Last Updated: 12/12/2024

About Us

The Family Health Group Ltd (The Family Health Group, we, us, or our) owns and operates this Website under the trading name Happen. We are a company registered in England and Wales under company number 14982976. Our registered office address is St Peters House, Suite 2, Silverwell Street, Bolton, England, BL1 1PP.

The Family Health Group is the controller and responsible for your personal data.

You can contact us at [email protected].

We have appointed a data protection officer (DPO) who is responsible for overseeing questions in relation to this Privacy Policy. You can contact the DPO using the details set out above.

What does this Privacy Policy cover?

This Privacy Policy is aimed at anyone who uses or visits our Website, social media channels or purchases our products or services, and any third parties with which we engage or do business. This includes our customers, suppliers, agents, consultants and partners who are individuals, as well as, where any of these are entities, their respective shareholders, directors, officers, managers, employees or other individuals who provide their personal data to us or whose personal data is provided to us, and any other third parties who interact with us (whether directly or through our Website). This privacy policy will inform you as to how we look after your personal data and tell you about your privacy rights and how the law protects you.

This Privacy Policy applies to any personal information that we collect from you or receive from a third party in various scenarios, including the following:

1. Website Usage: When you use our website.
2. Account Registration: When you register an account with us.
3. Product or Service Purchase: When you purchase our products or services.
4. Social Media Interaction: When you interact with our social media channels.
5. Feedback and Research: When you provide feedback, take part in market research or user testing, or provide customer testimonials.
6. Supplier Services: Where you provide services to us as a Supplier.
7. Information Requests: Where you have requested to receive information about our products and services.

It’s important to note that our website, products, and services are not intended for individuals under the age of 18, and we do not knowingly collect data relating to children.
If you do not agree with the contents of this Privacy Policy, you should not sign up for an account, purchase products or services, or otherwise submit information to us.

What personal information do we collect?

At The Family Health Group, we strive to provide you with the best possible service and experience. To achieve this, we collect, use, store, and transfer various types of personal information about you, including but not limited to:

• Identity Data: This includes your first name, last name, username, password, date of birth, user or device identifiers, job title, and company. This information helps us uniquely identify you and personalize your experience.
• Contact Data: This category comprises your email address, home address, business address, telephone number, and professional and/or social network contact details. We use this information to communicate with you and provide you with important updates.
• Financial Data: This may encompass (i) credit card and/or billing information for payment processing and address verification, (ii) bank details for payment if it’s part of our contractual agreements. Your financial data is securely processed to facilitate transactions.
• Transaction Data: This involves information about payments and details of purchases you have made. In certain cases, Transaction Data may include Health Data. This information helps us track your transactions and ensure a smooth payment process.
• Technical Data: This includes your IP address, browser type and version, time zone setting and location, referral sources, browser plug-in types and versions, operating system and platform, and other technology details from the devices you use to access our Site. We use this information to improve our website functionality and provide a better user experience.
• Usage Data: This category may contain information about your interactions with our Site (e.g., pages visited, length of visit, and actions taken), or social media channels. This data helps us understand how you use our services and tailor them to your needs.
• Audio/Visual Data: This pertains to your image and/or voice. This data may be collected for identification or authentication purposes.
• Assessment Data: These are details provided in response to questionnaires on the Site or consultations with clinicians, used to assess your suitability for a particular product or service. In certain instances, Assessment Data may include Health Data. This information helps us provide personalized recommendations and services.
• Feedback Data: This includes any feedback you provide to us during user testing, market research, or when you agree to provide customer testimonials. Depending on the feedback, it may include Health Data. Your feedback helps us improve our products and services.
• Marketing and Communications Data: This covers your preferences regarding receiving marketing or other communications from us. We use this information to send you relevant updates and offers.
• Health Data: This encompasses information about your current health or medical history, such as details of any health conditions or consultation notes. This information is collected and processed in accordance with applicable laws and regulations to provide you with personalized healthcare services. We will always treat Health Data as confidential and we will only process such data where there is a specific and legitimate purpose for doing so. We will only retain such data for as long as necessary to fulfil the purposes we collected it for, as required to satisfy any legal, accounting, or reporting obligations, or as necessary to resolve disputes.
• Location Data: We may collect information about your location, which can be derived from your IP address or other geolocation features on your device. This data helps us provide location-based services and content.
• Biometric Data: This may include data related to your physical characteristics, such as fingerprints or facial recognition, if such features are used for authentication or identification purposes. This data is collected and processed securely to ensure your privacy and security.
• Social Media Data: If you interact with our social media channels, we may collect information from those interactions, such as likes, shares, or comments. This data helps us understand your interests and tailor our social media content accordingly.
• Professional Data: This includes information related to your profession or occupation, such as job title, company name, and professional qualifications. This data helps us tailor our services to meet the needs of professionals in specific industries.
• Preferences Data: This covers information about your preferences and interests, which may be used to tailor our services or marketing communications to better suit your needs. This data helps us provide personalized recommendations and offers.
• User-Generated Content: Any content you create or submit to our website, such as reviews, comments, or posts, may be collected and stored. This data helps us understand your preferences and improve our services.

This list is not exhaustive, and we may collect other types of personal information as permitted or required by law. We are committed to protecting your privacy and ensuring the security of your personal information.

In this Privacy Policy:

• “Customer” refers to individuals who register an account on the website, whether or not they purchase products or services from The Family Health Group. Customers may provide various types of personal information, including but not limited to their name, contact details, and purchase history.
• “Website Visitors” are individuals who visit our website. Website Visitors may include Customers, as well as individuals who browse the Site without registering an account. When Website Visitors interact with the website, certain information may be collected, such as IP addresses, browser information, and pages visited.
• “Suppliers” are external vendors and suppliers that provide products and/or services to The Family Health Group. Suppliers may provide personal information as part of their business relationship with The Family Health Group, such as contact details and billing information.
• “Personal information” or “personal data” refers to any information about an individual from which that person can be directly or indirectly identified. This includes the information listed in the section “What personal information do we collect?” above. Personal information does not include data where the identity has been removed, such as anonymous data or aggregated data that cannot be used to identify an individual.

When you visit our website, we automatically collect technical and usage data through the use of cookies and similar technologies. These technologies, employed by us and our technology partners, help us provide you with relevant content, measure the effectiveness of the content we offer, enhance our website’s content, marketing, and user experience, and manage and protect the website. For more details on this, please refer to our Cookie Policy.

If you take one of our pre-treatment assessments as an unregistered user, we process your identity and assessment data to determine your suitability for treatment.

When you use the contact address provided on our website to get in touch with us, we collect your identity and contact details, as well as the content of your message.

Social Media Users

We utilize various social media platforms, including Facebook, Twitter, Instagram, and TikTok, to promote The Family Health Group’s products and services. When you interact with our social media channels by following or engaging with them, we collect usage and technical data to analyse user interactions. If you contact us through social media, we may use your contact details and message content to communicate with you. Moreover, if you interact with advertisements on social media, we may collect your identity, contact information, and marketing preferences.

When you engage with our social media channels, the respective social media company will also process your personal data for the aforementioned purposes, acting as joint controllers. We recommend reviewing the privacy notices published by these companies for more information.

Suppliers

If you are a supplier, we collect identity, contact, transaction, and financial data about you or individuals at your organization during the creation, negotiation, and management of contracts, as well as when receiving products or services from you.
As a supplier, we may also use your data to:

• Store and update your contact details on our database for communication regarding our agreements and the services you provide.
• Administer and manage our business relationship with you and obtain services from you.
• Comply with legal or regulatory requirements.
• Assist us in establishing, exercising, or defending legal claims.

Other Individuals

If you agree to participate in market research or user testing, we may process your identity, contact, audio/visual, and feedback data to analyze your feedback and identify areas for improvement in our website and/or products and services.

Additionally, we may collect and process personal information from other individuals, such as representatives of corporate clients, healthcare professionals, or event attendees, in the course of our business activities. This information is used for purposes related to the provision of our products and services, business development, and marketing activities.

Customers

When you register a user account on our website, we collect your identity and contact information. To manage and administer your account, we process various types of data, including identity, contact, technical, usage, transaction, assessment, audio/visual, and marketing and communications data. Certain information, such as your assessment data, is needed to evaluate your suitability for treatments. Depending on the product or service you’re interested in, we may also process your audio/visual and/or health data for this purpose. When you make purchases, we use your identity, contact, transaction, and financial data to process and fulfil the transaction. Additionally, we may process your audio/visual and/or health data, where necessary, to assess your suitability and prescribe prescription medication.

Some of our products and services require or allow you to consult with a medical professional. To facilitate these consultations, we process your identity, contact, audio/visual, and assessment data.

We may use anonymized data for clinical research, service and treatment improvement, and to enhance public understanding of health treatment effectiveness. Your personally identifying data will not be provided to third-party researchers unless you’ve explicitly consented or there’s a legal basis for disclosure.

If you participate in market research, provide a customer testimonial, or give feedback to The Family Health Group, we may process your identity, contact, transaction, audio/visual, and feedback data.

By signing up to our mailing list or opting-in during checkout to receive information on freebies, product discounts, and special offers, we will send you information about our products and services based on your marketing preferences. We may also use your contact and marketing data to deliver advertisements via social media channels, in line with your preferences. When you interact with our social media channels, the respective social media company will also process your personal data as joint controllers.

As a customer, we may also use your data to:

• Administer and manage our relationship with you, including responding to communications.
• Send transactional and service messages related to your order or account.
• Provide customer service and support.
• Investigate and respond to your complaint.
• Detect and fix technical problems and maintain the website.
• Analyse, assess, and improve the website and our product and service offerings.
• Manage the day-to-day operations of our business, such as administering a centralized data warehouse, data backup and recovery, and obtaining insurance policies.
• Comply with legal or regulatory requirements and help establish, exercise, or defend legal claims.

Additionally, we may use your data in other ways that are compatible with the purposes outlined above and that are necessary for the functioning of our business, such as conducting internal research, developing new products or services, and ensuring the security of our systems and data.

Special notice to customers registering on our Website

When you register a user account on our Website to receive our product or service, you consent to the creation of an online patient record. This record will include communications, personal details, and order history. These records are retained for a minimum of 8 years after the last consultation.

By asking us to inform your GP you are confirming that you consent to the transfer of your data by email to the GP service you specify.

Security and International Data Transfers

Security

We are committed to ensuring the security and integrity of our Site and the systems used to process your personal data. We adhere to widely accepted standards of technology and operational security to prevent accidental loss, unauthorized access, or unlawful use of personal information. While we have implemented appropriate technical and organizational measures, no method of electronic storage or transmission online is completely secure. Therefore, we cannot guarantee the absolute security of your personal data or accept responsibility for any unauthorized access or loss of personal data beyond our control.

Access to your personal information is limited to those with a genuine business need to know it. Those processing your information do so in an authorized manner and are bound by a duty of confidentiality.

We have procedures in place to address any suspected data security breach and will promptly notify you in the event of such a breach that may expose you to serious risk.

We recommend that our users take sensible steps to secure their data online, such as following guidance from the NHS and BCS Chartered Institute for IT on keeping online health and social care records safe and secure.

International Data Transfers

In the normal conduct of our business processes your information will be stored and processed in the UK.

When personal information is shared with third parties as described in the section “Who We Share Your Personal Information With” below, these parties may be located outside the United Kingdom. For example, some of our service providers supporting our services are based in the United States, involving the transfer of personal information to the USA. When we transfer your personal information outside the United Kingdom, we ensure it receives a similar level of protection by implementing appropriate safeguards. This may include relying on an adequacy decision, or implementing International Data Transfer Agreements or Standard Contractual Clauses, where appropriate.

Who We Share Your Personal Information With

We may share and disclose your personal information with the following categories of third parties for the purposes described in this Privacy Policy:

• Your General Practioner: Where you have asked us to notify your GP, you are consenting to us sharing your details with them. It is your responsibility to ensure the correct contact details are provided.
• Partner Clinicians: When you register an account and purchase a product or service, your contract is with The Family Health Group. However, to provide our services to you, The Family Health Group may share your personal information with our Partner Clinicians and Dispensing Partners. These clinicians act as independent data controllers and provide services including patient consultations, assessing treatment appropriateness, and prescribing medication. All our Partner Clinicians are registered in the United Kingdom with the General Pharmaceutical Council and hold accredited pharmacist independent prescriber qualifications. Our Dispensing Partners are fully accredited and regulated.
• Service Providers: We use various suppliers who perform functions on our behalf or assist us in providing products and services. These include cloud-based software providers, online storage providers, web hosting providers, email service providers, and web analytics providers. Our service providers are required to keep your personal information confidential and are only allowed to use it for the services they perform for us.
• Professional Advisors: We may disclose personal information to our professional advisers, such as lawyers, auditors, accountants, and insurers, as necessary for them to perform their professional services.
• Business Transfers: In the event of a sale, transfer, or merger of part of our business or assets, we may share personal information with third parties involved in such transactions. The new owners may use your personal information in the same way as described in this Privacy Policy.
• Compliance with Laws: We may disclose personal information as required to comply with the law.
• Verification Partners: We share information with our verification partner Lexis Nexis.
  Our verification partner will match your data to a database of public resources to determine whether the information you have provided us with is indeed correct. The data we pass on to our verification partner are the following:
  • First name and last name.
  • Date of birth.
  • Address.

Please refer to our general Website Terms of Use and Terms of Sale for further information on the roles of our partners and third parties.

Our Use of Cookies and Similar Technologies

In our efforts to enhance your browsing experience, we employ cookies and other information-gathering technologies to gain valuable insights into how you interact with our website. These technologies allow us to personalize your experience, deliver relevant content, and improve the functionality and performance of our Website.

You have the ability to manage your cookie preferences by adjusting your browser settings to either block some or all cookies or to receive notifications when websites attempt to set or access cookies. However, please be aware that disabling or refusing cookies may result in certain parts of our site becoming inaccessible or not functioning correctly. For more detailed information on the cookies we use and how they enhance your browsing experience, we recommend reviewing our Cookie Policy.

Third-Party Links and Services

Our website may include links to third-party websites, plugins, and applications. Clicking on these links or enabling these connections may allow third parties to collect or share data about you. While we strive to provide only quality links to reputable and secure websites, we do not have control over these third-party websites and their privacy practices. Therefore, we cannot be held responsible for the protection and privacy of any information you provide while visiting such sites. We advise you to exercise caution and review the privacy policies of any third-party websites you visit.

Data Retention

We are committed to retaining your personal information only for as long as necessary to fulfill the purposes for which it was collected, including meeting legal, accounting, or reporting requirements. Our retention period is determined by factors such as the nature and sensitivity of the information, the potential risks of unauthorized use or disclosure, the purposes of processing, and any legal requirements.

Marketing

If you receive marketing communications from us, you have the right to opt out at any time by utilizing the unsubscribe links provided in our marketing messages or by contacting our Data Protection Officer at [email protected]. It is important to note that opting out of marketing communications does not affect the receipt of important service-related communications.

Your Rights

Under applicable data protection laws, you have certain rights regarding your personal information. These rights include:

• The right to request access to your personal information and supplementary information.
• The right to request correction of incomplete or inaccurate information.
• The right to request erasure of your personal information in certain circumstances.
• The right to receive your personal information in a structured, commonly used, and machine-readable format and transmit it to a third party in certain situations.
• The right to object to the processing of your personal information for direct marketing purposes.
• The right to object to automated decision-making and profiling in certain situations.
• The right to object to our continued processing of your personal information in certain situations.
• The right to request restriction of processing of your personal information.
• The right to withdraw your consent to our processing of your personal information where consent was obtained.

To exercise any of these rights, please contact The Family Health Group Data Protection Officer at [email protected] and provide sufficient information to identify yourself. We may need to request specific information to confirm your identity and may contact you for further information to expedite our response.

Accessing your personal information or exercising any of these rights is generally free of charge. However, we reserve the right to charge a reasonable fee for unfounded, repetitive, or excessive requests or to refuse to comply in these circumstances. We aim to respond to legitimate requests within one month, but complex requests may require longer processing times. In such cases, we will notify you and keep you updated on the progress of your request.

Changes to this Notice

We are committed to ensuring that you are always informed about how we use your personal information. As part of this commitment, we will update this Privacy Policy from time to time to reflect any changes in our practices or to comply with changes in applicable laws or regulatory requirements. We encourage you to review this Privacy Policy periodically to stay informed about how your personal information is being used.