This is Our Privacy Statement which details how We use your personal data (“Personal Data”) when you use Our Website www.cleverbeauty.com. We take Our data protection responsibilities seriously.

1 Privacy Statement

1.1 This Website is owned by Pharma-e Limited (“Pharma-e”) a company registered in Guernsey at Albert House, South Esplanade, St Peter Port, Guernsey, GY1 1AJ with Company No. 36207. Pharma-e’s registration number with the Office of the Data Protection Commissioner in Guernsey is 10629. 1.2 The Data Protection (Bailiwick of Guernsey) Law 2017 (the “Regulations”) set out Our responsibilities. We have to protect your data.

1.3 This Privacy Statement sets out the way We will obtain and hold your Personal Data. This is known as “Processing”. When read together with Our Terms and Conditions of Sale and Cookie Policy, this Privacy Statement covers Our relationship with you in relation to this Website. By continuing to browse and use this Website, you agree to this Privacy Statement. If you disagree with any part of this Privacy Statement, please do not use Our Website.

1.4 Any questions, comments and requests you may have regarding this Privacy Statement are welcomed and should be addressed to: Data Protection Officer, Pharma-e Limited, Healthxchange Pharmacy, Albert House, South Esplanade, Guernsey, GY1 1AW. Telephone 01481736837

2 Data Protection Regulations

2.1 For the purposes of this Privacy Statement: (a) We determine the purposes for which and the manner in which your personal data is, or is to be processed, and we are known as the data controller (“Data Controller”); and

(b) in submitting your data and information to us to collect, handle and process, you will be the individual who is the subject of the data (the “Data Subject”); and

(c) in processing your data and information, any other parties contracted to process data by the Data Controller will be known as (“Data Processors”).

3. What information do We collect from you?

3.1 We may collect and process the following data and information that you give us if you fill in the Account Registration Form, nominate a Prescriber, place an order for Goods, or if you submit content on Our Website or by corresponding with us by phone email or otherwise: (a) name, date of birth and job title;

(b) contact information including address, email address, phone number;

(c) information necessary for the purposes of submitting a prescriber application, such as medical registration numbers, pin numbers, professional details and an image of your passport or driving licence;

(d) patient names and address; prescriber name, and medication prescribed and directions for use;

(e) payment card information.

(f) Recordings of phone calls to our offices or Customer Service Centre as well as other communications such as email and electronic messaging which may be used for staff training and audit purposes. For compliance purposes our recording equipment is muted while bank or payment card details are being discussed.

3.2 We understand that the data collected at 3.1(c) and 3.1(d) is Sensitive Personal Data.

3.3 We will collect and process the following data automatically from your visit to Our Website:

(a) technical information, including the internet protocol (IP) address used to connect your computer to the Internet, your login information, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform;

(b) information about your visit, including the full uniform resource locator (URL), clickstream to, through and from Our Website (including date and time), products you viewed or searched for, page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), methods used to browse away from the page, and any phone number used to call Our customer service number and any other anonymised data or metrics that identify user behavior and the habits of web visitors.

4. Cookies

4.1 By visiting this website, you consent to its use of cookies to distinguish you from other users. The use of cookies in no way gives Us access to your computer or any Personal Data, other than the data and information you choose to share with Us.

4.2 You may choose to accept or decline cookies by modifying your own browser’s settings.

4.3 Further information on the cookies We use and how they work is available in Our Cookie Policy.

5. How do We use the information?

5.1 We shall use the data and information you give to Us: (a) to allow you to create an account and nominate prescribers on the Website;

(b) to process and analyse your order(s) including dispensing and dispatching the products and processing your payments;

(c) to keep and maintain Our internal business records;

(d) for our internal training purposes;

(e) to provide you with Our own tailored marketing information that We think may suit your interests and needs;

(f) to provide you with marketing and promotional information from carefully restricted third party pharmaceutical manufacturers and medical software providers that We think may suit your interests and needs.

5.2 We reserve the right to add to the list of uses in clause 5.1. We shall not use pre-collected data and information for any new uses of your data without consulting you and obtaining your express consent if we a required under the Regulations.

5.3 Where you provide us with information for the purposes of account or prescriber registration and orders described above, We may use such information provided in order to verify the information provided, process your application and order. We may also transfer the data to our Data Processors in order to fulfil or analyse your order.

5.4 We reserve the right to anonymise your data to obtain analysis while retaining your privacy.

6. How do We handle your information?

6.1 The data and information We collect from you will be transferred to and securely stored by our hosting third party: Alternative Solutions Limited, PO Box 176, Cirrus House, Garenne Park, Rue de la Gache, St Sampson, Guernsey GY1 3LQ.

6.2 We are committed to ensuring that your data and information is secure. In order to prevent unauthorised access or disclosure, We have put in place suitable physical, electronic and managerial procedures to safeguard and secure the information We collect online, including:

(a) all data and information you provide to us is stored on secure servers;

(b) any payment transactions will be encrypted Using SSL technology;

(c) where We have given you (or where you have chosen) a password which enables you to access certain parts of Our Website, you are responsible for keeping this password confidential. We ask you not to share a password with anyone;

(d) erasing of information, and destruction of any copies kept;

(e) regularly updating our review procedure.

6.3 Any Sensitive Personal Data that we collect as described at clause 3.1(c) and 3.1(d) shall be processed in accordance with the Regulations, and only to permit Us to process your request or enquiry. Your Sensitive Personal Data will be stored securely and will not be passed on to third parties.

7. To whom may We disclose your information?

7.1 In providing us with data and information, you agree that We may disclose such information, where necessary for the purposes and uses listed in clause 5, to: (a) Our employees, agents representatives and any Data Processors officially contracted to process the data on Our behalf;

(b) selected third parties including:

(i) business partners, suppliers and sub-contractors for the performance of any contract We enter into with you;

(ii) analytic and search engine providers that assist us in the improvement and optimisation of Our Website;

(iii) payment card merchants who comply with PCI/DSS requirements;

(c) any other third parties We are legally obliged to disclose your information to.

7.2 In providing Us with Personal Data you agree that, subject to your express consent, We may disclose such data and information to carefully restricted third party pharmaceuticals manufacturers for their marketing and promotional purposes.

7.3 We will only disclose your Personal Data to parties who bare sufficient legal responsibility for its protection and who have sufficient privacy and security measures in place to reasonably ensure that it will be protected and handled appropriately.

7.4 We may disclose your Personal Data to third parties:

(a) in the event that We sell or buy any business or assets, in which case We will disclose your Personal Data to the prospective seller or buyer of such business or assets;

(b) if Our assets, or substantially all of Our assets are acquired by any third parties, in which case personal data held by it about Our customers will be one of the transferred assets;

(c) if We are under a duty to disclose or share your personal data in order to comply with any legal obligation, or in order to enforce or apply Our terms of use; or to protect Our rights, property or safety of Our customers or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction.

8. How can I control the use of my information?

8.1 You may choose to restrict the collection or use of your Personal Data in the following way: If you have previously agreed to us using your Personal Data for direct marketing purposes, you may change your mind at any time by writing to us at Data Protection Officer, Pharma-e Limited, Healthxchange Pharmacy, Albert House, South Esplanade Guernsey GY1 1AJ.

8.2 The Regulations gives you the right to access information held about you. Your right of access can be exercised in accordance with the Act. Any access request will be free. If you would like a copy of the information held on you please write to us at Data Protection Officer, Pharma-e Limited, Healthxchange Pharmacy, Albert House, South Esplanade, Guernsey, GY1 1AJ.

8.3 If you believe that any information We are holding on you is incorrect or incomplete, please write to or email us as soon as possible, at the above address. We will promptly correct any information found to be incorrect.

9. Changes to Privacy Statement

9.1 We reserve the right to make changes to this policy without notice from time to time by updating this page. Every time you wish to use Our Website, please check the statement to ensure you understand the terms that apply at that time.

9.2 The current statement was made effective as of August 2018 and incorporates the requirements of the General Data Protection Regulation (GDPR) implemented on 25th May 2018.

10. Your right to complain

10.1 If you believe that your information held by us is not being handled properly, you have the right to complain to the Data Commissioner.

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