Homingo OÜ ("Homingo", "we" or "us") respects the privacy of individuals. We are a "controller" for the purposes of the General Data Protection Regulation (EU) 2016/679 ("GDPR"), the Data Protection Act 2018 and the Privacy and Electronic Communications Regulations (EU) 2003/2426 (collectively referred to as the "Data Protection Laws").
- the type of information about you that we collect
- how that information is used
- who will have access to that information
- how long we will hold your personal information for
- our security measures for protection of that information
- how our processing of your personal data is lawful, and
- your rights under the Data Protection Laws.
The term "personal data" means any information from which a living individual can be identified such as name, contact details and photographs. "Special categories of personal data" relates to more sensitive types of personal data including (amongst others) racial or ethnic origin, physical or mental health or condition and sexual life. These terms are defined in the Data Protection Laws.
Categories of information collected
We will collect and hold these categories of personal data about you:
General enquiries or complaints
If you submit a general enquiry, or if you need to make a complaint, we will need to collect your:
- contact details (address, phone number, email address), and
- the details of your enquiry or complaint.
We collect the following information in order to create and maintain your account and enable the medical services provided to you:
- your first and last names
- your email address, username and password
- your date of birth
- your phone number
- your marketing preferences.
In order to assess whether you can be prescribed with the product you have requested, you need to complete our medical questionnaire which collects medical information about you. This is a special category of personal data and may include photographs that you submit in connection with your medical consultation.
Purchase of prescription products
We will collect the following information to administer any purchases you wish to make through us from the Pharmacy:
- your contact and delivery details (phone number, email address and postal address)
- your purchase information (product, date, amount)
- the prescription issued by a General Practitioner through the Pharmacy. The GP who assesses your medical information will decide if you can be safely prescribed the product you want.
We do not store your payment card details within your account as all payment is dealt with directly by Stripe Payments Europe, Ltd. Stripe notifies us whether a transaction is successful or not.
We may from time to time ask you to provide feedback on the quality of our service. To do this we will need to collect your:
- contact details (address, phone number, email address), and
- information in relation how you came across us, how you have found us and how you think we can improve our services.
Information collected automatically
When you visit our site or use our services, we will automatically collect some information from the hardware and software you use at that time, which together with the other information we collect may constitute “personal data” for the purposes of the Data Protection Laws. If you are an unregistered user, we will still collect the following data (which alone is unlikely to constitute “personal data” for the purposes of the Data Protection Laws, but that we wish to be transparent about in any case):
- your browsing history on our websites
- the information provided by your device and browser, including referrer and tracking data, and
your ip address.
Homingo implements security measures to help protect the personal information we hold. We do this by implementing and using the appropriate technical and organisational measures in order to protect your personal data against accidental or unlawful destruction, accidental loss or alteration, unauthorised disclosure or access and any other unlawful forms of processing. We also aim to ensure that the level of security and the measures adopted to protect your personal data are appropriate for the risks presented by the nature and use of your personal data. We do this by following recognised industry practices for protecting our IT environment and physical facilities: for example, we encrypt the transmission of information through the website and app by using secure socket layer (SSL) technology and utilise involve.me to assure compliance for the personal data that we store on your behalf. To help maintain the security of your personal information, We ask that you please notify us immediately of any unauthorised visit, access or use of the website or the loss or unauthorised use of your username or password using the contact information that appears below.
Storage and sharing of information collected
Homingo shares your personal information with Homingo’s service providers who process your data as part of the services they offer to us. We take steps to ensure that our service providers treat your data in accordance with the law, only use it in accordance with our contract with them and keep it secure. Like any business, we use many other providers to help us operate our business and who process your personal data as part of providing their services to us.
Those providers fall into the following categories:
- involve.me – for data storage, customer engagement services and surveys
- Webflow – for web hosting
- Google Analytics and Tag Manager – to analyse and develop our web services
- Facebook – for advertising and marketing
- Google AdWords – for advertising and marketing
In addition, we share your personal data with the following organisations who act as separate controllers of your personal data. You should review their privacy policies to find out how they process your personal data. If you have any queries or complaints about how they process your personal data by them, please contact them separately using the contact information provided on their website:
- AJPharm Limited, its affiliated doctors who assess your medical information in order to prescribe the products, and its associated pharmacies that sell and deliver the prescription products to you
Stripe Payments Europe, Ltd. – takes payment for the products.
We also share data as necessary to enforce our legal rights, defend legal claims and if required by law to disclose to courts, police, law enforcement agencies or regulators.
Your privacy rights under the Data Protection Laws
You have the following rights under the Data Protection Laws. We will respond to any rights that you exercise within a month of receiving your request, unless the request is particularly complex, in which case we will respond within three months. Please be aware that there are exemptions in relation to some of these rights which we will apply in accordance with the Data Protection Laws.
a. Right to access your personal data
You may ask to see what personal data we hold about you and be provided with: - a copy - details of the purpose for which it is being or is to be processed - details of the recipients or classes of recipients to whom it is or may be disclosed, including if they are overseas and what protections are used for those oversea transfers - the period for which it is held (or the criteria we use to determine how long it is held) - any information available about the source of that data, and - whether we carry out an automated decision-making, or profiling, and where we do information about the logic involved and the envisaged outcome or consequences of that decision or profiling. To help us find the information easily, please provide us as much information as possible about the type of information you would like to see.
b. Right to rectification
You can require us to correct any mistakes in your information which we hold free of charge. If you would like to do this, please let us know the information that is incorrect and what it should be replaced with.
c. Right to erasure (‘the right to be forgotten’)
You can ask us to erase your personal data where:
- if you had given us consent to process your data, you withdraw that consent and we cannot otherwise legally process your data;
- you object to our processing and we do not have any legitimate interests to process your personal data; or
- your personal data has been processed unlawfully or have not been erased when it should have been.
d. Right to withdraw consent
e. Right to restrict processing
You may request that we stop processing your personal data temporarily if:
- you do not think that your data is accurate. We will start processing again once we have checked whether or not it is accurate;
- the processing is unlawful but you do not want us to erase your data; or
- we no longer need the personal data for our processing, but you need the data to establish, exercise or defend legal claims.
f. Right to data portability
You may ask for an electronic copy of your personal data which you provide to us, which we hold electronically and which we process when we have entered into a contract with you. You can also ask us to provide this directly to another party.
g. Right to object to processing of your personal data
You may object to us processing your personal data where we rely on a legitimate interest as our lawful basis for processing. If you object to us processing your personal data we must demonstrate compelling grounds for continuing to do so. We believe we have demonstrated compelling grounds in the section 'Lawful basis for processing your personal data'.
h. Rights in relation to automated decision making
We do not make any automated decisions about you so this right does not apply.
By post: Homingo OÜ, with a subject line containing “Data Protection” at Ahtri tn 12, Tallinn, 10151, Estonia.
By email: firstname.lastname@example.org, with a subject line containing “Data Protection.”
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