Privacy

Identity of the Data Controller and Contact Details

Our Privacy Policy

MyAdvocates respects your privacy and is committed to protecting your personal data.

We are committed to using your personal information in accordance with our responsibilities. We won’t do anything with your information you wouldn’t reasonably expect. We are required to provide you with the information in this Privacy Notice under applicable law which includes (but is not limited to):

• the UK version of the General Data Protection Regulation (EU) 2016/679 which is part of UK law by virtue of the European Union Withdrawal Act 2018 (the "GDPR"), and the Data Protection Act 2018; and

• the Privacy and Electronic Communications (EC Directive) Regulations 2003

This Privacy Notice applies to the personal information of individuals who interact with MyAdvocates. This Privacy Notice does not apply to the personal information of MyAdvocates employees. If you are employed by MyAdvocates please contact us and we will advise you of the applicable Privacy Notice for your situation.

Processing of your personal information is carried out by or on behalf of Daro Consulting Limited (trading as “MyAdvocates”) which is a company incorporated in the United Kingdom with company number 11301156 registered at 87 Whitmore Gardens, London, United Kingdom, NW10 5HE.

If you have any queries about our Privacy Notice, please get in touch with our data protection team:

Email: privacy@myadvocates.info

This privacy policy explains in detail the way in which any personal data you provide to us is used and kept safe by MyAdvocates. It applies whenever we collect, store and use your personal data (including when you contract with us, use our website, or other digital platforms). We know there's a lot of information here, but we want you to be fully informed about your rights, and how MyAdvocates uses your data, so please take the time to read it.

It's likely that we'll need to update this privacy policy from time to time. We'll notify you of any significant changes, but you're welcome to come back and check it whenever you wish.

Our registration with the UK’s Data Protection Regulator (the ICO) is: Daro Consulting Ltd Reference: ZB413996.

Who we are and about this privacy policy

About MyAdvocates

MyAdvocates enables medical doctors to communicate with users via a third-party platform in order to discuss non-urgent health concerns.

For simplicity throughout this policy, 'we' and 'us' means MyAdvocate

Your trust in our data security and privacy is at the heart of what we do. It's not enough to ask you to trust us, we have to show that we are trustworthy. Being transparent about what we do with any personal data needed to provide our software is key to that.

About this privacy policy

This privacy policy explains what information we may collect about you, how we may use it, and the steps we take to ensure that it is kept secure. We also explain your rights in respect of your personal data.

So you are fully aware of how and why we are using your data, it is important that you read this privacy policy together with any other privacy notice or fair processing notice we may provide on specific occasions. These additional documents are intended to complement this privacy policy.

Our websites may include links to third-party platforms, 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 applications and are not responsible for their privacy statements. When you leave any of our website, we encourage you to read the privacy policy of every website and application you visit.

How is your personal data collected?

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

Direct interactions. You may give us your personal information by filling in forms, using any of our communication software or by corresponding with us by post, phone (we may record or monitor phone calls to make sure we are keeping to legal rules, codes of practice and internal policies, and for quality assurance purposes), email or otherwise.

When you directly give us information

We may collect and store information about you when you interact with us. For example, this could be when you:

• get in touch with us via phone, website, registration link or other method of communication;

• submit an enquiry

• register for or use our services

• give us feedback

• make a complaint

• apply for a job

• enter into a contract with us

If we provide you with services, we may collect information from:

• Your employer in order for us to verify who you are and enable you to use our services.

• Other third parties we work with, such as agents working on our behalf,

• Automated technologies or interactions. As you interact with our websites and mobile applications, we may automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies and other similar technologies.

Provided by someone acting on your behalf

We collect from:

• Our partners, in relation to your services, such as people providing you with mobile applications, medical treatment or health assessments.

• Organisations who carry out customer-satisfaction surveys or market research on our behalf, or who provide us with statistics and other information to help us to improve our products and services.

• Sources which are available to the public, such as the edited electoral register or social media.

The data we collect about you

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:

• Identity Data includes first name, maiden name, last name, username or similar identifier, marital status, title, GMC Number, date of birth and gender

• Health Data includes any information relating to your mental or physical health including details and conditions surrounding treatment received

• Contact Data includes billing address, email address and telephone numbers

• Financial Data includes bank account details and details about your payments

• Transaction Data includes details about payments to and from you

• Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access our websites

• Profile Data includes your username and password, your interests, preferences, feedback and survey responses

• Usage Data includes information about how you use our websites, products and services

• Marketing and Communications Data includes your preferences in receiving marketing from us and your communication preferences

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 services). In this case, we may have to cancel a service you have with us but we will notify you if this is the case at the time.

How 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 you provide us with explicit consent

• Where we need to perform the contract we are about to enter into, or have entered into with you

• 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

*Legitimate Interest 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.

• Where we have a legal or regulatory obligation to use your personal information, for example, when our regulators, the GMC, the Information Commissioner's Office (ICO) ask us to maintain certain records of any dealings with you

• Where we need to use your personal information to establish, exercise or defend our legal rights, for example when we are faced with any legal claims, or where we want to make any claims ourselves

• Where we need to use your personal information for reasons of substantial public interest, such as investigating fraudulent claims and carrying out fraud, credit and anti-money laundering checks

• Where we have an appropriate legitimate business need to use your personal information such as maintaining our business records, developing and improving our products and services, all whilst ensuring that this business need does not interfere with your rights and freedoms and does not cause you any harm

• Where we need to use your sensitive personal information such as health data because it is necessary for your vital interests, an example would be a life or death matter

Purposes for which we will use your personal data

We have set out below, in a table, 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.

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 grounds we are relying on to process your personal data where more than one ground has been set out in the table below.

Purpose/Activity Type of data Lawful basis for processing including basis of legitimate interest

To register you as a new user (a) Identity

(b) Health

(b) Necessary to comply with our legal obligations

To register you as a Health Professional (a) Identity

(d) GMC Number (a) Performance of a contract with you

Using MyAdvocates Services (a) Identity

(b) Health

(b) Necessary to comply with our legal obligations

To manage our relationship with you which will include:

(a) Notifying you about changes to our terms or privacy policy

(b) Asking you to leave a review or take a survey (a) Identity

(b) Health

(d) Profile

(e) Marketing and Communications (a) Performance of a contract with you

(b) Necessary to comply with a legal obligation

To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data) (a) Identity

(b) Health

(d) Technical (a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise)

(b) Necessary to comply with a legal obligation

To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you (a) Identity

(b) Health

(d) Profile

(e) Usage

(f) Marketing and Communications

(g) Technical (a) Necessary for our legitimate interests (use of strictly necessary cookies)

(b) Necessary for reasons of substantial public interest

To use data analytics to improve our website, products/services, marketing, customer relationships and experiences (a) Technical

(b) Health

(c) Usage (a) Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy)

(b) Necessary for reasons of substantial public interest

To make marketing suggestions and recommendations to you about goods or services that may be of interest to you (a) Identity

(b) Health

(d) Technical

(e) Usage

(f) Profile (a) Consent, where the individual has given clear consent for us to process their personal data for a specific purpose

(b) Necessary for our legitimate interests (to develop our products/services and grow our business)

Notifying you about changes to our privacy policy (a) Contact (a) Necessary to comply with a legal obligation

Opting out

You can ask us to stop sending you marketing messages at any time by contacting us at admin@myadvocates.info.

You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly. For more information about the cookies we use, please see our cookie policy.

Automated decision-making and profiling

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.

Disclosures of your personal data

We may have to share your personal data with the parties set out below for those purposes set out in table 'Purposes for which we will use your personal data':

Internal Third Parties

Other companies within MyAdvocates acting as joint controllers or processors and who provide IT and system administration services and undertake leadership reporting.

External Third Parties

• Service providers acting as processors who provide IT and system administration services, support services and commissioned services.

• Professional advisers acting as processors or joint controllers based in the United Kingdom including registered doctors, auditors, banking, legal, insurance and accounting services

• HM Revenue & Customs, regulators and other authorities acting as processors or joint controllers based in the United Kingdom who require reporting of processing activities in certain circumstances

• Fraud detection agencies and other third parties who operate and maintain fraud detection registers

• Regulatory authorities such as the Financial Conduct Authority and the Information Commissioner's Office.

• Third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. 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 policy.

We use the following categories of service providers:

• Cloud Web and App Hosting Services

• Corporate Communications Platforms

• Approved Doctors

• Secure Chat Channels

• Nature Language Processing and Machine Translation Platforms

• Professional Service Providers such as Lawyers, Solicitors and Accountants

• Financial Transaction Providers

• Telecoms Service and Carrier Providers

This list may be updated from time to time so for an updated list of third parties you should check this Privacy Policy periodically.

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.

International transfers

Some of our external third parties are based outside the UK or European Economic Area (EEA) so their processing of your personal data may involve a transfer of data outside the UK or EEA.

Whenever we transfer your personal data out of the UK or EEA, we ensure the same level of protection is afforded to it by ensuring an appropriate safeguard is implemented.

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, Health Professionals, 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.

Data retention

How long will you use my 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.

If you would like more information about how long we will keep your information for, please contact us at admin@myadvocates.info.

Your legal rights

Under certain circumstances, you have rights under data protection laws in relation to your personal data. You have the right to:

• 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 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. 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: (a) if you want us to establish the data's accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) 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 (d) 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 certain products or services to you. We will advise you if this is the case at the time you withdraw your consent

• Where any automated decision making and profiling has taken place, you have the right to obtain human intervention, express your point of view, and obtain an explanation of the decision and to challenge it.

If you wish to exercise any of the rights set out above, please contact us at admin@myadvocates.info.

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 may 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 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.

Data protection contacts

If you have any questions, comments, complaints or suggestions regarding any aspect of your personal data or this privacy policy, please contact our Data Protection Officer privacy@myadvocates.info.

You have a right to make a complaint at any time to your local privacy supervisory authority. MyAdvocates's main establishment is in the UK, where the local supervisory authority is the Information Commissioner's Office (ICO). You can also contact the Information Commissioner's Office using their online form: https://ico.org.uk/global/contact-us/email/

(www.ico.org.uk)

However we would appreciate the chance to address your concerns before you approach the ICO, so please contact us in the first instance.