We are committed to ensuring the security of your personal data and protecting your privacy. This policy will inform you as to how we look after your personal data when you use our PatientMetRx® service. It will also tell you about your privacy rights and how the law protects you.
Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it.
Who we are
We are Talking Medicines Limited. We are a company incorporated and registered in Scotland. Our company number is SC447227. Our registered office address is at Top Floor, 25 Blythswood Square, Glasgow, G2 4BL.
When we refer to “Talking Medicines” or “we“, “us” or “our” in this policy, we are referring to Talking Medicines Limited. We are the ‘controller’ in relation to the personal data you provide to us, which means we determine the purposes and the way in which your personal data is, or will be, processed and are responsible for it.
How to contact us
Questions, comments and requests regarding this policy are welcomed. You may either use our contact form to get in touch with us or you may write to our Data Privacy Manager at:
- Email: [email protected]
- Address: Top Floor, 25 Blythswood Square, Glasgow, G2 4BL
About our service
Talking Medicines is a data tech company serving the pharmaceutical and healthcare sectors.
The PatientMetRx service (“Service”) is designed to connect the pharmaceutical industry to the true voice of the patient through data intelligence.
|means a pharmaceutical company or any other party which we contract with to provide our Service
|means an employee of the Customer who is authorised to use our Service
|means our site at www.patientmetrx.com or such other site as we may use to provide our Service
The Service involves our PatientMetRx® web-based application which we provide to allow the Pharmaceutical industry access to the voice of the patient by supplying structured intelligence on patient experience by medicine.
You should be aware that our Service may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party apps and are not responsible for their privacy statements. When you leave our Service, we encourage you to read the privacy notice of every website or app you visit or use.
How is your personal data collected?
We use different methods to collect data from and about you including through:
|You may give us your personal data by accessing our Service and registering for an account, when you report a problem with our Service and by corresponding with us in person, by email, by phone, by post or otherwise.
|Automated technologies or interactions
|As you interact with our Service via our Service or Website, we may automatically collect personal data. We collect this personal data by using cookies and other similar technologies. Please see below on Cookies for further information.
What information do we collect about you
We may collect and process the following different kinds of personal data about you:
|this is the email address, username, password and any other information you provide to us when you register to use the Service if you are a User
|any contact data you provide to us to help with queries or support on the use of the Service
|includes information submitted to us via our Service and details of any correspondence between you and us
|includes any feedback you provide to us about your use of the Service including responses to surveys
|when you browse our Website, we collect some technical information about your visit to our Website, such as the IP address used to connect your computer to the internet, and browser and browser plug-in type and version. We also collect information such as the type of mobile device you use, a unique device identifier (for example, your device’s IMEI number or the mobile phone number used by the device), mobile network information, your mobile operating system, and the type of mobile browser you use.
If you want any further information about how we might collect or use your personal data, please contact us.
How do we use your personal data?
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:
● Where we need to perform the contract we have entered into with you or to take steps at your request prior to entering into a contract (e.g. when you register to use our Service).
● Where we have your prior consent to use your personal data.
● Where we need to comply with a legal or regulatory obligation.
● 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.
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.
We need to have further justification for collecting, storing and using special categories of personal data (i.e. patient records) and we have identified this where appropriate. It will normally be on the basis of your explicit consent.
Please note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.
|Type of data
|Lawful basis for processing
|To register you as a User
Necessary in order to comply with contractual obligations with a Customer.
Necessary for our legitimate interests – to run our business
|To provide our Service
Necessary in order to perform our contract with the Customer
To comply with our legal obligations
Necessary for our legitimate interest – to run our business
|To manage our relationship with you. This includes responding to any questions you may ask us; notifying you of changes to the Service; notifying you of any updates to any contractual terms, privacy policies and other relevant information
|Account data, Contact data
Necessary in order to perform our contract with you
To comply with our legal obligations
Necessary for our legitimate interests – to run our business
|To identify and fix problems if they arise during your use of the Service
Necessary in order to perform our contract with Customer
Necessary for our legitimate interests – to run our business
|To contact you to ask you to provide feedback, complete surveys or for other market research purposes and to use such information to improve our Service
|Contact and Feedback data
Necessary for our legitimate interest – to analyse and improve our Service
● identify when you use our Service
● recognise you when you return to our Service (e.g. we may show you relevant content or provide functionality you used previously)
● store information about your Service preferences
Necessary for our legitimate interests – to operate our Service and to improve client interactions and user experience.
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.
If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the lawful basis which allows us to do so.
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.
Disclosure of your information
We may have to share your personal information for the purposes set out above with the following third parties:
including those who provide:
● Webhosting, IT and system administration services
● Metrics and analytics
|including lawyers, bankers, auditors and insurers who provide consultancy, banking, legal, insurance and accounting services.
|including regulators and other authorities who require reporting of processing activities in certain circumstances.
|includes third parties who may invest in our business or to whom we may choose to sell, transfer, or merge parts of our business or our assets. 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.
|includes universities and other research institutions we may partner with to carry out research.
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.
Some of our external third parties may, from time to time, be based outside the United Kingdom (UK)) so their processing of your personal data will involve a transfer of data outside the UK..
If we transfer your personal data out of the UK, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:
- The country has been deemed to provide an adequate level of protection for personal data by the Information Commissioner’s Office. For further details, see Information Commissioner’s Office: International transfers after the UK exit from the EU Implementation Period.
- If we use certain service providers based outwith the UK, we may use specific contracts approved by the European Commission which give personal data the same protection it has in the UK, and may make changes to such specific contracts so they make sense in a UK context. For further details, see European Commission: Model contracts for the transfer of personal data to third countries.
- If we use providers based in the US, we may transfer data to them if they are part of the Privacy Shield which requires them to provide similar protection to personal data shared between the EU and the US, so long as such providers have updated their public commitments to specifically state that their commitment extends to personal data received from the UK. For further details, see European Commission: EU-US Privacy Shield.
- In any other case, we will obtain your explicit consent before any transfer takes place.
Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the UK.
We have put in place appropriate security measures in accordance with industry best practice 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.
All information you provide to us is stored on secure servers. Where we have given you (or where you have chosen) a password which enables you to access our Service, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.
How long we store your personal data for
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.
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.
Where we anonymise your personal data (i.e. so that it can no longer be associated with you) for further research or statistical purposes, then we may use this information indefinitely without further notice to you.
Under certain circumstances, you have rights under data protection laws in relation to your personal data. Please read through the table below to find out more about these rights.
|What this means
|Access to your information
|You have the right to ask for a copy of the information which we hold on you (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.
|Correcting personal data
You have the right to request that we correct personal data that we hold about you. This enables you to have any incomplete or inaccurate information we hold corrected, though we may need to verify the accuracy of the new data that you provide to us.
It is important that the personal data we hold about you is accurate and current, so please keep us informed if your personal data changes during your relationship with us.
|Deleting personal data
You may ask us to delete or remove personal data where there is no good reason for us continuing to process it. This is more commonly known as the ‘right to be forgotten’. 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.
Please note, however, that we may not always be able to comply with your request to delete or remove personal data for specific legal reasons which will be notified to you, if applicable, at the time of your request.
|Objecting to processing
You have the right to stop us processing your personal data for direct marketing purposes. We will always inform you if we intend to use your personal data for such purposes, or if we intend to disclose your information to any third party for such purposes. You could then exercise your right to prevent such marketing by contacting us.
You may also object to us processing 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. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
|Restriction of processing
This enables you to ask us to suspend the processing of your personal data in 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.
|Transferring your personal data
In certain circumstances, you may 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.
Please 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.
|Where we are relying on consent to process your personal data you can withdraw your consent at any time. Please note that this will not affect the lawfulness of any processing carried out before you withdraw your consent.
|Review by an independent authority
|You will always have the right to lodge a complaint with a supervisory body. The relevant authority in the UK is the Information Commissioner’s Office. If you do have a complaint, we would appreciate the chance to deal with your concerns before you approach the ICO, so please do contact us in the first instance if possible.
If you wish to exercise any of the rights set out above, please contact us. 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 may 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 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.
This version was last updated 26th of January 2021