This is our CURRENT policy and was Last Revised on the 28/02/2022. For further information on our policies please Contact Us.
- 1. Definitions and Interpretation
- 2. Information About Us
- 3. Scope – What Does This Policy Cover?
- 4. What Data Do We Collect?
- 5. How Do We Use Your Data?
- 6. How and Where Do We Store Your Data?
- 7. Do We Share Your Data?
- 8. What Happens If Our Business Changes Hands?
- 9. How Can You Control Your Data?
- 10. Your Right to Withhold Information and Your Right to Withdraw Information After You Have Given it
- 11. How Can You Access Your Data?
- 12. What Cookies Do We Use and What For?
- 13. Summary of Your Rights under GDPR
- 14. Automated Decision-Making and Profiling
- 15. Contacting Us
- INFORMATION YOU PROVIDE
- INFORMATION THAT MAY BE COLLECTED
- Third Party Information
- HOW WE USE YOUR DATA
Optimale Ltd understands that your privacy is important to you and that you care about how your information is used and shared online. We respect and value the privacy of everyone who visits Our Site and will only collect and use information in ways that are useful to you and in a manner consistent with your rights and Our obligations under the law.
1. Definitions and Interpretation
In this Policy the following terms shall have the following meanings:
- “Account” means an account required to access and/or use certain areas and features of Our Site;
- “Cookie” means a small text file placed on your computer or device by Our Site when you visit certain parts of Our Site and/or when you use certain features of Our Site. Details of the Cookies used by Our Site are set out in section 12, below;
- “Our Site” means this website, www.optimale.co.uk, and your Client Space, which you may access through a separate URL link provided by Optimale;
- “United Kingdom and EU Cookie Law” means the relevant parts of the Privacy and Electronic Communications (EC Directive) Regulations 2003 as amended in 2004, 2011 and 2015; and
- “We/Us/Our” Means Optimale Ltd, a limited company registered in England under company number 10878576, whose registered address is 71-75 Shelton Street, London, WC2H 9JQ and whose main trading address is 71-75 Shelton Street, London, WC2H 9JQ.
2. Information About Us
2.1 Our Site, www.optimale.co.uk, is owned and operated by Optimale Ltd, a limited company registered in England under company number 10878576, whose registered address is 71-75 Shelton Street, London, WC2H 9JQ and whose main trading address is 71-75 Shelton Street, London, WC2H 9JQ.
2.2 Optimale is a website via which individuals in the UK (Customer, Customers, you, your, yourself) may contact participating doctors registered with the UK General Medical Council: www.gmc-uk.org, (the GMC) (known as Practitioners), and may purchase the Services that we provide including blood testing services, consultations and access to private medical treatment.
2.3 Our data protection officer is David Kennett who can be contacted at [email protected]
2.4 We are registered with the Information Commissioner’s Office under registration reference ZA290266.
3. Scope – What Does This Policy Cover?
4. What Data Do We Collect?
4.3 Date of Birth;
4.4 Contact information such as email addresses and telephone numbers;
4.5 Questionnaire results which may be linked to a medical condition;
4.6 IP address (automatically collected);
4.7 web browser type and version (automatically collected);
4.8 operating system (automatically collected);
4.9 a list of URLs starting with a referring site, your activity on Our Site, and the site you exit to (automatically collected).
When signing up for our services, we process personal information about you because we have a contract with you to make available our Services. We need that personal information to carry out our obligations under that contract.
5. How Do We Use Your Data?
5.1 All personal data is stored securely in accordance with the EU General Data Protection Regulation (Regulation (EU) 2016/679) (GDPR). For more details on security see section 6, below.
5.2 We use your data to provide the best possible services to you. This includes:
5.2.1 Providing and managing your Account;
5.2.2 Providing and managing your access to Our Site;
5.2.3 Personalising and tailoring your experience on Our Site;
5.2.4 Supplying Our services to you;
5.2.5 Personalising and tailoring Our services for you;
5.2.6 Responding to communications from you;
5.2.7 Supplying you with email newsletters, alerts etc. that you have subscribed to (you may unsubscribe or opt-out at any time);
5.2.8 Market research;
5.2.9 Analysing your use of Our Site [and gathering feedback] to enable Us to continually improve Our Site and your user experience;
5.3 In some cases, the collection of data may be a statutory or contractual requirement, and We will be limited in the services We can provide you without your consent for Us to be able to use such data.
5.4 With your permission and/or where permitted by law, We may also use your data for marketing purposes which may include contacting you by email, telephone and/or post with information, news and offers on Our services. We will not, however, send you any unsolicited marketing or spam and will take all reasonable steps to ensure that We fully protect your rights and comply with Our obligations under the GDPR and the Privacy and Electronic Communications (EC Directive) Regulations 2003, as amended in 2004, 2011 and 2015.
5.5 Under GDPR we will ensure that your personal data is processed lawfully, fairly, and transparently, without adversely affecting your rights. We will only process your personal data if at least one of the following basis applies:
a) you have given consent to the processing of your personal data for one or more specific purposes;
b) processing is necessary for the performance of a contract to which you are a party or in order to take steps at the request of you prior to entering into a contract;
c) processing is necessary for compliance with a legal obligation to which we are subject;
d) processing is necessary to protect the vital interests of you or of another natural person;
e) processing is necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller; and/or
f) processing is necessary for the purposes of the legitimate interests pursued by us or by a third party, except where such interests are overridden by the fundamental rights and freedoms of the data subject which require protection of personal data, in particular where the data subject is a child.
6. How and Where Do We Store Your Data?
6.1 We only keep your data for as long as We need to in order to use it as described above in section 5, and/or for as long as We have your permission to keep it. In any event, We will conduct an annual review to ascertain whether we need to keep your data. Your data will be deleted if we no longer need it in accordance with the terms of our Data Retention Policy.
6.2 Some or all of your data may be stored or transferred outside of the European Economic Area (“the EEA”) (The EEA consists of all EU member states, plus Norway, Iceland and Liechtenstein). You are deemed to accept and agree to this by using Our Site and submitting information to Us. If We do store or transfer data outside the EEA, We will take all reasonable steps to ensure that your data is treated as safely and securely as it would be within the EEA and under the GDPR. Such steps may include, but not be limited to, the use of legally binding contractual terms between Us and any third parties We engage and the use of the EU-approved Model Contractual Arrangements.
6.3 Data security is of great importance to Us, and to protect your data We have put in place suitable physical, electronic and managerial procedures to safeguard and secure data collected through Our Site.
6.4 Notwithstanding the security measures that We take, it is important to remember that the transmission of data via the internet may not be completely secure and that you are advised to take suitable precautions when transmitting to Us data via the internet.
7. Do We Share Your Data?
7.1 We may contract with third parties to supply services to you on Our behalf. These may include medical practitioners, blood testing laboratories, phlebotomy services, NHS clinics, private medical clinics, payment processors, delivery services, search engines, advertisers and marketers. In some cases, the third parties may require access to some or all of your data. Where any of your data is required for such a purpose, We will take all reasonable steps to ensure that your data will be handled safely, securely, and in accordance with your rights, Our obligations, and the obligations of the third party under the law.
7.2 We may compile statistics about the use of Our Site including data on traffic, usage patterns, user numbers, sales and other information. All such data will be anonymised and will not include any personally identifying information. We may from time to time share such data with third parties such as prospective investors, affiliates, partners and advertisers. Data will only be shared and used within the bounds of the law.
7.3 In certain circumstances We may be legally required to share certain data held by Us, which may include your personal information, for example, where We are involved in legal proceedings, where We are complying with the requirements of legislation, a court order, or a governmental authority. We do not require any further consent from you in order to share your data in such circumstances and will comply as required with any legally binding request that is made of Us.
8. What Happens If Our Business Changes Hands?
8.2 In the event that any of your data is to be transferred in such a manner, you will be contacted in advance and informed of the changes.
9. How Can You Control Your Data?
9.1 When you submit information via Our Site, you may be given options to restrict Our use of your data. We aim to give you strong controls on Our use of your data (including the ability to opt-out of receiving emails from Us which you may do by unsubscribing using the links provided in Our emails.
9.2 You may also wish to sign up to one or more of the preference services operating in the United Kingdom: The Telephone Preference Service (“the TPS”), the Corporate Telephone Preference Service (“the CTPS”), and the Mailing Preference Service (“the MPS”). These may help to prevent you receiving unsolicited marketing. Please note, however, that these services will not prevent you from receiving marketing communications that you have consented to receiving.
10. Your Right to Withhold Information and Your Right to Withdraw Information After You Have Given it
10.1 You may access Our Site without providing any data at all. However, to use all features and functions available on Our Site you may be required to submit or allow for the collection of certain data.
10.3 You may withdraw your consent for Us to use your personal data as set out in section in 5 at any time by contacting Us using the details set out in section 15, and We will delete Your data from Our systems. However, you acknowledge this may limit Our ability to provide the best possible services to you.
11. How Can You Access Your Data?
You have the legal right to ask for a copy of any of your personal data held by Us (where such data is held). Please contact us for more details at [email protected] or using the contact details below in section 15.
12. What Cookies Do We Use and What For?
12.2 By using Our Site you may also receive certain third party Cookies on your computer or device. Third party Cookies are those placed by websites, services, and/or parties other than Us. We use third party Cookies on Our Site for marketing, research and analysis purposes. For more details, please refer to section 5, above, and to section 12.6 below. These Cookies are not integral to the functioning of Our Site.
12.3 All Cookies used by and on Our Site are used in accordance with current English and EU Cookie Law.
12.4 Before Cookies are placed on your computer or device, subject to section 12.5 and section 12.8, you will be shown a pop-up cookie consent bar requesting your consent to set those Cookies. By giving your consent to the placing of Cookies you are enabling Us to provide the best possible experience and service to you. You may, if you wish, deny consent to the placing of Cookies; however certain features of Our Site may not function fully or as intended.
12.5 Certain features of Our Site depend on Cookies to function. The United Kingdom and EU Cookie Law deems these Cookies to be “strictly necessary”. These Cookies are shown below in section 12.6. Your consent will not be sought to place these Cookies. You may still block these Cookies by changing your internet browser’s settings as detailed below in section 12.10, but please be aware that Our Site may not work as intended if you do so. We have taken great care to ensure that your privacy is not at risk by allowing them.
12.6 The following first party Cookies may be placed on your computer or device:
|Name of Cookie||Purpose||Strictly Necessary|
|__cfduid||Used by our content delivery network to identify trusted traffic/visitors||Yes|
|PHPSESSID||Preserves the user’s session state across page requests.||Yes|
and the following third party Cookies may be placed on your computer or device:
|Name of Cookie||Provider||Purpose|
|_ga||Google Analytics||Registers a unique user ID to generate statistical data on how the visitor uses the website.|
|_gat||Google Analytics||Used by Google Analytics to throttle request rate.|
|_gid||Google Analytics||Registers a unique user ID to generate statistical data on how the visitor uses the website.|
|collect||Google Analytics||Used to send data to Google Analytics about the visitor’s device and behaviour. Tracks the visitor across devices and marketing channels.|
12.7 Our Site uses analytics services provided by Google Analytics. Website analytics refers to a set of tools used to collect and analyse usage statistics, enabling Us to better understand how people use Our Site. This, in turn, enables Us to improve Our Site and the services offered through it. You do not have to allow Us to use these Cookies, as detailed below, however whilst Our use of them does not pose any risk to your privacy or your safe use of Our Site, it does enable Us to continually improve Our Site, making it a better and more useful experience for you.
12.8 The analytics service(s) used by Our Site use(s) Cookies to gather the required Certain of these Cookies may be placed immediately when you first visit Our Site and it may not be possible for Us to obtain your prior consent. You may remove these Cookies and prevent future use of them by following the steps set out below in section 12.10.
The analytics service(s) used by Our Site use(s) the following Cookies:
|Name of Cookie||First / Third Party||Provider||Purpose|
|_ga||Third Party||Google Analytics||Registers a unique user ID to generate statistical data on how the visitor uses the website.|
|_gat||Third Party||Google Analytics||Used by Google Analytics to throttle request rate.|
|_gid||Third Party||Google Analytics||Registers a unique user ID to generate statistical data on how the visitor uses the website.|
|collect||Third Party||Google Analytics||Used to send data to Google Analytics about the visitor’s device and behaviour. Tracks the visitor across devices and marketing channels.|
12.10 You can choose to enable or disable Cookies in your internet browser. Most internet browsers also enable you to choose whether you wish to disable all cookies or only third party cookies. By default, most internet browsers accept Cookies but this can be changed. For further details, please consult the help menu in your internet browser or the documentation that came with your device.
12.11 You can choose to delete Cookies at any time however you may lose any information that enables you to access Our Site more quickly and efficiently including, but not limited to, login and personalisation settings.
12.12 It is recommended that you keep your internet browser and operating system up-to-date and that you consult the help and guidance provided by the developer of your internet browser and manufacturer of your computer or device if you are unsure about adjusting your privacy settings.
13. Summary of Your Rights under GDPR
Under the GDPR, you have:
13.1 the right to request access to, deletion of or correction of, your personal data held by Us;
13.2 the right to complain to a supervisory authority;
13.3 be informed of what data processing is taking place;
13.4 the right to restrict processing;
13.5 the right to data portability;
13.6 object to processing of your personal data;
13.7 rights with respect to automated decision-making and profiling (see section 14 below).
14. Automated Decision-Making and Profiling
14.1 In the event that We use personal data for the purposes of automated decision-making and those decisions have a legal (or similarly significant effect) on You, You have the right to challenge to such decisions under GDPR, requesting human intervention, expressing their own point of view, and obtaining an explanation of the decision from Us.
14.2 The right described in section 14.1 does not apply in the following circumstances:
a) The decision is necessary for the entry into, or performance of, a contract between the You and Us;
b) The decision is authorised by law; or
c) You have given you explicit consent.
14.3 Where We use your personal data for profiling purposes, the following shall apply:
a) Clear information explaining the profiling will be provided, including its significance and the likely consequences;
b) Appropriate mathematical or statistical procedures will be used;
c) Technical and organisational measures necessary to minimise the risk of errors and to enable such errors to be easily corrected shall be implemented; and
d) All personal data processed for profiling purposes shall be secured in order to prevent discriminatory effects arising out of profiling.
14.4 We currently make the following automated decisions:
14.5 We currently profile your personal data for the following purposes:
15. Contacting Us
INFORMATION YOU PROVIDE
In order to complete a questionnaire, order a blood test or report a problem with the Website or use the Services, you may be asked to provide personal details such as your name, address, date of birth, age, e-mail address and phone number, the Device’s phone number, username, password and other registration information, financial and credit card information, personal description and/or photograph for identification purposes.
The first time you log in to the Client Space you will be asked to create an online account (Account). To create an Account, you must provide Personal Data that will be shared with Practitioners and members of the Optimale team (from time to time, as required) who have been appropriately checked (including DBS checked) to ensure they meet the requirements to access such information (in accordance with UK law). After you create your Account you can use the same details to log in to the Client Space and use the Services.
Optimale creates a record of the consultations, care/advice and Services you receive via the Website and Client Space. Some examples of the information collected or created through this process are electronic medical records that may be uploaded by you or created as a result of your use of the Services.
When you use Optimale to consult with Practitioners we will collect debit and/or credit card information, which is maintained by our billing processing partner in a secure vault (compliant with the payment card industry security standard) for use when you decide to utilise any Services.
INFORMATION THAT MAY BE COLLECTED
Each time you use the Website we may automatically collect the following information:
- technical information, including the type of device (mobile or tablet) you are using, the temporary or persistent unique device identifiers (UDIDs) placed by us or our service providers, the unique identifier assigned by Optimale to your Device, the I.P. address of your Device, your mobile operating system, the type of mobile internet browsers you use and data about the way you use our Website or Client Space (Device Information);
- information about your visit, including the full uniform resource locators (URL) clickstream to, through and from the Website (including date and time); Services you viewed or searched for; page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks and mouse-overs), consultation length(s), recurrence of visits and other interaction information, methods used to browse away from the page and any phone number used to call our customer service number (Website Information);
- when you install or uninstall a Service containing a unique application number or when such a Service searches for automatic updates, that number and information about your installation, for example, the type of operating system, may be sent to us (Unique Application Numbers);
- information stored on your Device, including contact information, login information, photos, videos or other digital content and check ins (Content Information);
- details of your use of the Website including, but not limited to, traffic data, weblogs and other communication data, whether this is required for our own billing purposes or otherwise, and the resources that you access (Log Information); and
- if you contact us, we may keep a record of that correspondence.
Third Party Information
We are working closely with third parties (including, for example, private UK GMC doctors, local NHS practices and community services, business partners, sub-contractors in technical, payment and delivery services, advertising networks, analytics providers, search information providers, credit reference agencies) and may receive information about you from them.
We may associate any category of information with any other category of information and will treat the combined information as Personal Data in accordance with this policy for as long as it is combined.
HOW WE USE YOUR DATA
We need the personal information we collect in order to provide you with the Services and to send you essential information about the Services (where you ask us to send you such information) and to help us with the operation of the Website and Service. Here are some typical examples:
- to carry out our obligations arising from any contracts entered into between you and us and to provide you with the information and Services that you request from us;
- to notify you about changes to the Website, Client Space and/or Services;
- to ensure that content from the Website/Client Space is presented in the most effective manner for you and your computer or Device;
- to undertake planning, Service evolution, new product development, Service delivery, marketing, internal and external performance indicators and a range of other business intelligence functions;
- to administer our site and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes;
- to allow you to participate in interactive features of the Services;
- to measure or understand the effectiveness of advertising we serve to you and others, and to deliver relevant advertising to you;
- to make suggestions and recommendations to you and other users of the Website/Client Space about goods or services that may interest you or them; and
- to respond to any queries you raise with us and to provide customer support.
In addition to the above, your email address, mobile telephone number and other contact information that you provide via your Account may also be used by Optimale to enable your use of the Services. Optimale will use your email address and mobile number as the joint primary means to reset your username and password.
You have the right to ask us to restrict processing of your personal data and a right to object to our processing of your personal data in this way, but if you do either of these, it may impact on your use of the Services and/or we may not be able to provide you with information about the Services that you have requested us to provide to you.
For example, we may send you email feedback forms to complete about us or any aspect of the website and/or the Services. We may also use it to provide you, or permit selected third parties to provide you, with information about goods or services we feel may interest you. If you are an existing customer, we will only contact you by electronic means (e-mail or SMS) with information about goods and services similar to those which were the subject of a previous transaction. If you are a new customer, and where we permit selected third parties to use your data, we (or they) will contact you by electronic means only if you have consented to this. If you do not want us to use your data in this way, or to pass your details on to third parties for marketing purposes, please Contact Us.
WHO DO WE SHARE YOUR PERSONAL DATA WITH?
For example, we may disclose your personal information to the following third party data processors:
- We may disclose or otherwise make available Personal Data about you to service providers that assist the function of the Website/Client Space. These service providers may collect device-specific data, such as a UDID, when you use our Website/Client Space. This data will not be associated in any way with your Account or any Personal Data that identifies who you are; we use this UDID to improve our Website and Services.
- Your email address and mobile number may be shared with third parties working with Optimale in the delivery and development of the Services and the Website/Client Space, to track usage, and these details may be used to advertise new Optimale services to you from time to time.
- You should also know that we work with third party analytics companies to discover how we can improve, update and change the Website and Client Space. Such third parties may therefore gain access to your Personal Data (but not any medical records). If you do not consent to such use of Personal Data, please do not use the Website or Client Space.
In addition to the above, we may share your personal data with the following third parties:
- In the event that we sell or buy any business or assets, in which case we may disclose your personal data to the prospective buyer or seller.
- If Optimale or substantially all of its assets are acquired by a third party, in which case personal data held by it about its customers will be one of the transferred assets.
- If we are under a duty to disclose or share your personal data in order to comply with any legal or regulatory obligation or request.
- In order to:
- enforce or apply the Terms and Conditions or to investigate potential breaches; or
- protect the rights, property or safety of Optimale, our customers or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction.
SENSITIVE PERSONAL DATA
In order to participate in the Services, you will need to provide health information about yourself to Optimale and the Practitioner(s) such as: your NHS or other medical records; measurements, such as weight, blood pressure or glucose levels; test results; health history, family history and other health information, such as medication information. This is classed as sensitive personal data under the Data Protection Act 1998.
Information that Practitioners on the Website or Client Space record in your online notes (your Electronic Medical Records or EMRs) will include relevant and pertinent information that you have discussed with Practitioners on the Client Space. Such EMRs may also include Practitioners’ comments, diagnoses and commentary as well as factual information, medical advice and the symptoms that you have presented with in a session. We will also collect and process demographic information about you (where available) such as your age, location, gender and income. To protect your EMRs we may print hard copies and place these in a secure vault environment at regular intervals throughout the year.
HOW INFORMATION ABOUT YOU MAY BE USED BY OPTIMALE
Use and Disclosure of Sensitive Personal Data
Optimale may gather sensitive personal data, as described above, to share with Practitioners for the purposes of diagnosis, treatment and health care operations. Optimale may also use aggregated, anonymised data sets of unidentifiable, non-personal information for: (i) statistical analysis, improvement of the Services and customisation of UX-design and content layout or creation; or (ii) sharing with government agencies or regulators that oversee and monitor health care providers in both the public and private sectors.
Further, Optimale is permitted to use and disclose your sensitive personal data for purposes of: (a) treatment; and (b) to enable medical service provision, as follows:
Optimale may use or disclose your personal health information to facilitate treatment or the provision of medical services by a Practitioner. Optimale may share your sensitive personal data with doctors, technicians or Optimale employees, as required to fulfil its contractual obligations to you. For example, departments may share your personal health information to plan your care. This may include prescriptions, lab work, other digitised / digital health information that you make available to us about you from time to time. Optimale will make all reasonable endeavours to procure that such persons securely store, transmit or destroy such data and comply in all respects with applicable data protection law from time to time.
Optimale may share your sensitive personal data with people not at Optimale including, but not limited to, referring practitioners, specialists, GP practices, hospitals, pharmacists, pharmacies and other healthcare providers who are treating you.
Enabling Medical Service Provision:
Optimale may use and disclose your personal health information to help us in the operating and improvement of the Website/Client Space. For example, Optimale may use sensitive personal data to review the treatment and provision of Services by certain Practitioners. Optimale may also use sensitive personal data to measure the performance of its own staff and may share sensitive personal data with third parties who Optimale engages to provide various Services on the Client Space or to Optimale itself, such as Practitioners and other healthcare workers, research agencies, clerical services providers, marketing agencies and data processing houses. If any such third party requires access to your sensitive personal data in order to perform the agreed services, Optimale will make all reasonable endeavours to procure that such third party complies with: (i) the terms of this policy; and (ii) applicable data protection law from time to time as well as seeking informed consent from you.
Video Recordings for Training and Special Incidents
Optimale does not routinely record any of the video/telephone interactions and would only do so to meet a serious training need, a review or other special incident and would never record any patient or doctor’s visual/video/audio interaction unless it was in the strictest conformity with the guidance and guidelines on Visual and Audio Recordings as published by the GMC, a version of which is available at: http://www.gmc-uk.org/guidance/ethical_guidance/making_audiovisual.asp
To Prevent Incidents and Protect You:
Optimale may use and disclose your Personal Data to the extent required to prevent a serious threat to your health and safety or that of others (including but not limited to instances of child abuse or neglect). In such circumstances Optimale will only disclose your Personal Data to public bodies or officials who can help prevent the identified or possible threat (as permitted by s.31 Data Protection Act 1998).
To Prevent Public Health Risks:
Optimale may share your Personal Data for public health activities, as required by departments or parties duly authorised by the UK Government. For example, we may share your Personal Data:
- to report reactions to medicines or problems with products;
- if a Practitioner believes that you may have been exposed to, or may be at risk of spreading, certain specified serious diseases or conditions.
Legal Disputes and Cases:
If you are involved in a legal dispute, Optimale may share your Personal Data in response to a court order, legal demand or other lawful process.
Optimale may share sensitive personal data if asked to do so by the police in certain limited circumstances, including reporting of certain types of wounds.
Optimale may share, if required, your Personal Data with UK Government officials for national security reasons (as permitted by s.28 Data Protection Act 1998).
The importance of security for all your Personal Data including, but not limited to, sensitive personal data is of great concern to us. At Optimale, we have gone to great lengths to manage the security and integrity of the Website and to ensure that we use best–in-class services when providing secure transmission of information from your computer or Device.
Personal Data collected via the Website/Client Space is stored in secure environments that are not available or accessible to the public; only those duly authorised people, officers, employees or agents of Optimale who need access to your information in order to do their jobs are allowed access. Anyone who violates our privacy or security policies is subject to disciplinary action, including possible termination of their contract with Optimale and civil and/or criminal prosecution.
Optimale uses the latest technologies to ensure utmost security, including utilising several layers of firewall security and encryption of personal data to ensure the highest level of security.
Optimale is the sole owner of any data collected via the Website.
We may collect and store personal data on your Device using application data caches and browser web storage (including HTML 5) and other technology.
Certain features of the Website link to social networking. Ensure when using these features that you do not submit any Personal Data that you do not want to be seen, collected or used by third parties.
Security when using the Website/Client Space:
When using the Website/Client Space, all your Personal Data, including but not limited to your debit or credit card number(s), are transmitted through the internet using Secure Socket Layers (SSL) technology. SSL technology causes your browser to encrypt your entered information before transmitting it to our secure server. SSL technology, an industry standard, is designed to prevent a third party from capturing and viewing your Personal Data. Optimale also takes the following measures to protect your Personal Data online:
You are required to go through a two-step verification process to create and restore your Account. Online access to your Account is protected with a password that you create. We strongly recommend that you do not disclose your password to anyone. Optimale will never ask you for your password in any unsolicited communication (including unsolicited correspondence such as letters, phone calls, email or text messages). You will only ever be able to reset your password using a two-step process.
Since any information you provide to us on the Website will be transmitted using a secure connection, if your web browser cannot support the required level of security you will not be able to use the Website properly. The most recent versions of Google Chrome, Safari and Firefox can support a secure connection and can be downloaded for free from their respective websites. Should you choose to download and/or install any such package such actions are at your own risk.
No data transmission over the internet can be guaranteed to be 100% secure. While we strive to protect your Personal Data from unauthorised access, use or disclosure, Optimale cannot ensure or warrant the security of any information you transmit to us via the Website/Client Space. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access.
Accessing Your Personal Information:
We believe that patients should have access to their medical information without charge where possible, to enable patients to take a more active role in their own health future. You can access your EMRs on Optimale any time by contacting us via the Contact Us page.
For access to other Personal Data please see “Accessing Information Held By Us” below.
Right to Amend:
We do not allow ANYONE to AMEND EMRs created or held by Optimale. We only ever allow authorised contributors (that is, Practitioners and the Customer) to ‘add to’ records, making an update to the information without deletion of the original record. We believe this approach is for everyone’s benefit and best ensures the integrity of the information we hold. If you would like to update your medical information or EMRs please Contact Us.
Optimale may, in circumstances such as these, deny your request to update your record (this is a non-exhaustive list):
- Your request has not been submitted in writing and does not include a valid reason.
- Optimale did not create the record or original information, in which case you should contact the creator, author or originator of the records. (In the case the creator, author or originator of the record is no longer in legal operation or accessible we may be able to assist you: please clarify this in your request.)
- Optimale does not hold the record and/or that information may not be updated at your request but requires another party’s authorisation.
HOW LONG WE KEEP PERSONAL INFORMATION
Patient personal data gathered during the consultation process will be retained for up to 30 years. Personal data about registered users who have not used our consultation services will be deleted after 5 years of inactivity on the Client Space and Website.
If you agree to be added to our mailing list, we will keep your personal information for that purpose unless and until you tell us that you want to unsubscribe or be removed from the list. If you advise that you do not want to be added to our mailing list or you ask to be removed, we will delete your personal data (aside from keeping a record that you have asked us not to send you marketing information).
Notices, Amendments and Updates:
Optimale may revise this policy to reflect any changes in its privacy practices. We reserve the right to make any revised policy effective for Personal Data we already have about you as well as any information we receive in the future. We will post a copy of the updated policy on our Website prior to any change becoming effective. The effective date of this policy is displayed directly under the title of the document. If we make any material changes we will notify you by means of a notice on the Website prior to the change becoming effective.
Social Media Sharing:
Accessing Information Held By Us:
If you would like a copy of all of the Personal Data, we hold about you please Contact Us. We do charge for providing information because we have to gather, collate and process this data to make it available to you in its entirety: a fee of £10 must be paid prior to releasing data and details of how this should be paid will be provided in our response to your request. The Data Protection Act allows us up to 40 days (from the date instructions and payment have been received – please note payments must clear first) to retrieve, process and provide the information requested.
If you have any complaints, please Contact Us.