Privacy Policy

Last updated: 9 May 2025

We amend this Privacy Policy from time to time. Every time you use our website, please check this policy to ensure you understand the version that applies at that time.

Who are we and what do we do?

We are PrivateDoc Limited (“we”, “our”, “us”), a company registered in England and Wales under company number 07466982 with a registered address at Regis House, 45 King William Street, London, England, EC4R 9AN. We are a data controller and responsible for your personal data.

In accordance with our Terms of Service and Supply, we provide:

• a website at www.privatedoc.com (the “Website”);
• online clinical assessment service for the treatment of a range of medical conditions, and, where our Clinical Team consider it is appropriate to do so, we may issue a prescription, as detailed on our Website from time to time (the “Service”); and
• medical products in accordance with a prescription or otherwise, and test kits, as detailed on our website from time to time for purchase through our Website (the “Product(s)”).

You can contact us by writing to our registered address, by telephoning our customer service team at 0333 358 0200, or by e-mailing us at [email protected].

What does this Privacy Policy cover?

This Privacy Policy tells you what personal data we collect and why, how we use and protect your personal data, and what your rights are in respect of your personal data. Please read this Privacy Policy carefully.

The Website is not intended for children and we do not knowingly collect data relating to children.

Please note, this Website may contain links to other websites. We are only responsible for the privacy practices and security of this site. We recommend that you check the privacy and security notices of every website that you visit.

Keeping your personal data up to date

You should ensure that the personal data we process relating to you is accurate and up to date. Please update your personal information promptly if it changes. You can update or correct your personal information online via your patient account.

If information changes about your health, please contact our Customer Care Team as this may affect the appropriateness of the medication prescribed to you.

What personal data do we collect?

Personal data means any information about an individual from which that person can be identified.

We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:

• Identity Data includes first name, last name, any previous names, username or similar identifier, marital status, title, date of birth, gender and ID details such as passport or driving licence number.
• Contact Data includes billing address, delivery address, email address and telephone numbers.
• Financial Data includes bank account and payment card details.
• Transaction Data includes details about payments to and from you and other details of products and services you have purchased from us.
• Health Data includes sensitive personal data concerning your current or former physical or mental health, including but not limited to information about any healthcare you have received from us or other healthcare providers such as GPs, or hospitals (private and/or NHS), which may include test results, prescription or treatment details, photographs, and information you provide when communicating with our Clinical Team. This is considered special category personal data in the UK and is subject to additional protections under data protections laws.
• 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, device ID and other technology on the devices you use to access this website.
• Profile Data includes your username and password, purchases or orders made by you, your interests, preferences, feedback and survey responses.
• Usage Data includes information about how you interact with and use our website, products and services.
• Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.

We also collect, use and share aggregated data such as statistical or demographic data which is not personal data as it does not directly (or indirectly) reveal your identity. For example, we may aggregate individuals' Identity Data and Usage Data to calculate the average age or gender of users accessing a specific website feature in order to analyse general trends in how users are interacting with our website to help improve the website and our service offering.

How do we collect personal data?

We use different methods to collect data from and about you including through:

Your interactions with us

You may give us your personal data by filling in online forms, attending telephone or video consultations or by corresponding with us. This includes personal data you provide when you:

• apply for our Products or Services;
• create an account on our Website;
• subscribe to our service or publications;
• request marketing to be sent to you;
• enter a competition, promotion or survey; or
• give us feedback or contact us.

Automated technologies or interactions

We may use “cookies” and similar tracking technologies on the Website. Cookies are used by most website operators to gather small pieces of information that are stored by your browser on your computer’s hard drive and are used to record how you navigate this Website on each visit. You can think of cookies as providing a ‘memory’ for the Website, so that it can recognise you when you come back and respond appropriately. Cookies enable us to understand the size of our audience, your interests, how you use the site and speed up how you find information.

Most browsers automatically accept cookies, but you can change your browser to prevent cookies being stored by following your browsers instructions. If you choose to turn cookies off, this could limit the service we provide to you and may affect your online experience.

For more information on our use of cookies, please see our Cookie Consent Manager.

Third parties or publicly available sources

We will receive personal data about you from various third parties as set out below:

• Technical Data is collected from the following parties:
  • analytics providers such as Google based outside the UK.
  • providers of IoT / wearables such as Libra or Fitbit.
• Contact, Financial and Transaction Data is collected from providers of technical, payment and delivery services such as Stripe based outside the UK and DPD based outside the UK.
• Identity and Contact Data is collected from identity verification partners such as GB Global.
• Health Data is collected from your GP or other healthcare providers, where consent is provided.

How do we use your personal data?

Article 6 of the UK GDPR requires us to have a legal basis for collecting and using your personal data. We rely on one or more of the following legal bases:

• Performance of a contract with you: Where we need to perform the contract we are about to enter into or have entered into with you (i.e. the Terms of Service and Supply).
• Legitimate interests: We may use your personal data where it is necessary to conduct our business and pursue our legitimate interests, for example to prevent fraud and enable us to give you the best and most secure customer experience. We make sure we consider and balance any potential impact on you and your rights (both positive and negative) 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).
• Legal obligation: We may use your personal data where it is necessary for compliance with a legal obligation that we are subject to. We will identify the relevant legal obligation when we rely on this legal basis.
• Consent: We rely on consent only where we have obtained your active agreement to use your personal data for a specified purpose, for example if you subscribe to an email newsletter.

In addition, Article 9 of the UK GDPR requires us to have an additional legal basis for processing special category data (i.e. Health Data).

The following table sets out the ways in which we use the various categories of your personal data and the legal bases (both under Article 6 and Article 9 where relevant) we rely on to do so. We have also identified what our legitimate interests are where appropriate.

Disclosures and transfers of your personal data

We may share your personal data where necessary with the parties set out below, for the purposes set out in the table above.

• Subcontractors, suppliers and partners, such as IT infrastructure providers like Microsoft, delivery and courier service providers like DPD and Royal Mail, and identity verification partners like GB Group.
• Laboratory and pharmacy services providers, such as our partner pharmacists at Omnicare Pharmacy Ltd and test-kit partner The Doctor’s Laboratory Ltd. We only share your information with them for the provision of your care and to provide our Services and Products to you.
• Your GP or other healthcare professionals, to inform them of any medicines that our Clinical Team prescribe. Please note that in some cases, our Clinical Team may consider it is not safe to prescribe medication in the absence of consent to share information with your regular GP.
• Regulatory bodies, such as the Care Quality Commission, General Medical Council, General Pharmaceutical Council, Nursing and Midwifery Council or the Information Commissioner’s Office.
• Law enforcement agencies, courts, or other relevant party, to the extent necessary for the establishment, exercise, or defence of legal rights or otherwise in accordance with applicable laws.
• 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 Policy.

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.

Marketing

You will receive marketing communications from us if you have requested information from us or purchased Products from us and you have not opted out of receiving the marketing. We may also analyse your Identity, Contact, Technical, Usage and Profile Data to form a view of which Products and Services may be of interest to you so that we can then send you relevant marketing communications.

We will get your express consent before we share your personal data with any third party for their own direct marketing purposes.

You can ask us to stop sending you marketing communications at any time by following the opt-out links within any marketing communication sent to you or by contacting us. If you opt out of receiving marketing communications, you will still receive service-related communications that are essential for administrative or customer service purposes.

Data security

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.

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.

Data retention

We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.

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, regulatory, tax, accounting or other requirements.

By law we have to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for six years after they cease being customers for tax purposes. All medical records will be retained in accordance with “Records Management Code of Practice 2024” as updated from time to time.

In some circumstances you can ask us to delete your data: see the paragraph below on “Your rights”.

In some circumstances we will 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.

Your rights

You have a number of rights under data protection laws in relation to your personal data.

You have the right to:

• Request access to your personal data (commonly known as a “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.
• 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.
• Request erasure of your personal data in certain circumstances. 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.
• Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) as the legal basis for that particular use of your data (including carrying out profiling based on our legitimate interests). In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your right to object.
• 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.
• Object at any time to the processing of your personal data for direct marketing purposes.
• Withdraw consent at any time where we are relying on consent to process your personal data (i.e. Health 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.
• Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in one of the following scenarios:
  • If you want us to establish the data's accuracy;
  • Where our use of the data is unlawful but you do not want us to erase it;
  • 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
  • You have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.

If you wish to exercise any of the rights set out above, please contact us at [email protected].

You 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 could refuse to comply with your request in these circumstances.

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.

We try to respond to all legitimate requests within one month. Occasionally it could 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.

Contacting us and complaints

If you have any questions about this Privacy Policy, please contact us by email at [email protected], by telephone on 0333 358 0200, or by post at PrivateDoc Limited, Regis House, 45 King William Street, London, England, EC4R 9AN. Please ensure that your query is clear, particularly if it is a request for information about the data we hold about you.

You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK regulator for data protection issues (www.ico.org.uk). We are registered under number ZA201954. We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.