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly. For more information about the cookies we use, please see our Cookie Policy. 

Use of Your Information 
We will only use the information that we collect from you as follows: 

• To enable us to provide our health services to you 
• To enable us to comply with regulatory requirements 
• To communicate with you in the event that there is a query or problem with your order 
• To inform you of any changes to our website, services or goods and products 
• For record keeping purposes 
• To track and analyse activity on our website 

Marketing purposes 
We will only contact you for marketing purposes where you have given us your express consent to contact you for this purpose. Once you have given us your permission to contact you for marketing purposes, we may use Your Data for one or more of the following: 

• To provide information to you that you request from us relating to our products or services. 
• To provide information to you relating to other products that may be of interest to you. 
• To allow selected third parties to use Your Data to enable them to provide you with information regarding unrelated goods and services, which we believe may interest you. 

You may change your mind and withdraw your permission for us to contact you for marketing purposes at any time by emailing us at hello@curely.co.uk. This will not affect your use of our services.

Use of your Medical Data for marketing purposes 
Where you have given us your express permission in advance (separately to permitting us to send you more general marketing material), we may also use your Medical Data to send you specialist information about our products and services. For example, if a customer told us that they suffer from acne and asked us to send them marketing material about acne related goods and services, we may do so. This information would never be shared with third parties to enable them to send you information regarding their goods and services. 
You can change your mind and withdraw your permission for us to use your Medical Data for marketing purposes at any time by emailing us at hello@curely.co.uk. This will not affect your use of our services. 

Change of purpose 
We will only use Your Data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please email hello@curely.co.uk. Should we need to use Your Data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so. 
Please note that we may process Your Data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law. 

Storing Your Personal Data 
We have put in place appropriate security measures to prevent Your Data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to Your Data to those employees, agents, contractors and other third parties who have a business need to know. They will only process Your Data on our instructions and they are subject to a duty of confidentiality. 
We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so. 
Please note that sending information via the internet is not totally secure and on occasion such information can be intercepted. We cannot guarantee the security of personal information that you choose to send us electronically and sending such information is entirely at your own risk. 

Data retention 
We will only retain Your Data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements. 
To determine the appropriate retention period for Your Data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of Your Data, the purposes for which we process Your Data and whether we can achieve those purposes through other means, and the applicable legal requirements. 
During the provision of our services to you we will retain Your Data to provide our goods or services to you. 
We are required by law to retain specific categories of Your Data for certain periods after we stop providing our goods or services to you. We are therefore required to store any Medical Data, Identity Data and Contact Data submitted to us to comply with our legal obligations. 
Please note that we may keep Your Data for longer than the periods stated above if it is necessary. However, this will be assessed on a case by case basis. If we determine that it is necessary to keep Your Data for longer than the periods listed above, we will confirm this to you in writing when we have finished providing our goods and services to you and explain why it is necessary. 

Disclosing Your Data 
We may share your data with selected third parties. For example, we may share your information with: 

• Our staff 
• Your doctor  
• Third party couriers (e.g. DPD or Royal Mail) in order to arrange delivery or your order. We will only share your full name, postal address and phone number or email address. 
• Clinical auditors and regulatory bodies. Our pharmacy is registered with the General Pharmaceutical Council. Our prescribers are registered with the General Pharmaceutical Council. Medicines are regulated by the Medicines and Healthcare Products Regulatory Agency. As such, our practices are routinely inspected by these regulatory bodies on a periodic basis. During an inspection, we may be required to share information about your consultation with an approved auditor. 
• Analytics and search engine providers that assist us in the improvement and optimisation of our site; 
  credit reference agencies for the purpose of assessing your credit score where this is a condition of us entering into a contract with you. 

Third Party Links 
On occasion we include links to third-party websites, plug-ins and applications on this website. 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 and/or policies. When you leave our website, we encourage you to read the privacy policy of every website you visit. 

Your legal rights 
In certain circumstances, you have the following rights under data protection laws in relation to Your Data. You have the right to: 
Request access to Your Data (commonly known as a "data subject access request"). This enables you to receive a copy of the Your 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 Data . This enables you to ask us to delete or remove Your 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 Data where you have successfully exercised your right to object to processing (see below), where we may have processed Your Data unlawfully or where we are required to erase Your 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 Data where we are relying on a legitimate interest (or those of a third party) and there is something about your 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 Data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process Your Data which override your rights and freedoms. 
Request restriction of processing of Your Data. This enables you to ask us to suspend the processing of Your Data in the following scenarios: 

• if you want us to establish the data's accuracy; 
• where our use of Your Data is unlawful, but you do not want us to erase it; 
• where you need us to hold Your Data even if we no longer require it as you need it to establish, exercise or defend legal claims; or 
• you have objected to our use of Your Data, but we need to verify whether we have overriding legitimate and/or legal grounds to use it. 

Request the transfer of Your Data to you or to a third party. We will provide to you, or a third party you have chosen, Your 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 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 certain products or services to you. We will advise you if this is the case at the time you withdraw your consent. Please note that we may not be able to comply with this request where we have a legal obligation to keep Your Data. 
If you wish to exercise any of the rights set out above, please email hello@curely.co.uk or telephone 0200 111 1111 and ask to speak to the DPL. 

Data subject access request 
You will not have to pay a fee to access Your Data (or to exercise any of the other rights set out above). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may 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 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 may take us longer than a month if your request is particularly complex or you have made several requests. In this case, we will notify you and keep you updated. 

Contacting Us 
Please do not hesitate to contact us regarding any matter relating to this Policy at hello@curely.co.uk