Privacy Policy

Website and Privacy Policy

This privacy policy was last updated in March 2022

Please read this privacy notice (‘Notice’) carefully to understand how Millbrook Healthcare looks after your Personal Data.

We have set this Notice out in a layered format so you can click quickly navigate to the specific areas set out below.

1. WHO WE ARE AND WHAT THIS NOTICE COVERS

2. PERSONAL DATA WE COLLECT ABOUT YOU

3. HOW WE COLLECT YOUR PERSONAL DATA

4. HOW WE USE YOUR PERSONAL DATA

5. AUTOMATED TECHNOLOGIES

6. DISCLOSURES OF YOUR PERSONAL DATA

7. INTERNATIONAL TRANSFERS

8. DATA SECURITY

9. DATA RETENTION

10. YOUR LEGAL RIGHTS

 

1.               WHO WE ARE AND WHAT THIS PRIVACY NOTICE COVERS

What This Privacy Notice Covers

This Notice covers our online data collection activities, including Personal Data that we collect when you visit our Mi-Guardian website and purchase a subscription to our Mi-Guardian service.

This website is not intended for children and we do not knowingly collect data relating to children.

Who We Are

Millbrook Healthcare Ltd is the controller of your personal data and is responsible for keeping it safe (collectively referred to as "MHC", "we", "us" or "our" in this privacy policy).

We have appointed a data protection officer (DPO) who is responsible for overseeing questions in relation to this privacy policy. If you have any questions about this privacy policy, including any requests to exercise rights, please email [email protected]

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). It’s our priority to ensure you are satisfied with our data processing practices. If you do find you have a complaint, we would appreciate the chance to try and resolve any issues you have before you approach the ICO.

Changes to the privacy policy and your duty to inform us of changes

We keep this Notice under regular review. It is important that the Personal Data we hold about you is accurate and current. Please keep us informed if your Personal Data changes during your relationship with us.

Third-party links

This website 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 websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy policy of every website you visit.

2.               PERSONAL DATA WE COLLECT ABOUT YOU

Depending on how you interact with us (online, over the phone, email, etc) and whether you are an end user of our service, we collect various types of data from you which we have grouped together as follows:

  • Identity Data: this includes your first name and last name.
  • Contact Data: this includes your postal address, billing address, e-mail and contact number.
  • Financial Data: this includes your bank account information, sort code and account number.
  • Transaction Data: this includes details about your subscription payments to us for the services you have purchased.
  • Call Data: this includes call recordings, frequency of calls and type of calls made between you and us via our customer service team or our 24/7 monitoring centre.
  • Technical Data: this includes your operating system type, web browser type, Internet Protocol (IP) address, device type, time zone, geo location and browser plug-in types and version that you provide to us when you visit our website.
  • Profile Data includes your username and password, identity and contact data, and subscription service information. 
  • Usage Data as you navigate through and interact with our website or newsletter, we use automatic data collection technologies to collect certain information about your actions. This includes information such as which links you have clicked on, which pages or content you have viewed and for how long, and other similar information and statistics about your interactions, such as the length of your visits to certain pages. Please see section 5 for how these technologies work.
  • Marketing Data this includes your preferences for receiving email marketing from us.
  • Health Data (end user only): this includes your medical history and conditions, medications, allergies, Healthcare professionals’ details, sensory needs and any other relevant information you provide us to ensure we can competently provide you our service.
  • Emergency Contact Data (end user only): this includes details about your nominated network of contacts such as friends, family or carers who we can call to provide you assistance when required.

3.               HOW WE COLLECT YOUR PERSONAL DATA

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

Direct interactions. We receive your Identity, Contact, Financial, Transaction, Profile, Marketing, Health and Emergency Contact Data when you:

  • go through the checkout process on our website;
  • when you set up a Direct Debit and make subscription payments for our Mi-Guardian service;
  • create an account on our website;
  • subscribe to our email newsletter;
  • request marketing to be sent to you;
  • contact us via email or phone;
  • when we contact you in our Welcome Call;
  • when you are referred to us by a local authority;

Website, Newsletter and Phone Call Interactions. We automatically collect your Technical, Usage and Call Data when you:

  • interact with our website or newsletter;
  • make or request a call to or from our customer service team;
  • trigger a call to or response from our 24/7 monitoring centre;

Some of this information is captured using automated technologies such as website cookies, log files, web beacons and third-party tracking. For further information about how these technologies work, please see Section 5.  

External Sources. We receive some of your Technical and Usage Data, about your online interactions, from third parties such as Google, Facebook and Bing which we use to deliver relevant online advertising to you and to improve our website and service. Please see Section 5 for more details.

4.               HOW WE USE YOUR PERSONAL DATA

The table below provides a description of the various purposes for which we use your Personal Data and the lawful basis we rely on to do so. Please note that not all of the uses below will be relevant to every individual.

How we use your Personal Data Type of Data Lawful Basis
 

 To register you as a new customer for our Mi-Guardian   service. This includes:

  • setting up your account in the Welcome call and collecting important information such as your Health Data and Emergency Contact Data.
  • sending you your device welcome pack
  • setting up your Direct Debit payment for our Mi-Guardian service

(a) Identity

(b) Contact

(c) Financial

(d) Profile

(e) Health

(f) Emergency Contact

 (a) Performance of a contract with you*

 

 (b) Explicit consent (we ask for your explicit consent to   collect  and process your Health Data)

 To process Direct Debit payments for our Mi-Guardian   service. 

 (a) Financial

 (b) Transaction

 

 (a) Performance of a contract with you*

 We and our payment processing provider(s) handle payment   and financial information in a manner compliant with   applicable laws, regulations and security standards such as   PCI DSS.

 To respond to customer enquiries we receive by email, over the phone or via our website contact form.

(a) Financial

(b) Transaction

(a) Performance of a contract with you*

We and our payment processing provider(s) handle payment and financial information in a manner compliant with applicable laws, regulations and security standards such as PCI DSS.

To respond to customer enquiries we receive by email, over the phone or via our website contact form.

(a) Identity

(b) Contact

(c) Call

(a) Necessary for our legitimate interests (to provide quality service to our customers and improve our business services)
 

To process and deliver your Mi-Guardian device via our courier provider which includes:

·        providing delivery tracking; and

notifying you at what time you should expect your delivery.

(a) Identity

(b) Contact

(a) Performance of a contract with you*

To manage our relationship with you which includes:

·        Notifying you about changes to our terms and conditions or privacy policy;

·        Providing you call assistance with device setup or device diagnostic issues;

·        Providing you key updates about our service;

·        Reminding you to update your details from time to time;

Asking you to leave a review or take a survey;

a) Identity

(b) Contact

(c) Profile

(d) Marketing

(a) Performance of a contract with you

(b) Legitimate interests (to keep our records updated and to improve our service)

To process your VAT exemption (where applicable) which includes sharing your data with HMRC (where applicable) to demonstrate your VAT exemption.

(a) Identity

(b) Health

(a) Necessary to comply with a legal obligation
To send you email marketing for similar goods and services you previously purchased from us, or to market the goods and services of our business partners.

(a) Identity

(b) Contact

(c) Marketing

 

(a) Necessary for our legitimate interests (to send you email marketing for similar good and services you previously purchased from us. We will always ensure you can opt-out of this at the time you provide your email to us and within every email you receive. This is known as a “soft opt-in” under PECR. You can read more about his here.)

(b) Consent (we rely on your consent to market our business partners goods or services to you)

We record calls made to our customer service team or 24/7 monitoring centre. We also record the frequency of calls made and type of calls triggered. We use you Call Data to ensure we are providing a quality customer service, to resolve customer complaints promptly, for staff training purposes, and to improve our service offering.

(a) Identity

(b) Call

(a) Necessary for our legitimate interests (to ensure quality customers service, to resolve customer complaints promptly, for staff training purposes, and to improve our service offering)

If you are an end user of our Mi-Guardian service, we use your data for the following purposes:

·        To identify you when a call is triggered to our 24/7 monitoring centre.

·        To notify your emergency contacts if you need assistance

·        To notify emergency services if you require assistance and also share your Health data with them (where necessary) so they can respond accordingly

·        To notify your Healthcare professional (with your permission) where required

(a) Identify

(b) Contact

(c) Heath

(d) Nominated Contact

(a) Performance of a contract with you*

(b) Necessary for our legitimate interests (we rely on legitimate interests to provide our service to end users who do not have direct contractual relationship with us)

(c) Vital Interests (this is relevant where we need to share your data with emergency services in emergency situations)

(d) Explicit Consent (to process your Health Data outside of emergency situations)

To deliver and measure the effectiveness of our marketing strategy which includes:

·        delivering relevant advertisements to you

understanding how you engage and interact with our website, emails and advertisements to better improve the effectiveness of the advertising we serve to you and to optimise customer website experience

(a) Usage

(b) Technical

(c) Marketing

(a) Consent (we rely on your consent to place any non-essential cookies on your browser)

(b) Necessary for our legitimate interests (to inform and improve the effectiveness of our customer engagement strategy)

In the event Millbrook Healthcare Ltd or its assets are acquired by or merged with another company including through bankruptcy, we will share your Personal Data with any of our legal successors.

We will also disclose your Personal Data to third parties:

(a) when required by applicable law;

(b) in response to legal proceedings;

(c) in response to a request from a competent law enforcement agency;

(d) to protect our rights, privacy, safety or property, or the public; or

(e) to enforce the terms of any agreement or the terms of our Website.

(a) All data categories

(a) Necessary to comply with a legal obligation

(b) Necessary for our legitimate interests (to protect our assets and staff)

     

 


5.               AUTOMATED TECHNOLOGIES

We collect some of your data via automated technologies which is broken down into the following categories:

Cookies. A cookie is a small text file that is stored on your browser that collects your Technical and Usage data. You can set your browser to refuse all or some cookies that websites would like to store on your browser. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly.

Log Files. We collect information in the form of log files that record website activity and gather statistics about your browsing habits. These entries are generated automatically, and help us to troubleshoot errors, improve performance and maintain the security of our website.

Web Beacons. Web beacons (also known as “web bugs”) are small strings of code that deliver a graphic image on a web page or in an email for the purpose of transferring data back to us. The information collected via web beacons will include information such as IP Address, as well as information about how you respond to an email campaign (e.g. at what time the email was opened, which links you click on in the email, etc.). We use web beacon information for a variety of purposes, including but not limited to, site traffic reporting, unique visitor counts, advertising, email auditing and reporting, and personalisation.

For more information on these automated technologies, please read our cookie policy [LINK [MF2] TO YOUR COOKIE POLICY].

6.               DISCLOSURES OF YOUR PERSONAL DATA

We share your Personal Data with the following categories of third-party providers to deliver our services:

Services Providers:

These are external companies that we use to help us run our day-to-day service function which includes order fulfilment providers, payment processing providers, fraud detection and identity verification providers, website operation and hosting providers, customer relationship management providers and IT system administration providers.

Professional Service Advisers:

These are professional service advisers who help us meet our legal and regulatory compliance requirements which includes auditors (financial and cyber security), legal practitioners, banks and insurers.

Marketing Providers:

These are external providers we use to help us create and deliver our marketing strategy which includes marketing agencies who run our paid advertising campaigns, advertising networks such as Google, Facebook and Bing, and data analytics providers such as Google Analytics.

Under Our Instruction. All providers, and their selected staff, are only allowed to access and use your Personal Data on our behalf for the specific tasks that they’ve been requested to carry out, based on our instructions, and are required to keep your Personal Data confidential and secure. The only exception is if we are required by law to disclose your Personal Data such as to HMRC for auditing purposes.

No sale of personal information to third parties. We do not and will not sell your Personal Data to third parties in any situation unless it is within the context of a merger and acquisition.

 

7.               INTERNATIONAL TRANSFERS

Some of our service and marketing providers may host your Personal Data outside the UK. Whenever this occurs, we ensure a similar degree of protection is afforded to your Personal Data by implementing one of the following safeguards:

  • Only transferring your Personal Data to countries that have been deemed to provide an adequate level of protection to that of the UK.
  • Utilising UK Standard Contractual Clauses which ensures your Personal Data is provided the same protection it has in the UK.

Please contact us at [email protected] if you would like further information on the specific mechanism used by us.

 

8.               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 on a need-to-know basis only. They will only process your personal data on our instructions and are subject to a duty of confidentiality.

 

9.               DATA RETENTION

How long will you use my personal data for?

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.

 

10.            YOUR LEGAL RIGHTS

Under certain circumstances, you have the following rights in relation to your personal data:

Request access to your personal data (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.

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. 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 legitimate interests (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. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.

Request restriction of processing of your personal data. 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.
  • You have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.

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.

Withdraw consent at any time where we are relying on consent to process your personal 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 you our services and may need to end the contract between us. We will advise you if this is the case at the time you withdraw your consent.

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

No fee usually required

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.

What we may need from you

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.

Time limit to respond

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.

Integrated Governance, Millbrook Healthcare Ltd, Calmore Industrial Park, Nutsey Lane, Totton, Hampshire, SO40 3XJ

© 2021 Millbrook Healthcare Ltd | Registered in England and Wales, Company No, 833987.