Privacy Notice

Thank you for your interest in our services. We are committed to protecting and respecting your privacy.

This Privacy Notice sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us.

When we refer to “MyHealthChecked”, “we”, “our” or “us” in this Privacy Notice, we are referring to Concepta Diagnostics Limited (“Concepta”) which provide the services to you. The “services” refers to the applications, services and websites provided by Concepta.

Please read the following carefully to understand our practices regarding your personal data and how we will treat it. This Privacy Notice applies to any processing by us of your personal data including when you visit MyHealthChecked , and any other websites we operate (our ”sites”) or by using any of the MyHealthChecked applications (our “applications”).

For the purpose of the Data Protection Act 2018 (the Act) and Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 (the General Data Protection Regulation, or GDPR), the data controller is Concepta Diagnostics Limited of The Maltings, East Tyndall Street, Cardiff, Wales, CF24 5EA, UK.

The lawful basis of our processing

The lawful basis to the various purposes of our processing of your personal data is as follows: where you give your consent to our processing your personal data; or when we are processing your personal data in the performance of a contract between us or preparatory to such a contract; or when we further process your personal data for the purposes of marketing as it is necessary in our legitimate interests to do so, (except where such interests are overridden by your interests or fundamental rights). We undertake a three part Legitimate Interest Assessment (LIA) in order to test (i) whether such a legitimate interest exists, and (ii) to establish the necessity of processing and (iii) a balancing act to decide if a particular processing operation can rely on the legitimate interest provision in GDPR; we may also lawfully process your personal data where we are under a legal obligation to do so, or that the processing is necessary to protect your vital interests, or the vital interests of another person.

Generally, explicit consent is required for us to process special categories of personal data, such as health data. On the occasions where we are asking you to consent to our processing of your sensitive personal data, we will always tell you why and how the information will be used.

For COVID-19 testing, however, where we are collecting your biological sample, we will not be seeking your explicit consent for the processing of your test result, as that processing is necessary for reasons of public interest in the area of public health.

Information we collect from you

We will collect and process the following data about you:

Information you give us

This is information about you that you give us by filling in forms on our sites and within our applications, by uploading documents or by corresponding with us by phone, e-mail or otherwise. It includes information you provide when you register to use our sites, subscribe to our services, use our applications, participate in discussion boards or other social media functions on our sites or applications, enter a competition, promotion or survey, register for our newsletter and when you report a problem with our sites, applications or services. The information you give us may include your name, address, e-mail address and phone number, financial and credit card information, personal description and other identification details.

Information we may collect about you

With regard to each of your visits to our site and application we may automatically collect the following information:

technical information, including the Internet protocol (IP) address used to connect your computer to the Internet, your login information, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform;

information about your visit, including the full Uniform Resource Locators (URL), clickstream to, through and from our site (including date and time), products 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), methods used to browse away from the page, and any phone number used to call our customer service number.

This information is the result of the testing service that we provide.

You will not receive your test results unless you have provided your full consent. If you have not provided your consent, your sample will be put into quarantine at the laboratory and we will be unable to process it. Our sample quarantine period for samples received that full consent has not been given is as follows:

After this period, your sample will be destroyed, and a new kit must be purchased if you wish to proceed with the analysis.

Our sample retention policy is as follows:

For DNA Tests (wellness oral swabs)

· Your sample will be retained for 10 days

· Your DNA will be extracted from the swab sample you provide to us for genetic analysis

· Information regarding your genotype is generated when we process and analyse your swab sample

· You can withdraw consent by contacting us via email to care@myhealthchecked.com

For RNA Tests (COVID test and urine samples)

· Your COVID test RNA sample will be retained for 48 hours after the laboratory report is issued to the doctor, with the exception of detected results for chlamydia or unconfirmed reactive results for gonorrhoea which will be retained for 3 months

· Your RNA will be extracted from the swab sample you provide to us for genetic analysis

· For COVID tests, as part of the kit registration you are required to explicitly consent to Concepta storing and performing additional analyses on your RNA sample subject to laboratory legal and regulatory requirements

· You can withdraw consent by contacting us via email to care@myhealthchecked.com

For Blood Tests

· Your blood test sample will be retained for one week with the exception of unconfirmed reactive HIV or Syphilis test results which will be retained for 24 months

· You can withdraw consent by contacting us via email to care@myhealthchecked.com

Following these retention periods, subject to any overriding legal obligation, all special categories of personal data are anonymised or placed beyond use by the Controller and are thus rendered inaccessible. Any remaining personal data is retained for no longer than is necessary for the purposes for which it is processed.

Information we may receive from other sources

This is information we receive about you if you use any of the other websites we operate or the other services we provide. We are working closely with third parties (including, for example, business partners, sub-contractors in technical, payment and delivery services, advertising networks, analytics providers, search information providers, credit reference agencies).

Cookies

Our website uses cookies to distinguish you from other users of our website. This helps us to provide you with a good experience when you browse our website and also allows us to improve our site. For detailed information on the cookies, we use and the purposes for which we use them see our Cookie policy.

Purposes of the processing

We use information held about you for the following purposes:

Information you give to us

We will use this information:

· To carry out our obligations arising from any contracts entered into between you and us and to provide you with the information, products and services that you request from us;

· To provide you with information about other goods and services we offer that are similar to those that you have already purchased or enquired about;

· 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 sale or negotiations of a sale to you. 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 tick the relevant box situated on the form on which we collect your data (the registration form);

· To notify you about changes to our service;

· To ensure that content from our site is presented in the most effective manner for you and for your computer.

Information we may collect about you

We may use this information:

· To administer our site and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes.

· To improve our site to ensure that content is presented in the most effective manner for you and for your computer.

· To allow you to participate in interactive features of our service, when you choose to do so; as part of our efforts to keep our site safe and secure;

· 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 our site about goods or services that may interest you or them.

Information we collect through our testing service

We may use this information:

· To carry out our obligations arising from any contracts entered into between you and us and to provide you with the test result, information, products and services that you request from us

Information we may receive from other sources

We may combine this information with information you give to us and information we collect about you. We will use this information and the combined information for the purposes set out above (depending on the types of information we receive).

Disclosure of your information

We may share your personal information with:

· Any member of our group, which means our subsidiaries, our ultimate holding company and its subsidiaries, as defined in section 1159 of the UK Companies Act 2006

· Selected third parties including:

o Business partners, suppliers and sub-contractors for the performance of any contract we enter into with them or you;

o Advertisers and advertising networks that require the data to select and serve relevant adverts to you and others. We do not disclose information about identifiable individuals to our advertisers, but we will provide them with aggregate information about our users (for example, we may inform them that 500 men aged under 30 have clicked on their advertisement on any given day). We may also use such aggregate information to help advertisers reach the kind of audience they want to target (for example, women in SW1). We may make use of the personal data we have collected from you to enable us to comply with our advertisers’ wishes by displaying their advertisement to that target audience;

o Analytics and search engine providers that assist us in the improvement and optimisation of our site;

o Credit reference agencies for the purpose of assessing your credit score where this is a condition of us entering into a contract with you.

o Other users of our sites and applications only where you voluntarily elect to share your personal information with that user.

· We may disclose your personal information to third parties:

o In the event that we sell or buy any business or assets, in which case we will disclose your personal data to the prospective seller or buyer of such business or assets.

o If Concepta Diagnostics Limited 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.

o If we are under a duty to disclose or share your personal data in order to comply with any legal obligation, or in order to enforce or apply our Terms of Use and other agreements with you; or to protect the rights, property, or safety of Concepta Diagnostics Limited, our customers, or others.

· We will not transfer your personal data outside the European Economic Area

Where we store your personal data

The data that we collect from you will be transferred to, and stored at, a destination within the European Economic Area. It will also be processed by staff who work for us or for one of our suppliers. This includes staff engaged in, among other things, the fulfilment of your order, the processing of your payment details and the provision of support services. By submitting your personal data, you agree to this transfer, storing or processing.

All information you provide to us is stored on our secure servers. Any payment transactions will be encrypted.

Where we have given you (or where you have chosen) a password which enables you to access certain parts of our sites or applications, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.

Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our site; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access.

Our sites and applications may, from time to time, contain links to and from the websites of our partner networks, advertisers and affiliates. If you follow a link to any of these websites, please note that these websites have their own privacy notices and that we do not accept any responsibility or liability for such information. Please check these privacy notices before you submit any personal data to these websites.

Your rights

At any point while we are processing your personal data, you have the following rights:

(i) Right of access – you have the right to request a copy of the information that we hold about you.

(ii) Right of rectification – you have a right to correct data that we hold about you that is inaccurate or incomplete.

(iii) Right to be forgotten – in certain circumstances you can ask for the data we hold about you to be erased from our records.

(iv) Right to restriction of processing – where certain conditions apply to have a right to restrict the processing.

(v) Right of portability – in certain cases, you have the right to have the data we hold about you transferred to another organisation.

(vi) Right to object – you have the right to object to certain types of processing such as direct marketing.

(viii) Right to object to automated processing, including profiling.

(ix) Right to judicial review: in the event that we refuse your request under any of the above rights of, we will provide you with a reason as to why. You have the right to complain to the Supervisory Authority as outlined below

Complaints

In the event that you wish to make a complaint about how your personal data is being processed by us, please write to us at the address above or email us at administration@conceptaivd.com. If you are unhappy as to how your complaint has been handled, you may contact our data protection officer Dr Philip Griffiths at sar@thedpo.co.uk. You also have the right to lodge a complaint directly with the Supervisory Authority.

The Supervisory Authority in the United Kingdom is the Information Commissioner’s Office (ICO), Make a complaint , Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF. Telephone 0303 1231113 email casework@ico.org.uk.