Privacy Policy

Our promise to you

Whether you are a registered patient or a member of our digital community, your personal data is of the utmost importance to My Menopause Centre. We use your data to provide an excellent healthcare service, relevant and helpful communications and to facilitate your interaction with our online community. We value the trust you place in us and will never misuse your data or abuse it in any way.

As a registered provider of healthcare services, we take great care when handling your sensitive data. We understand the importance of protecting your right to privacy, and as a wholly-digitalised business, have taken great care to ensure we keep your personal data safe and secure.

Our reputation depends on the integrity of our service to you, therefore, we remain committed to the ongoing review of our data storage and processing to give you peace of mind. We will remain open and honest, and comply with the transparency obligations of your right to be informed.

You will find detailed information here about how we collect, process and store your personal data in line with the UK General Data Protection Regulation (UK GDPR).

Who are we?

My Menopause Centre Limited is a company registered in England and Wales with company number 12586554.

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 how we process your information, please do not hesitate to get in touch by contacting our Data Protection Officer:

• Phone number: 0333 444 1067
• Email address: hello@mymenopausecentre.com

What type of information do we hold about you?

We currently collect and process personal information about you, including your name, age, and contact details. We also collect what is classed as ‘special category data’ – personal data that needs more protection because it is sensitive. Specifically, this includes:

• personal data revealing racial or ethnic origin
• data concerning health, including lifestyle, menopause, and mental health symptoms
• data concerning a person’s sex life.

We use special category data to help us assess your individual needs and provide the right treatment, products, and services.

How we get the information and why we have it

Most of the personal, sensitive, and medical information we process is provided to us directly by you. You are responsible for the accuracy of the information that you provide to us.

We also receive personal information indirectly, from the following sources in the following scenarios:

Information and accuracy

For us to provide the level of service and care that you need it is really important that the information you provide at any point during your engagement with My Menopause Centre is accurate and up to date. If there are any changes to your contact details or personal information or if information relating to your health changes, please let us know. You can do so by telephoning us on 0333 444 1067.
You are responsible for the accuracy of the information you provide to us and we will not be responsible for any losses arising from any inaccurate, incomplete, inauthentic, or deficient data that you provide to us.

If you fail to provide personal data

Where we need to collect personal data by law, or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with goods or services). In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.

Building a profile about you

We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy policy.

We collect anonymous information on our website via Google Analytics and Hotjar. We collect some information on how you interact with our website, such as using cookies or device IDs, to monitor our digital platform and the efficiency of our service. We do this so that we can continually improve our content and provide you with the very best customer experience.

We also use HubSpot analytics to monitor and analyse web traffic and to keep track of user behaviour.

Lawful rights to process data

Under the UK General Data Protection Regulation (GDPR), the lawful bases we rely on for processing this information are:

• (a) Your consent. You are able to remove your consent at any time. You can do this by contacting the Data Protection Officer at hello@mymenopausecentre.com. 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.
• (b) We have a contractual obligation. This means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.
• (c) We have a legal obligation.
• (d) We have a legitimate interest. This means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights 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). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.

Our lawful basis for processing special category data under Article 9 is:

• (e) Explicit consent
• (f) Health or social care (with a basis in law)

We meet the associated condition in UK law, set out in Part 1 of Schedule 1 of the DPA 2018, to store and process special category data for Health or social care purposes (Schedule 1, Part 1 (2).

Change of purpose

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 legal 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.

What we do with the information we have

We use the information that you have given us in order to:

• Add you to our contacts database to ensure you receive relevant communications from our company and community, pause.
• Provide a personalised assessment on completion of the online Menopause Questionnaire
• Create an accurate patient record
• Better assess your needs, lifestyle, and symptoms to provide appropriate and necessary care
• Process your online appointment booking
• Process online prescription ordering and fulfilment
• Processing blood tests using our third-party service, Medichecks
• Create, edit and maintain your patient records in our digital platform, Heydoc

Where necessary, we may also use and disclose your personal data:

• As part of regulatory requirements to audit consultations, your data, and other interactions with our service. This enables My Menopause Centre to comply with the regulatory and compliance standards to which we are bound.
• Compile your data as part of any aggregated research into the menopause and its associated impacts.

Strict confidentiality and data security provisions will apply at all times to any such audit and data use. We may share this information with:

• Semble – our patient management software
• Medichecks – our blood test service partner
• Pharmacierge or Smartway Pharma – our prescription ordering and fulfilment partner(s)
• Specific health authorities, NHS trusts, legal authorities, and ambulance services

There are times where you may be required to provide My Menopause Centre with specific permission to use and access your data. At these times, My Menopause Centre will provide you with all the details required in order for you to make your decision.

Updating your personal information

If you would like to change the information we hold about you, or want your information removed from our database, please contact us by advising that you wish to make a change by emailing the Data Protection Officer at hello@mymenopausecentre.com. You can use the “unsubscribe” option which will be included in our marketing email communications to opt-out of our marketing emails.

How we store your information

Your information is securely stored in the following locations:

• Amazon Web Services (AWS)
• Heydoc encrypted servers
• HubSpot encrypted servers

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. In some circumstances you can ask us to delete your data: see your legal rights above for further information. 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.

Financial information

We do not collect or process any payment information. All payment details entered into our website are processed through our third-party processor ‘Stripe’ and you can refer to their website to see how they will store all payment information and transaction details. We will not retain any payment information.

Third parties

We use the following third-party providers who will each have their own privacy policy to which your personal information will be subject. We use these services to fulfil our requirements to you as MMC’s registered patients:

• Heydoc – https://www.heydoc.co.uk/privacy-policy
• Medichecks – https://medichecks.com/pages/privacy-policy
• Pharmacierge – https://www.pharmacierge.com/privacy-policy
• Smartway Pharma – https://www.smartrx.co.uk/RxPad/privacypolicy
• HubSpot – https://legal.hubspot.com/privacy-policy
• Stripe – https://stripe.com/en-gb/privacy

We use Google products and Hotjar to track the performance of our website:

• Google – https://privacy.google.com/businesses/compliance
• Hotjar – https://www.hotjar.com/legal/policies/privacy

We keep your medical records in accordance with national guidelines – Records Management Code of Practice 2020 – A guide to the management of health and care records. We will dispose your information in line with best practice described in the guidance. Many of our external third parties are based outside the UK so their processing of your personal data will involve a transfer of data outside the UK. Whenever we transfer your personal data out of the UK, we ensure a similar degree of protection is afforded to it. Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the UK.

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.

Your data protection rights

Under data protection law, you have rights including:

• Your right of access – You have the right to ask us for copies of your personal information. You can make a subject access request to see the personal information we hold about you.
• Your right to rectification – You have the right to ask us to rectify information you think is inaccurate. You also have the right to ask us to complete information you think is incomplete.
• Your right to erasure – You have the right to ask us to erase your personal information in certain circumstances.
• Your right to restriction of processing – You have the right to ask us to restrict the processing of your information in certain circumstances.
• Your right to object to processing – You have the right to object to the processing of your personal data in certain circumstances.
• Your right to data portability – You have the right to ask that we transfer the information you gave us to another organisation, or to you, in certain circumstances.

You are not required to pay any charge for exercising your rights. If you make a request, we have one month to respond to you. Please contact us at Data Protection Officer at hello@mymenopausecentre.com if you wish to make a request. 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.

Links to other websites

Our website contains links to other websites. Please note that we are not responsible for the privacy practices of other websites. This Privacy Policy applies solely to information collected by this website and all other methods as identified above.

Marketing

We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising, the following personal data control mechanisms:

Promotional offers from us

We may use your Identity, Contact, Technical, Usage, and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services, and offers may be relevant for you (we call this marketing).
You will receive marketing communications from us if you have requested information from us or purchased [goods or services] from us and you have not opted out of receiving that marketing.

Opting out

You can ask us or third parties to stop sending you marketing messages at any time (by logging into the website and checking or unchecking relevant boxes to adjust your marketing preferences OR by following the opt-out links on any marketing message sent to you OR by contacting us at any time). Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a product/service purchase, warranty registration, product/service experience or other transactions.

How to complain

Please contact us at hello@mymenoapusecentre.com if you wish to make a complaint.

You can also complain to the ICO if you are unhappy with how we have used your data.

The ICO’s address is:

Information Commissioner’s Office
Wycliffe House
Water Lane
Wilmslow
Cheshire
SK9 5AF

Helpline number: 0303 123 1113