Online GP Services Ltd, trading as ‘GenderGP’ a company registered in England and Wales under number  whose registered address is at Office 7, 35-37 Ludgate Hill, London, England, EC4M 7JN hereinafter referred to as (GGP]’ ‘We’, ‘Us’ or ‘Our’, have created this privacy statement (‘Statement’) in order to demonstrate Our firm commitment to the privacy of the details that You provide to Us when using the GGP Site to access the GGP Services.
We are committed to protecting and respecting Your privacy and Your Personal Data. For the purpose of the Data Protection Act 1998 (and the GDPR as from the 25th May 2018), Katie Tiplady-Startin is the Data Controller (ICO registration number: ZA227187).
For all matters relating to privacy and data protection, please contact Katie Tiplady-Startin, Data Protection Manager by email to firstname.lastname@example.org.
In this Statement, references to ‘You’, ‘Your’ and ‘GGP User/ Customer’ are references to visitors who use the GGP Site. When You use the GGP Site to access the GGP Services, You are consenting to the practices set forth in this Statement.
We aim to be as clear as possible in this Statement in respect of Your Personal Data. This Statement applies to Your Personal Data that We collect about You when You use the GGP Site, how and when it is used, how We protect it and who has access to it (the ‘Terms’).
Unless otherwise stated, any defined terms in here shall have the meaning set out in the Service Standards
YOUR ACCEPTANCE OF THIS PRIVACY STATEMENT
This Statement governs Your use of the GGP Services, including any dispute concerning privacy. By using the GGP Services, You accept this Statement in full. You should read the Statement carefully and ensure that You understand its effect before proceeding to use the GGP Site to access the GGP Services. We reserve the right to make reasonable changes to any of the Terms herein at any time. Any changes We do may make will be posted on this page and, where appropriate, notified to You by email, or, when You next log in, the new Terms may be displayed on-screen and You may be required to read and accept them to continue.
Personal Data and Special Category Personal Data are defined in accordance with the Data Protection Legislation. In this Privacy Statement, Personal Data shall include the meaning of Special Category Personal Data.
WHAT PERSONAL DATA IS COLLECTED & HOW?
PERSONAL DATA SUBMITTED VOLUNTARILY BY YOU TO US:
In order for Us to provide You with the GGP Services, We collect various types of Personal Data. We are committed to ensuring that the information We collect and use is appropriate, relevant and proportionate for the stated purpose. Some types of Personal Data may be voluntarily provided by You which is to be shared with Us and GGP Service Providers as applicable in respect of yourself (or in respect of one or more other individuals where lawful authority is granted to You by those other individuals) which shall include as follows:
|What Personal Data is processed?||Where is it collected from/via?||What is the ‘purpose’ of processing||What is the lawful basis for processing?||Retention: For how long is it held?|
Personal contact details
Website contact form
In order to be able to respond and contact the enquirer
Article 6(1)(b) GDPR
No end date due to medical nature
|Medical history||To assess suitability for treatment||Article 6(1)(b) and 9(1)h GDPR||No end date due to medical nature|
|Blood test results||Email/Post||To assess suitability for treatment and ongoing safety of treatment||Article 6(1)(b) and 9(1)h GDPR||No end date due to medical nature|
|Contact details of other interested parties||To keep all involved specialist up to date||Article 6(1)(b) and 9(1)h GDPR||No end date due to medical nature|
Some of the information collected in the table above is essential for Us to provide You with the GGP Services but it is Your choice whether You provide all the information We request. Not providing information may affect Our ability to provide all the GGP Services to You.
We will retain your Personal Data only for as long as is necessary to provide the GGP Services which You request and in accordance with the retention periods set out in column 4 of the table at Clause 2.1. We shall then delete it unless you ask Us not to, or We have a legitimate reason to retain it. We need to retain sufficient information about You in compliance with legal or statutory requirements, for example, in the event of a legal or insurance claim in the future so that We can identify You.
We may from time to time offer a range of additional services. We may need to collect additional information about You as part of this. This may include but us not limited to promotions, prize draws, competitions and surveys. Additional notices about the information that We collect and how We will use it will be provided to You at the point that You are invited to avail of these additional services.
Where We state that We rely on consent under Article 6(1)(a) to process Your Personal Data for a particular purpose as per column 3 of the table at Clause 2.1, You have the right to withdraw Your consent at any time. This will not affect the lawfulness of processing carried out by Us which was based on consent before its withdrawal.
PERSONAL DATA AUTOMATICALLY COLLECTED BY US:
• Your visits to the GGP Site and the GGP Content that You download;
• Your IP address;
• Your geographical location;
• Your browser type and version;
• Your operating system;
• Your referral source;
• Your length of visit;
• Your page views and Site navigation and exit;
GGP agrees and warrants that it will adhere to all Data Protection Legislation and will take appropriate technical and organisational security measures against the unauthorised or unlawful processing of Your Personal Data and against accidental loss or destruction of, or damage to Your Personal Data.
GGP shall process Personal Data list in the table at Clause 2.1 only to the extent, and in such a manner, as is necessary for the sole purpose of fulfilling the GGP Services (including making improvements to the GGP Services). For the avoidance of doubt, GGP is the exclusive owner (or lawful licensee) of the GGP Site as well as the GGP Content.
FINANCIAL PERSONAL DATA
Each monetary transaction made via GGP Site shall be processed by a third-party payment processing partner who is a GGP Service Provider – Chargedesk, Stripe, and/or PayPal. You will be required to provide Chargedesk, Stripe, or PayPal with Your Personal Data including financial data in order to use the payment processing services.
To make and complete a financial purchase or to receive a payment via the GGP Site the policies of named in the relevant section shall apply.
You are subject to the terms and conditions of those named in the relevant section.
HOW IS YOUR DATA USED?
GGp will process i.e. collect, store and use the Personal Data You provide in a manner that is compatible with the Data Protection Legislation.
We will endeavor to keep Your Personal Data accurate and up-to-date and not keep it for longer than is necessary. Our aim is not to be intrusive and We undertake not to ask irrelevant or unnecessary questions. Moreover, the information You provide will be subject to rigorous measures and procedures to minimise the risk of unauthorised access or disclosure.
You acknowledge that, Your Personal Data may be used by GGP to contact You when necessary in connection with Your use of the GGP Site to access the GGP Services as follows:
|What type of Non-Marketing Communication?||Method of presentation/sending?||Legal Basis for processing?|
|Administration related – to set up and continue to provide ongoing support services||We do not need Your explicit consent for this as the “processing is necessary for the performance of a contract” under Article 6(1)(b) GDPR.|
|Blood test requests and results – required as part of the ongoing service provision.||We do not need Your explicit consent for this as the “processing is necessary for the performance of a contract” under Article 6(1)(b) GDPR.|
|Appointment arrangement – should you require an appointment we will need to arrange this||We do not need Your explicit consent for this as the “processing is necessary for the performance of a contract” under Article 6(1)(b) GDPR.|
From time to time and with Your permission, GGP may contact You and send you Marketing Communications that We believe may be of interest to You which shall be of the type (and via the method(s)) referred to in the table. By looking at Your participation profile as well as any additional information which You have agreed can be shared with Us, We can identify news, offers and services that are most likely to be most relevant and will meet Your needs. When We send You a Marketing Communication, We may monitor whether You have opened the communication and clicked on any included links. This will enable Us to track and analyse Your level of engagement/ interest in the communication We are sending to You and will provide Us with further insight on what type of communications are of most interest to You.
|What Type of Marketing Communication?||Method of presentation/sending?||Legal Basis for processing?||How can you opt out of continuing to receive direct marketing communications?|
|Email newsletter||We will only send You these where You have provided Us with specific consent for this specific purpose as permitted under Article 6(1)(a) GDPR
where You have purchased from Us and have not opted out of, or objected to, receiving Marketing Communications under Article 6(1)(f) GDPR.
|In the email footer and manage send preferences in Mailchimp|
If You agree to receiving any of the above Marketing Communications but later change Your mind, You can opt out at any point, by using the ‘unsubscribe’ link at the end of any Electronic Mail communication received by You.
LEGITIMATE INTERESTS TO PROCESS YOUR PERSONAL DATA:
We process Personal Data about You where We have a legitimate interest to do so. In some cases, this may require Us to collect additional information from You or from other sources. Where We do rely on legitimate interests under Article 6(1)(f) GDPR to process Your Personal Data, You have the right to object to any of the processing We undertake. If You wish to object please complete Our Objections Form. Please bear in mind that if You object, this may affect our ability to provide to You the benefits of the GGP Services.
We may from time to time use publicly available demographic information to determine who We target for specific events or marketing campaigns so as to avoid contacting individuals unnecessarily.
WHO HAS ACCESS TO YOUR DATA?
To minimise the risk of unauthorised access to Your Personal Data, We use some of Your Personal Data to authenticate Your identity when You use the GGP Site to access the OGPS Services.
We have a legitimate interest in sharing Your Personal Data with Our GGP Service Providers who We engage to provide some of Our business and daily operational functions on Our behalf to ensure the GGP Services. Consequently, We need to disclose Your Personal Data to them for the sole purpose of fulfilling the GGP Services only (including making improvements to the GGP Services) and not for the purposes of those GGP Service Providers sending Marketing Communications to You. We limit the Personal Data that We share to the minimum required to provide the service and the GGP Service Provider will only be able to use Personal Data for the specific purposes for which it was shared. We do not need Your express consent for this as We rely on legitimate interests under Article 6(1)(f) GDPR in addition to the fact that the “processing is necessary for the performance of a contract” under Article 6(1)(b) GDPR
Disclosure of Your Personal Data in Compliance with Laws or by way of a Legal/Statutory Obligation
You should be aware that We may release Your Personal Data when We believe it is necessary to comply with laws or regulations, to assist law enforcement, to enforce the terms under which You transact or communicate with GGP or to protect the rights, property or safety of GGP, a GGP User/ Customer or other third parties. We may need to process Personal Data about You to comply with a legal or statutory obligation including but not limited to:
- accounting, auditing, compliance and administration practices; and,
- the maintenance of amendments to consents and to create suppression lists to ensure GGP Users/ Customers who object to processing are excluded from the relevant processing activity in the future.
Transfer of Your Personal Data
From time to time, We may transfer Your Personal Data to a related company, agent or contractor (also known as GGP Service Providers) in order to improve Our GGP Services or to assist our security, credit risk or fraud protection activities and as permitted by Data Protection Legislation from time to time.
Some or all of Your Personal Data is transferred and stored within the European Economic Area (the “EEA”) (The EEA consists of all EU member states, plus Norway, Iceland, Liechtenstein) in compliance with the Data Protection Legislation. Should We need to transfer Your Personal Data outside of the UK or EEA in the future, it will be in compliance with the GDPR requirements for external transfer and all details will be added to Our Privacy Statement.]
Transfer of Personal Data in the Event of the Sale of Online GP Services Ltd or its Assets
In the event that GGP is sold or transfers some of its assets to another party, Your Personal Data could be one of the transferred assets. If Your Personal Data is transferred, its use will remain subject to this Privacy Statement. Your Personal Data will be passed on to a successor in the event of a liquidation or administration.
Other Websites and their Privacy Policies and Cookie Policies
The GGP Site may contain links to other websites or applications. GGP is not responsible for the privacy practices or the content of such websites or applications or for the privacy policies, cookie policies and practices of other third parties, so You should be careful to read and understand those policies independently.
HOW DO WE PROTECT YOUR PERSONAL DATA & FOR HOW LONG?
We aim to ensure Our GGP Services are fully inclusive and accessible to everyone. To make this possible We need to collect (and may provide to prospective GGP Service Providers) information on Your usage of the GGP Services which will help us review the accessibility of, and Your usage of, the GGP Services. This information is very important to Us as it also enhances Our understanding of the GGP User needs and helps Us to aid the technical administration of [GGP Site to better understand how the GGP Site is functioning and to draw conclusions upon demographic information. Such information is provided in anonymised and aggregate form and do not include any individually identifiable data.
How long We keep Your Personal Data collected through the GGP Site depends on the context in which You provide it and the purpose for which We use it. We will only retain it for as long as is necessary for such purposes. GGP uses it discretion to decide retention periods in consultation with the advice provided by any organisation by which We are a member of or regulated or governed by as referred to at the top of this Privacy Statement. Our retention periods are set out in the table at Clause 2.1.
We may record calls, both inbound and outbound, as it helps Us to understand the contents of the conversations better especially when they involve work requests/ instructions from You. These recordings may also be used for training and quality control to ensure that We continuously monitor and improve Our service standards. Sometimes, We need to listen to a call over and over again to save Us contacting You again for the same info! If We record calls, they are recorded and stored using the services of a Third Party Service Provider called justcall.io. Sometimes We will download it to a computer file. All recordings are deleted from Our computers as soon as We determine that We no longer need it. This may be immediately following the call. Our legal basis for processing Personal Data in this way is supported by Article 6(1)(b) GDPR or where contract does not apply, We rely on Our legitimate interests under Article 6(1)(f) GDPR
YOUR RIGHTS UNDER DATA PROTECTION LEGISLATION
|What is your right under the GDPR?||How do we honour your right?|
|The right to be informed||We must provide ‘fair processing information’, typically through a privacy statement such as this describing how and why We collect and use Your Personal Data.
Read more guidance from the ICO on what information we should supply to You and when You should be informed (which shall differ depending on whether or not We obtained the Personal Data directly from You or a third party).
|The right of access||We try to be as open and transparent as We can be in terms of giving You access to the information that We hold on You. You are entitled to be able to check the lawfulness of any processing of Your Personal Data. You can find out if We hold (and process) any other Personal Data by making a ‘Data Subject Access Request’ (DSAR). To make a DSAR to access Your Personal Data that We may hold, You need to put the request in writing addressing it to the postal address provided or You can send it electronically to the email address below. We will action Your request without delay and at the latest within one (1) month of Your request subject to any extensions granted. Alternatively, if You agree, We will try to deal with Your request informally, for example, by providing You with the specific information You need over the telephone.
If We do hold information about You, We will:
Read more guidance from the ICO.
|The right of rectification||You are entitled to have Your Personal Data rectified if it is inaccurate or incomplete. If We have disclosed this to third parties, We will inform You. We have one month initially to rectify it subject to a possible extension.
Where We decide not to rectify, We shall provide an explanation as to why We are not making changes and inform You of Your further rights.
Read more guidance from the ICO.
|The right of erasure||You haYou have a legal and personal “right of erasure”, the extension of which is also known as the “right to be forgotten”. Upon Your request, We will close Your Account and remove Your Personal Data as soon as reasonably possible from all of Our records unless a lawful reason exists for Us to retain some or all of it.
Read more guidance from the ICO.
|The right to restrict processing||You have a right to ‘block’ or ‘suppress’ the processing of Your Personal Data under certain circumstances but We are still entitled to store just enough of Your Personal Data to ensure that the restriction is respected in future.
Read more guidance from the ICO.
|The right to object||
Read more guidance from the ICO.
|The right to data portability||You are entitled to obtain (in a commonly used and machine readable form) and reuse Your Personal Data that You have provided to Us (via consent or contract performance) and which We process by automated means for Your own purposes across different services and free of charge. We must respond to a request without undue delay, and within one month whether or not We decide to action Your request. Where We decide not to, We shall inform You of Your further rights.
Read more guidance from the ICO.
|Rights related to automated decision making and profiling||Subject to any exceptions, We should not take a potentially damaging decision concerning You as a result of using automated processing operations without human intervention. We must ensure that You have the opportunity to:
Read more guidance from the ICO.
COMPLAINTS OR QUERIES
If You have a complaint about the way in which GGP has processed Your Personal Data or a general request for information about Our Privacy Statement or a Data Subject Access Request, please contact the person named in the introduction in writing or by email.
GGP tries to meet the highest standards when collecting and using Personal Data. For this reason, We take any complaints We receive about this very seriously. We encourage You to bring it to Our attention. We are happy to provide any additional information or explanation needed in respect of Our processing activities upon request. If You are still not happy with the way in which Your Personal Data is being processed by Us, please contact the UK’s supervisory authority to whom You can lodge a complaint – www.ico.org.uk.
DEFINITIONS & INTERPRETATIONS
Article 6(1)(a) GDPR: You have given Your consent to the processing of Your Personal Data for the specific purpose(s).
Article 6(1)(b) GDPR: the “processing is necessary for the performance of a contract”.
Article 6(1)(c) GDPR: processing is necessary for compliance with a legal obligation to which We as a Data Controller are subject.
Article 6(1)(d) GDPR: processing is necessary in order to protect the vital of You or another natural person.
Article 6(1)(e) GDPR: processing is necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in Us as a Data Controller.
Article 6(1)(f) GDPR: processing is necessary for the purposes of the legitimate interests pursued by Us as a Data Controller or by a third party and such interests are not overridden by Your interests or fundamental rights and freedoms of the data subject which require protection of Personal Data.
Data Subject Access Request or ‘DSAR’: refers to right of access as further described in the table at Clause 7.
Electronic Mail: includes email, text, video, voicemail, picture and answerphone messages (including push notifications.
Intellectual Property Rights: patents, rights to inventions, copyright and neighbouring and related rights, trademarks and service marks, business names and domain names, rights in get-up and trade dress, goodwill and the right to sue for passing off or unfair competition, rights in designs, database rights, rights to use, and protect the confidentiality of, confidential information (including know-how and trade secrets) and all other intellectual property rights, in each case whether registered or unregistered and including all applications and rights to apply for and be granted, renewals or extensions of, and rights to claim priority from, such rights and all similar or equivalent rights or forms of protection which subsist or will subsist now or in the future in any part of the world.
Marketing Communication(s): refers to any communication whether by an Electronic Mail method or otherwise that We send to You (either directly or via a GGP Service Provider) which may include but are not necessarily limited to relevant newsletters and magazines, information about opportunities, products, services and events and relevant information.
Non-Marketing Communication(s): refers to any communication which is functional/ administrative only and are not Marketing Communications.
Partner Organisation: refers to a third party (as distinct from GGP Service Provider) with whom We may share Your Personal Data from time to time subject to Your consent who may then contact You directly with Marketing Communications or Non-Marketing Communications subject to Your permission.
GGP Content: the content including all Intellectual Property Rights therein residing on the GGP Site (which may or may not include Personal Data).
GGP Services: refers to the GGP Services We may provide to You.
GGP Service Providers: refers to the external third party data processors (as distinct from Partner Organisations) with whom We work with from time to time as a necessary part of providing the GGP Services and with whom We therefore need to share Your Personal Data with from time to time which shall include professional and legal advisors GGP [insert Company Abbreviation] Site.
Special Category Data: is defined under Article 9 of the GDPR as personal data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, and the processing of genetic data, biometric data for the purpose of uniquely identifying a natural person, data concerning health or data concerning a natural person’s sex life or sexual orientation.
CHANGES TO THIS STATEMENT
We keep Our Statement under regular review. This Statement was last updated on 15th May 2018