Privacy Policy

This is the privacy notice of Online Medical Services Limited trading as GSTT Sexual Health. In this document, "we", "our", or "us" refer to Online Medical Services Limited.

We are company number 06482984 registered in England and Wales.

Our registered office is at 7 Tufton Street, London SW1P 3QB.

Introduction

1. This is a notice to inform you of our policy about all information that we record about you. It sets out the conditions under which we may process any information that we collect from you, or that you provide to us. It covers information that could identify you ("personal information") and information that could not. In the context of the law and this notice, "process" means collect, store, transfer, use or otherwise act on information.
2. We take seriously the protection of your privacy and confidentiality. We understand that all visitors to our website are entitled to know that their personal data will not be used for any purpose unintended by them and will not accidentally fall into the hands of a third party.
3. We undertake to preserve the confidentiality of all information you provide to us, and hope that you reciprocate.
4. Our policy complies with UK law accordingly implemented, including that required by the EU General Data Protection Regulation (GDPR).
5. The law requires us to tell you about your rights and our obligations to you in regards to the processing and control of your personal data. We do this now, by requesting that you read the information provided at www.knowyourprivacyrights.org.
6. Except as set out below, we do not share, or disclose to a third party, any information collected through our website.

The bases on which we process information about you

The law requires us to determine under which of six defined bases we process different categories of your personal information, and to notify you of the basis for each category.

If a basis on which we process your personal information is no longer relevant, then we shall immediately stop processing your data.

If the basis changes then if required by law, we shall notify you of the change and of any new basis under which we have determined that we can continue to process your information.

1. Information we process because we have a contractual obligation with you

When you create an account on our website, buy a product or service from us, or otherwise agree to our terms and conditions, a contract is formed between you and us.

In order to carry out our obligations under that contract we must process the information you give us. Some of this information may be personal information.

We may use it in order to:

• 1.1. provide you with our core service:
  • 1.1.1 sell diagnostic testing kits
  • 1.1.2 delivery of testing kits
  • 1.1.3 processing of samples
  • 1.1.4 reporting of results
• 1.2. provide you with suggestions and advice on products, services and how to obtain the most from using our website

We process this information on the basis there is a contract between us, or that you have requested we use the information before we enter into a legal contract.

Additionally, we may aggregate this information in a general way and use it to provide class information, for example to monitor our performance with respect to a particular service we provide. If we use it for this purpose, you as an individual will not be personally identifiable.

We shall continue to process this information until the contract between us ends or is terminated by either party under the terms of the contract.

2. Information we process with your consent

Through certain actions when otherwise there is no contractual relationship between us, such as when you browse our website or ask us to provide you more information about our business, including our products and services, you provide your consent to us to process information that may be personal information.

Wherever possible, we aim to obtain your explicit consent to process this information, for example, by asking you to agree to our use of cookies.

Sometimes you might give your consent implicitly, such as when you send us a message by e-mail to which you would reasonably expect us to reply.

Except where you have consented to our use of your information for a specific purpose, we do not use your information in any way that would identify you personally. We may aggregate it in a general way and use it to provide class information, for example to monitor the performance of a particular page on our website.

We continue to process your information on this basis until you withdraw your consent, or it can be reasonably assumed that your consent no longer exists.

You may withdraw your consent at any time by instructing us at customerservice@gsttsexualhealth.org.uk. However, if you do so, you may not be able to use our website or our services further.

3. Information we process for the purposes of legitimate interests

We may process information on the basis there is a legitimate interest, either to you or to us, of doing so.

Where we process your information on this basis, we do so after having given careful consideration to:

• whether the same objective could be achieved through other means
• whether processing (or not processing) might cause you harm
• whether you would expect us to process your data, and whether you would, on the whole, consider it reasonable to do so

For example, we may process your data on this basis for the purposes of:

• record-keeping for the proper and necessary administration of our business
• responding to unsolicited communication from you to which we believe you would expect a response
• protecting and asserting the legal rights of any party
• insuring against or obtaining professional advice that is required to manage organisational risk
• protecting your interests where we believe we have a duty to do so

4. Information we process for the purpose of vital interest

We may process your data for the purpose of vital interest in matters of life or death.

5. Information we process on the grounds of public interest task

We may process limited personal information with our 'partner notification' service, and only then at your request.

6. Information we process because we have a legal obligation

We are subject to the law like everyone else. Sometimes, we must process your information in order to comply with a statutory obligation.

For example, we may be required to give information to legal authorities if they so request or if they have the proper authorisation such as a search warrant or court order.

This may include your personal information.

Specific uses of information you provide to us

7. Information provided on the understanding that it will be shared with a third party

• 7.1. Under the performance of contract, we may share some personal information with third parties, such as: fulfilment providers, laboratory, electronic communication providers, payment services, data centres and corporate partners that have referred you to us.

Provided your request is reasonable and there is no legal basis for us to retain it, then we will agree to your request to delete personal information that you have provided. You can make a request by contacting us at customerservice@gsttsexualhealth.org.uk.

8. Information relating to your method of payment

We do not store information about your debit or credit card or other means of payment when you provide it to us. We do transfer your payment information to authorised payment services providers to enable you to pay for our services.

We take the following measures to protect your payment information:

• 8.1. We keep your payment information encrypted during transfer.
• 8.2. We do not keep your payment information in any form.
• 8.3. Access to your payment information at the payment services providers is restricted to authorised staff only.
• 8.4. If we ask you questions about your payment information, the payment services providers only show the last four digits of the debit or credit card number, so that you can identify the means of payment to which we refer.

9. Job application and employment

If you send us information in connection with a job application, we may keep it for up to three years in case we decide to contact you at a later date.

If we employ you, we collect information about you and your work from time to time throughout the period of your employment. This information will be used only for purposes directly relevant to your employment. After your employment has ended, we will keep your file for six years before destroying or deleting it.

10. Sending a message to our support team

When you contact us, whether by telephone, through our website or by e-mail, we collect the data you have given to us in order to reply with the information you need.

We record your request and our reply in order to increase the efficiency of our organisation.

11. Complaining

When we receive a complaint, we record all the information you have given to us.

We use that information to resolve your complaint.

We may also compile statistics showing information obtained from this source to assess the level of service we provide, but not in a way that could identify you or any other person.

12. Affiliate and business partner information

This is information given to us by you in your capacity as an affiliate of us or as a business partner.

It allows us to recognise visitors that you have referred to us, and to credit you commission due for such referrals. It also includes information that allows us to transfer commission to you.

The information is not used for any other purpose.

We undertake to preserve the confidentiality of the information and of the terms of our relationship.

We expect any affiliate or partner to agree to reciprocate this policy.

Use of information we collect through automated systems when you visit our website.

13. Cookies

Cookies are small text files that are placed on your computer's hard drive by your web browser when you visit any website. They allow information gathered on one web page to be stored until it is needed for use on another, allowing a website to provide you with a personalised experience or the website owner with statistics about how you use the website so that it can be improved.

Some cookies may last for a defined period of time, such as one day or until you close your browser. Others last indefinitely.

Your web browser should allow you to delete any you choose. It also should allow you to prevent or limit their use.

Our website uses cookies. They are placed by software that operates on our servers, and by software operated by third parties whose services we use.

If you choose not to use cookies or you prevent their use through your browser settings, you will not be able to use all the functionality of our website.

We use cookies in the following ways:

• 13.1. to track how you use our website
• 13.2. to record whether you have seen specific messages we display on our website
• 13.3. to keep you signed in on our site

14. Personal identifiers from your browsing activity

Requests by your web browser to our servers for web pages and other content on our website are recorded.

We record information such as your geographical location, your Internet service provider and your IP address. We also record information about the software you are using to browse our website, such as the type of computer or device and the screen resolution.

We use this information in aggregate to assess the popularity of the web pages on our website and how we perform in providing content to you.

If combined with other information we know about you from previous visits, the data possibly could be used to identify you personally, even if you are not signed in to our website.

Disclosure and sharing of your information

15. Information we obtain from third parties

Although we do not disclose your personal information to any third party (except as set out in this notice), we sometimes receive data that is indirectly made up from your personal information from third parties whose services we use.

16. Data may be processed outside the European Union

Our websites are hosted in the United Kingdom.

We may also use outsourced services in countries outside the European Union from time to time in other aspects of our business.

Accordingly data obtained within the UK or any other country could be processed outside the European Union.

In such instances we shall ensure that the transfer of your personal data is carried out in accordance with applicable privacy laws and, in particular, that appropriate contractual, technical, and organisational measures are in place such as the Standard Contractual Clauses approved by the EU Commission.

Access to your own information

17. Access to your personal information

• 17.1. At any time you may review or update personally identifiable information that we hold about you, by signing in to your account on our website.
• 17.2. To obtain a copy of any information that is not provided on our website you may send us a subject access request at customerservice@gsttsexualhealth.org.uk.
• 17.3. After receiving the request, we will tell you when we expect to provide you with the information (no longer than 30 days). There is not normally any charge for a subject access request. If your request is 'manifestly unfounded or excessive' (for example, if you make repetitive requests) a fee may be charged to cover our administrative costs in responding.

18. Removal of your information

If you wish us to remove personally identifiable information from our website, you may contact us at customerservice@gsttsexualhealth.org.uk.

This may limit the service we can provide to you.

19. Verification of your information

When we receive any request to access, edit or delete personal identifiable information we shall first take reasonable steps to verify your identity before granting you access or otherwise taking any action. This is important to safeguard your information.

Other matters

20. Use of site by children

• 20.1. We do not sell products or provide services for purchase by children, nor do we market to children.
• 20.2. We collect data about all users of and visitors to these areas regardless of age, and we anticipate that some of those users and visitors will be children.
• 20.3. Such child users and visitors will inevitably visit other parts of the site and will be subject to whatever on-site marketing they find, wherever they visit.

21. Security and encryption

We take the security of personal information seriously. We employ security technology, including firewalls, and Secure Socket Layers to safeguard information and have procedures in place to ensure that our paper and computer systems and databases are protected against unauthorised disclosure, use, loss and damage.

Whenever information is transferred between us, you can check that it is done so using SSL by looking for a closed padlock symbol or other trust mark in your browser's URL bar or toolbar.

22. How you can complain

• 22.1. If you are not happy with our privacy notice or if have any complaint, then you should tell us by email. Our address is customerservice@gsttsexualhealth.org.uk.
• 22.2. If a dispute is not settled, then we hope you will agree to attempt to resolve it by engaging in good faith with us in a process of mediation or arbitration.
• 22.3. If you are in any way dissatisfied about how we process your personal information, you have a right to lodge a complaint with the Information Commissioner's Office. This can be done at https://ico.org.uk/concerns/.

23. Retention period for personal data

Except as otherwise mentioned in this privacy notice, we keep your personal information only for as long as required by us:

• 23.1. to provide you with the services you have requested;
• 23.2. to comply with other law, including for the period demanded by our tax authorities;
• 23.3. to support a claim or defence in court.

24. Compliance with the law

Our privacy policy has been compiled so as to comply with the law of the United Kingdom.

25. Review of this privacy policy

We may update this privacy policy from time to time as necessary. The terms that apply to you are those posted here on our website on the day you use our website. We advise you to download a copy for your records.

If you have any question regarding our privacy policy, please contact us.

This privacy policy was last updated 24 May 2018.