CORTIBA HEALTH’S Privacy Policy
1. Introduction
1.1 Welcome to CORTIBA HEALTH’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 CORTIBA HEALTH 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
CORTIBA HEALTH, the trading name of Vertical Pharma Resources Ltd. Our trading name is CORTIBA HEALTH. We are the controller and responsible for our personal data. All companies with the CORTIBA HEALTH name, for more information about CORTIBA HEALTH, 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@cortibahealth.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 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 notdirectly 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.
11. Marketing
We strive to provide you with choices regarding certain personal data uses, particularly around marketing.
12. Promotional Offers From Us
You will receive marketing communications from us if you have requested information from us or signed up for such communications and, in each case, you have not opted out of receiving that marketing.
13. Opting Out
You can ask us or third parties to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you or by contacting us at any time.
14. 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 paragraph 23.
15. Change of Purpose
15.1 We will only use your personal 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 contact us.
15.2 If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
15.3 Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
16. Disclosures of Your Personal Data
16.1 We may have to share your personal data with the parties set out below for the purposes set out in the table in paragraph 10 above.
16.1.1 Internal Third Parties as set out in the Glossary.
16.1.2 External Third Parties as set out in the Glossary.
16.1.3 Third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy notice.
16.2 We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.
17. International Transfers
We do not transfer your personal data outside the European Economic Area.
18. Data Security
18.1 We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.
18.2 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.
19. Data Retention
19.1 We will only retain your personal 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.
19.2 To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.
19.3 Details of retention periods for different aspects of your personal data are available in our retention policy which you can request from us by contacting us.
19.4 In some circumstances you can ask us to delete your data: see [Request erasure] below for further information.
19.5 In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.
20. Your Legal Rights
20.1 Under certain circumstances, you have rights under data protection laws in relation to your personal data. If you wish to exercise any of the rights set out below after the Glossary please contact us.
20.2 No fee usually required
will not have to pay a fee to access your personal data (or to exercise any of the other rights). 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.
20.3 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 personal 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.
20.4 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 a number of requests. In this case, we will notify you and keep you updated.
GLOSSARY
21. Lawful Basis
Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.
Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.
Comply with a legal or regulatory obligation means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.
22. Third Parties
Internal Third Parties
Other companies in the CORTIBA HEALTH Group acting as joint controllers or processors and who are based in the UK and provide IT and system administration services and undertake leadership reporting.
External Third Parties
22.1 Service providers acting as processors based in the UK who provide IT and system administration services.
22.2 Professional advisers acting as processors or joint controllers including lawyers, bankers, auditors and insurers based in the United Kingdom who provide consultancy, banking, legal, insurance and accounting services.
22.3 HM Revenue & Customs, regulators and other authorities acting as processors or joint controllers based in the United Kingdom.
22.4 Financial Conduct Authority acting as processors or joint controllers based in the United Kingdom who require reporting of processing activities in certain circumstances or to whom it is necessary to provide information as part of our services.
Your legal rights
22.5 You have the right to:
22.5.1 Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
22.5.2 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.
22.5.3 Request erasure of your personal data. This enables you to ask us to delete or remove personal 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 personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal 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.
22.5.4 Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular 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 personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
22.5.5 Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
22.5.6 Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal 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.
22.5.7 Withdraw consent at any time where we are relying on consent to process your personal 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.
23 Cookies Policy – Information Vertical Pharma Resources Ltd collects from you.
23.1 What is a cookie? A cookie is a small amount of data, which often includes a unique identifier that is sent to your computer or mobile phone (referred to here as a “device”) browser from a website’s computer and is stored on your device’s hard drive. Each website can send its own cookie to your browser if your browser’s preferences allow it, but (to protect your privacy) your browser only permits a website to access the cookies it has already sent to you, not the cookies sent to you by other websites. Many websites do this whenever a user visits their website in order to track online traffic flows (statistics).
On Vertical Pharma Resources Ltd websites (www.cortibahealth.com) cookies record information about your online preferences and allow us to tailor the websites to your interests.
Users have the opportunity to set their devices to accept all cookies, to notify them when a cookie is issued, or not to receive cookies at any time. The last of these means that certain personalised features cannot then be provided to that user and accordingly they may not be able to take full advantage of all of the website’s features. Each browser is different, so check the “Help” menu of your browser to learn how to change your cookie preferences.
During the course of any visit to an Vertical Pharma Resources Ltd website, the pages you see, along with a cookie, are downloaded to your device. Many websites do this, because cookies enable website publishers to do useful things like find out whether the device (and probably its user) has visited the website before. This is done on a repeat visit by checking to see, and finding, the cookie left there on the last visit.
23.2 How does Vertical Pharma Resources Ltd use cookies? Information supplied by cookies can help us to analyse the profile of our visitors and help us to provide you with a better user experience. For example, if on a previous visit you went to our services pages, we might find this out from your cookie and highlight service information on your second and subsequent visits.
23.3 Third Party Cookies on Vertical Pharma Resources Ltd pages
Please note that during your visits to Vertical Pharma Resources Ltd websites you may notice some cookies that are not related to Vertical Pharma Resources Ltd. When you visit a page with content embedded from, for example, YouTube or Flickr, you may be presented with cookies from these websites. Vertical Pharma Resources Ltd does not control the dissemination of these cookies. You should check the third party websites for more information about these.
23.4 Vertical Pharma Resources Ltd cookies and how to reject cookies? A list of the main cookies that the Vertical Pharma Resources Ltd websites set (and what each is used for) together with ways to minimise the number of cookies you receive can be found on paragraph 23.4.1.
23.4.1 How to control and delete cookies
Vertical Pharma Resources Ltd will not use cookies to collect personally identifiable information about you. However, if you wish to restrict or block the cookies which are set by Vertical Pharma Resources Ltd websites, or indeed any other website, you can do this through your browser settings. The Help function within your browser should tell you how.
Please be aware that restricting cookies may impact on the functionality of Vertical Pharma Resources Ltd websites.
If you wish to view your cookie code, just click on a cookie to open it. You’ll see a short string of text and numbers. The numbers are your identification card, which can only be seen by the server that gave you the cookie.
For information on how to do this on the browser of your mobile phone you will need to refer to your handset manual.
23.4.2 Third Party Cookies
To support our services, we sometimes embed photos and video content from websites such as YouTube and Flickr. As a result, when you visit a page with content embedded from, for example, YouTube or Flickr, you may be presented with cookies from these websites. Vertical Pharma Resources Ltd does not control the dissemination of these cookies. You should check the third party websites for more information about these.
Google Analytics
Vertical Pharma Resources Ltd uses Google Analytics, a web analytics service provided by Google, Inc. Google Analytics sets a cookie in order to evaluate your use of website(s) and compile reports for us on website activity.
Google stores the information collected by the cookie on servers in the United States. Google may also transfer this information to third parties where required to do so by law, or where such third parties process the information on Google’s behalf. Google will not associate your IP address with any other data held by Google.
By using our website, you consent to the processing of data about you by Google in the manner and for the purposes set out above.
For more information on the cookie set by Google Analytics, including information on how to opt out please go to: https://www.google.com/intl/en/privacypolicy.html
23.4.3 List of the main Vertical Pharma Resources Ltd cookies
This is a list of the main cookies set by the www.cortibahealth.com website, and what each is used for:
uit,di,dt,uid,_utavc,bt2,loc –
This set of cookies third party cookies supplied by addthis to enable you to share our content via social networks such as facebook, twitter and linked in, these cookies are required to enable logins to each network.
.ASPXANONYMOUS
This cookie stores a session ID for users who have not registered and logged in to the website to view standard website content.
ASP.NET SessionID
This cookie is set by ASP.NET and stores the identifier of the currentuser’s session i.e. Every time a user visits the website, they have a unique session ID. This stops page requests from being seen as independent requests, but part of a string of requests. This lasts for the user’s current session only. A session is defined as the period of time that a unique user interacts with a Web application.
_RequestVerfificationToken
This cookie is generated by ASP.NET MVC and is designed to protect our website against malicious form post attacks.
The __utma Cookie
This cookie is what’s called a “persistent” cookie, as in, it never expires (technically, it does expire…in the year 2038). This cookie keeps track of the number of times a visitor has been to the site according to the cookie, when their first visit was, and when their last visit occurred. Google Analytics uses the information from this cookie to calculate statistics such as visits per day.
The __utmb and __utmc Cookies
The B and C cookies work together to calculate how long a visit takes. __utmb takes a timestamp of the exact moment in time when a visitor enters a site, while __utmc takes a timestamp of the exact moment in time when a visitor leaves a site. __utmb expires at the end of the session. __utmc waits 30 minutes, and then it expires.
The __utmz Cookie
__utmz keeps track of where the visitor came from, what search engine they used, what link they clicked on, what keyword they used, and where they were in the world when they accessed a website. It expires in 15,768,000 seconds – or, in 6 months. This cookie is how Google Analytics knows to whom and to what source / medium / keyword to assign the credit for a Goal Conversion.
The _ga Cookie
This cookie is used by Google Analytics to distinguish users, it has an expiration time of 2 years
The _gat Cookei
This cookie is used by Google Analytics to reduce the amount of requests sent. It has an expiration time of 10 minutes
StayInEditMode
This is a functional administration cookie that really only affects logged in users and administrators of the website, ensuring that the correct mode “edit mode” is the default setting for making website changes.
LastPageID
This cookie identifies the last page that was visited.
authentication
This cookie stores a session ID for users who have not registered and logged in to the website to view standard website content.
language
Stores user location to deliver country specific content.
CookieDirective
This cookie is used to identify when the cookie directive warning should be displayed to a new visitor when they enter the website. It will continue to show until the user accepts the notice.
Last updated 5th November 2020
1. Introduction
1.1 Welcome to CORTIBA HEALTH’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 CORTIBA HEALTH 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
CORTIBA HEALTH, the trading name of Vertical Pharma Resources Ltd. Our trading name is CORTIBA HEALTH. We are the controller and responsible for our personal data. All companies with the CORTIBA HEALTH name, for more information about CORTIBA HEALTH, 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@cortibahealth.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 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 notdirectly 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.
| Purpose/Activity | Type of data | Lawful basis for processing including basis of legitimate interest |
| To register you as a new customer | Identity Contact | Performance of a contract with you |
| To comply with our legal obligations before supplying certain products | Identity Contact Data related to your health | · Necessary to comply with a legal obligation · Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services) |
| To manage our relationship with you which will include: (a) notifying you about changes to our terms or privacy policy (b) asking you to leave a review or take a survey | Identity Contact Profile Marketing and Communications | Performance of a contract with you · Necessary to comply with a legal obligation · Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services) |
| To enable you to complete a survey | Identity Contact Profile Usage Marketing and Communications | · Performance of a contract with you · Necessary for our legitimate interests |
| To administer and protect our business and our website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data) | Identity Contact Technical | · Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise) · Necessary to comply with a legal obligation |
| To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you | Identity Contact Profile Usage Marketing and Communications Technical | Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy) |
| To use data analytics to improve our website, products/services, marketing, customer relationships and experiences | Technical Usage | Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy) |
11. Marketing
We strive to provide you with choices regarding certain personal data uses, particularly around marketing.
12. Promotional Offers From Us
You will receive marketing communications from us if you have requested information from us or signed up for such communications and, in each case, you have not opted out of receiving that marketing.
13. Opting Out
You can ask us or third parties to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you or by contacting us at any time.
14. 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 paragraph 23.
15. Change of Purpose
15.1 We will only use your personal 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 contact us.
15.2 If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
15.3 Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
16. Disclosures of Your Personal Data
16.1 We may have to share your personal data with the parties set out below for the purposes set out in the table in paragraph 10 above.
16.1.1 Internal Third Parties as set out in the Glossary.
16.1.2 External Third Parties as set out in the Glossary.
16.1.3 Third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy notice.
16.2 We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.
17. International Transfers
We do not transfer your personal data outside the European Economic Area.
18. Data Security
18.1 We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.
18.2 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.
19. Data Retention
19.1 We will only retain your personal 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.
19.2 To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.
19.3 Details of retention periods for different aspects of your personal data are available in our retention policy which you can request from us by contacting us.
19.4 In some circumstances you can ask us to delete your data: see [Request erasure] below for further information.
19.5 In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.
20. Your Legal Rights
20.1 Under certain circumstances, you have rights under data protection laws in relation to your personal data. If you wish to exercise any of the rights set out below after the Glossary please contact us.
20.2 No fee usually required
will not have to pay a fee to access your personal data (or to exercise any of the other rights). 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.
20.3 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 personal 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.
20.4 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 a number of requests. In this case, we will notify you and keep you updated.
GLOSSARY
21. Lawful Basis
Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.
Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.
Comply with a legal or regulatory obligation means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.
22. Third Parties
Internal Third Parties
Other companies in the CORTIBA HEALTH Group acting as joint controllers or processors and who are based in the UK and provide IT and system administration services and undertake leadership reporting.
External Third Parties
22.1 Service providers acting as processors based in the UK who provide IT and system administration services.
22.2 Professional advisers acting as processors or joint controllers including lawyers, bankers, auditors and insurers based in the United Kingdom who provide consultancy, banking, legal, insurance and accounting services.
22.3 HM Revenue & Customs, regulators and other authorities acting as processors or joint controllers based in the United Kingdom.
22.4 Financial Conduct Authority acting as processors or joint controllers based in the United Kingdom who require reporting of processing activities in certain circumstances or to whom it is necessary to provide information as part of our services.
Your legal rights
22.5 You have the right to:
22.5.1 Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
22.5.2 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.
22.5.3 Request erasure of your personal data. This enables you to ask us to delete or remove personal 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 personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal 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.
22.5.4 Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular 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 personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
22.5.5 Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
22.5.6 Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal 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.
22.5.7 Withdraw consent at any time where we are relying on consent to process your personal 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.
23 Cookies Policy – Information Vertical Pharma Resources Ltd collects from you.
23.1 What is a cookie? A cookie is a small amount of data, which often includes a unique identifier that is sent to your computer or mobile phone (referred to here as a “device”) browser from a website’s computer and is stored on your device’s hard drive. Each website can send its own cookie to your browser if your browser’s preferences allow it, but (to protect your privacy) your browser only permits a website to access the cookies it has already sent to you, not the cookies sent to you by other websites. Many websites do this whenever a user visits their website in order to track online traffic flows (statistics).
On Vertical Pharma Resources Ltd websites (www.cortibahealth.com) cookies record information about your online preferences and allow us to tailor the websites to your interests.
Users have the opportunity to set their devices to accept all cookies, to notify them when a cookie is issued, or not to receive cookies at any time. The last of these means that certain personalised features cannot then be provided to that user and accordingly they may not be able to take full advantage of all of the website’s features. Each browser is different, so check the “Help” menu of your browser to learn how to change your cookie preferences.
During the course of any visit to an Vertical Pharma Resources Ltd website, the pages you see, along with a cookie, are downloaded to your device. Many websites do this, because cookies enable website publishers to do useful things like find out whether the device (and probably its user) has visited the website before. This is done on a repeat visit by checking to see, and finding, the cookie left there on the last visit.
23.2 How does Vertical Pharma Resources Ltd use cookies? Information supplied by cookies can help us to analyse the profile of our visitors and help us to provide you with a better user experience. For example, if on a previous visit you went to our services pages, we might find this out from your cookie and highlight service information on your second and subsequent visits.
23.3 Third Party Cookies on Vertical Pharma Resources Ltd pages
Please note that during your visits to Vertical Pharma Resources Ltd websites you may notice some cookies that are not related to Vertical Pharma Resources Ltd. When you visit a page with content embedded from, for example, YouTube or Flickr, you may be presented with cookies from these websites. Vertical Pharma Resources Ltd does not control the dissemination of these cookies. You should check the third party websites for more information about these.
23.4 Vertical Pharma Resources Ltd cookies and how to reject cookies? A list of the main cookies that the Vertical Pharma Resources Ltd websites set (and what each is used for) together with ways to minimise the number of cookies you receive can be found on paragraph 23.4.1.
23.4.1 How to control and delete cookies
Vertical Pharma Resources Ltd will not use cookies to collect personally identifiable information about you. However, if you wish to restrict or block the cookies which are set by Vertical Pharma Resources Ltd websites, or indeed any other website, you can do this through your browser settings. The Help function within your browser should tell you how.
Please be aware that restricting cookies may impact on the functionality of Vertical Pharma Resources Ltd websites.
If you wish to view your cookie code, just click on a cookie to open it. You’ll see a short string of text and numbers. The numbers are your identification card, which can only be seen by the server that gave you the cookie.
For information on how to do this on the browser of your mobile phone you will need to refer to your handset manual.
23.4.2 Third Party Cookies
To support our services, we sometimes embed photos and video content from websites such as YouTube and Flickr. As a result, when you visit a page with content embedded from, for example, YouTube or Flickr, you may be presented with cookies from these websites. Vertical Pharma Resources Ltd does not control the dissemination of these cookies. You should check the third party websites for more information about these.
Google Analytics
Vertical Pharma Resources Ltd uses Google Analytics, a web analytics service provided by Google, Inc. Google Analytics sets a cookie in order to evaluate your use of website(s) and compile reports for us on website activity.
Google stores the information collected by the cookie on servers in the United States. Google may also transfer this information to third parties where required to do so by law, or where such third parties process the information on Google’s behalf. Google will not associate your IP address with any other data held by Google.
By using our website, you consent to the processing of data about you by Google in the manner and for the purposes set out above.
For more information on the cookie set by Google Analytics, including information on how to opt out please go to: https://www.google.com/intl/en/privacypolicy.html
23.4.3 List of the main Vertical Pharma Resources Ltd cookies
This is a list of the main cookies set by the www.cortibahealth.com website, and what each is used for:
uit,di,dt,uid,_utavc,bt2,loc –
This set of cookies third party cookies supplied by addthis to enable you to share our content via social networks such as facebook, twitter and linked in, these cookies are required to enable logins to each network.
.ASPXANONYMOUS
This cookie stores a session ID for users who have not registered and logged in to the website to view standard website content.
ASP.NET SessionID
This cookie is set by ASP.NET and stores the identifier of the currentuser’s session i.e. Every time a user visits the website, they have a unique session ID. This stops page requests from being seen as independent requests, but part of a string of requests. This lasts for the user’s current session only. A session is defined as the period of time that a unique user interacts with a Web application.
_RequestVerfificationToken
This cookie is generated by ASP.NET MVC and is designed to protect our website against malicious form post attacks.
The __utma Cookie
This cookie is what’s called a “persistent” cookie, as in, it never expires (technically, it does expire…in the year 2038). This cookie keeps track of the number of times a visitor has been to the site according to the cookie, when their first visit was, and when their last visit occurred. Google Analytics uses the information from this cookie to calculate statistics such as visits per day.
The __utmb and __utmc Cookies
The B and C cookies work together to calculate how long a visit takes. __utmb takes a timestamp of the exact moment in time when a visitor enters a site, while __utmc takes a timestamp of the exact moment in time when a visitor leaves a site. __utmb expires at the end of the session. __utmc waits 30 minutes, and then it expires.
The __utmz Cookie
__utmz keeps track of where the visitor came from, what search engine they used, what link they clicked on, what keyword they used, and where they were in the world when they accessed a website. It expires in 15,768,000 seconds – or, in 6 months. This cookie is how Google Analytics knows to whom and to what source / medium / keyword to assign the credit for a Goal Conversion.
The _ga Cookie
This cookie is used by Google Analytics to distinguish users, it has an expiration time of 2 years
The _gat Cookei
This cookie is used by Google Analytics to reduce the amount of requests sent. It has an expiration time of 10 minutes
StayInEditMode
This is a functional administration cookie that really only affects logged in users and administrators of the website, ensuring that the correct mode “edit mode” is the default setting for making website changes.
LastPageID
This cookie identifies the last page that was visited.
authentication
This cookie stores a session ID for users who have not registered and logged in to the website to view standard website content.
language
Stores user location to deliver country specific content.
CookieDirective
This cookie is used to identify when the cookie directive warning should be displayed to a new visitor when they enter the website. It will continue to show until the user accepts the notice.
Last updated 5th November 2020
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