Privacy Notice

The Website is operated by Health Bridge Limited, trading as ZAVA.

We are registered in England and Wales under company number 07392646 and our head office and trading address is: Health Bridge Limited t/a ZAVA, 46 Essex Rd, London N1 8LN.

We are registered with the ICO (Information Commissioner’s Office) under number Z2715245.

Our Data Protection Officer can be contacted by emailing [email protected].

We are what is known as a data controller. In terms of the Data Protection Act 2018, that means we are trusted to look after and deal with your personal information in accordance with this policy. We determine the ways and means of processing and must therefore be accountable for it.

As a data subject, you have rights in respect of our processing of your personal data.

Your right of access: you have the right to ask us for copies of your personal information.

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 - unless it’s a legal requirement,or we have a valid business reason not to delete it. As a healthcare provider, we will not always be able to delete your data for the following reasons:

• continuity of healthcare provision. We need to be able to know what treatments we have provided to you in the same way as your GP. For example, providing relevant information to other healthcare professionals providing care to you if we need to (for example, do we know of any allergies or any bad reactions to a certain ingredient etc). For this reason, we will not delete your medical record as well as any communications between you and our team related to your request of a medical service.
• establishment, exercise or defence of legal claims.

Based on the guidance published by the General Medical Council which states that doctors should follow the UK Department of Health and Social Care guidance on how long health records should be kept, we will keep this data until 10 years after the patient’s death. Telephone calls with our doctors can be recorded and stored for up to 30 days for clinical governance purposes. Written consultation notes will be kept in your patient record thereafter.

You can ask us to suspend your electronic patient account by clicking on the suspend button in your online account. Your account will stop working immediately and you will no longer be able to access your account. You will also cease to receive any further notifications in relation to your account, but the data will not be erased.

Your right to restriction of processing: you have the right to ask us to restrict the processing of your information in certain circumstances. For example, because you believe that your data is incorrect or the processing of your data is unlawful.

Your right to object to processing: you have the right to object to our processing your information if the legal basis is a legitimate interest.

Your right to data portability: this only applies to information you have given us. You have the right to ask that we transfer the information you gave us from one organisation to another, or give it to you. The right only applies if we are processing information based on your consent or under a contract, or in talks about entering into one, and the processing is automated.

If you want to exercise any of these rights, please email us at [email protected] and state the nature of your request in the subject line. (For example, Access Request, Deletion request etc).

You also have the right to lodge a complaint about our processing with a supervisory authority. In the UK that is the Information Commissioner’s Office (ICO).

Our promise to you

• Our security measures protect you against unauthorised access, changes, disclosure or destruction of your data.
• We regularly review our security measures, including how we collect, process, and store data. Part of this means encrypting data and putting in place physical security measures to protect our storage systems. We are Cyber Essential Plus certified.
• Your payment transaction and your personal data are encrypted using SSL technology.
• Every member of our staff signs and agrees to a confidentiality agreement when they start working for us and are trained in relevant data protection regulations.
• Access to your data is only given to employees on a need-to-know basis.
• All our suppliers have to abide to privacy undertakings, in accordance with the applicable data protection laws and regulations.

To see more about how we use your personal data, read the notice or notices which apply best to your relationship with us:

1. I am an Asda Online Doctor by ZAVA patient
2. I am just browsing your website
3. I am a research participant
4. I am a supplier

As a patient of Asda Online Doctor by ZAVA, we hold the following information about you:

Identity details

When you set up an account with us, you will provide your name, date of birth, gender, and you might also have to provide an ID in order for us to check your identity.

We also generate a patient ID in order to identify you in a pseudonymised manner wherever possible.

Contact details

When you set up the account, the identifier and username of our services is your email address.

The email address is used to send you alerts to let you know that you have a service related email in your patient account and also to send marketing emails to you if you have not opted out.

We will email you about prescriptions reminders, basket abandonment, and reviews if you have not opted out to these.

We process your delivery address in order to deliver your treatment. This is also required on the prescription and as a billing address for payment purposes.

If you provided a phone number, it is used to send information to you in relation to the service you requested. We do not currently use your phone number for marketing purposes. If we decide to do so, we will ask for your consent.

Medical information

We hold information about your health and medical history that you provide us with when you complete our medical assessments on the website. This includes:

• photos (when applicable)
• information you provided when communicating with our doctors or Patient Care team
• treatments that our doctors prescribed to you
• your test results
• referral letters
• fit notes

This data is required to enable our doctors to do the diagnosis and provide treatment or advice to you.

We might also obtain information from your GP when we or you inform your GP of the treatments we provided to you.

Financial information

When you make a payment to us, we will process your payment data. However, we do not act as a payment provider, so we do not store your card details, we just pass them directly to the provider. We do however have access to the following transaction details:

• type of card
• bank details
• last 4 digits of your card
• billing address
• transaction IDs

Those details are not directly saved by us, but we are able to access them in order to assist you or if there is a payment dispute. In the case of a dispute, we would store the details of the transaction until the dispute is settled.

Technical Information

When you are browsing our website, or using our services, we will automatically collect technical information such as the type of device you’re using, browser, IP address, screen size etc.

This allows us to understand any issues with our website, show you relevant information (like pharmacies near you), and for the prevention of fraud.

Browsing activity and usage details

When using our website, if cookies are loaded, we will process information about the pages you have visited, your searches, load and download times, time spent on our pages, interaction with the page (click, scrolling, mouse-overs), and what led you to our website (like a link in an article or a Google search etc).

We perform analytics based on this data. Performing analytics is vital for us to understand how you interact with our website and various services in order to improve them and to give you a good user experience.

Marketing information

We store your consent status and the type of marketing you are subscribed and unsubscribed to.

Data used for research purposes

In some circumstances we will anonymise or aggregate your personal data (so that it can no longer be associated with you) for research or statistical purposes.

Aggregated data is derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity.

Data that does not identify an individual does not fall under the UK or EU GDPR.

If you have participated in research or feedback surveys, we will store the different surveys you have participated in and your survey responses.

Please find below the purpose of our processing, the type of data processed, and the lawful basis used to process the data (article 6 and 9 of UK GDPR, or schedule 9 and 10 of Data Protection Act 2018).

Purpose: To register you as a new customer.

Type of data: Identity details (e.g. name, surname, gender, date of birth), contact details (e.g. email, telephone number, address).

Lawful basis: Performance of a contract.

Purpose: To provide the medical service as requested by you. To perform the diagnosis, issue a prescription when appropriate, and for the delivery of your treatment or goods. To follow-up on the treatments and advice given by our doctors.

Type of data: Identity details (e.g. name, surname, gender, date of birth); medical details provided in the online questionnaire, treatment prescribed, messages between the patient and our doctors and Patient Care team, prescription, contact details (e.g. email, telephone number, address).

Lawful basis: Performance of a contract and medical diagnosis, provision of health care and treatment pursuant to the contract between the patient and us.

Purpose: To verify that you actually are who you say you are.

Type of data: Identity details (e.g. name, surname, gender, date of birth), contact details (e.g. email, telephone number), financial data (e.g transaction details such as date, amount, name, address, email).

Lawful basis: Legitimate interests (to prevent identity or medical fraud).

Purpose: To prevent fraud and maintain security on our website (e.g. suspicious connection to our website outside the countries we operate in). To improve your browsing experience based on your technical device information.

Type of data: Technical details (e.g. technical device information such as type of device used, browser used, IP address, location, device unique identifier, network information, login information).

Lawful basis: Legitimate interests.

Purpose: To collect and recover money owed to us. To provide you with updates about your transaction (e.g. has the payment succeeded?)

Please note: we do not store card data on our end. The payment process is delegated to a third party supplier certified to process payments.

Type of data: Financial data (e.g. name, email, last 4 digits of the payment card, billing address, delivery address, cardholder address, time and date of the transaction).

Lawful basis: Performance of a contract and legitimate interests to prevent fraud.

Purpose: To understand the behaviours of the visitors on our website.

Type of data: Usage details (e.g. browsing information such as clickstream, your searches on our website, load and download time, time spent on our pages, interaction with the page such as clicks, scrolling, and mouse-overs), IP address, identity details (anonymous ID, patient ID when logged in on the website).

Lawful basis: Legitimate interests.

Purpose: Marketing. In order to send you relevant information, news, advice, recommendations, and offers.

This data can be processed to send information only to certain patients (e.g only women within a certain age range).

Type of data: Identity details (e.g. name, gender, age), contact details (e.g. email, telephone number), order details.

Lawful basis: Legitimate interests.

Note: soft opt-in under PECR allows us to send marketing communications to an existing customer. You can unsubscribe at any time.

Purpose: Marketing - medically targeted. Medical data will be used to serve you with more medically specific content adapted to the condition you came to see us for.

Type of data: Health information (data provided in the medical questionnaire).

Lawful basis: Explicit consent.

You can withdraw consent and/or unsubscribe at any time.

Purpose: Advertising. To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you.

Type of data: Technical details (IP address), usage (page viewed), system assigned ID number.

Lawful basis: Legitimate interests (to study how customers use our products and services, to develop them, to grow our business and to inform our marketing strategy).

Purpose: Research and statistics

Type of data: Identity details (e.g. name, gender, age), information provided during the surveys, interviews and research sessions.

Lawful basis: Depending on the type of research, legitimate interest or consent.

Within Asda Online Doctor by ZAVA:

Your medical information and identity details are shared amongst our doctors to provide quality and continuity of care. Our Patient Care team might also need to access your record to assist you in your query and verify your identity before releasing any information to you.

Our IT department might need to access your account if there is a technical issue to solve or in order to enhance the tools we’re using.

Finally, the compliance/legal team might also access your information in order to send you data when you make a data subject request.

All our staff are bound to strict confidentiality undertakings and have had initial and ongoing data protection training.

Asda Online Doctor by ZAVA implements an access right policy and this allows access to the data only on a need to know basis.

With third parties and processors:

Like most companies, we use a number of suppliers as part of our data processing, for example cloud services, technology services, carriers. Your data is being shared with ASDA Stores Limited for the dispensing of your prescription. For marketing purposes, research and analytics, we are also using suppliers such as email platform providers, analytics software, survey tools.

We have data processing agreements in place with these providers to secure the use of your data by these suppliers.

If data is transferred from the UK to the EEA or from the EEA to the UK, then it is done so on the basis of those countries receiving the data are having a comparable data protection regime to the country sharing the data (adequacy)

Where data is transferred outside of the EEA, we ensure that appropriate protection and mechanisms are in place, for example with Standard Contractual Clauses with additional due diligence.

In order to provide the medical service to you and for security purposes, we need to share your personal data with third parties including payment providers.

As regulated healthcare providers, we might need to disclose some of your information including personal data and medical data, including but not limited to:

• The medical regulators who inspect our service and premises (Care Quality Commission and General Pharmaceutical Council).
• Other regulators such as the General Medical Council and the Information Commissioner Office if you make a complaint or in case of an investigation.
• Your GP with your consent or based on your vital interests
• Other healthcare partners such as laboratories.

Finally, we may need to share your information for legal reasons:

• Should we sell or buy any business or assets, we may need to share your data with the future seller or buyer.
• If we are asked to share your personal data as a result of a court order, legal processing or any other legal obligation.
• To protect the rights, property, or safety of Asda Online Doctor by ZAVA, our patients, suppliers and partners, or others. This includes exchanging information for fraud protection, reducing credit risk and verifying your identity by an ID&V provider.

Rest assured, we only share information that is absolutely necessary and we go to great lengths to make sure everyone we work with takes your privacy as seriously as we do.

Medical records

We follow the NHS Records Management Code of Practice for Health and Social Care 2016 and therefore keep your health record for 10 years after your death, or after we are made aware that you have left the EU. Note that the records include your identity data, medical data and contact details and the messages exchanged with our doctors and Patient Care team.

Account details

If you registered with us and have not ordered any service, we will retain this data until you notify us that you want to stop using our service and ask for your data to be deleted unless we have a legal or regulatory reason to keep them.

If you’ve ordered from us or had any exchanges with our doctors about your health or if you are making any claim, we will keep these data as per the paragraph above (Medical Records) and in order to defend our rights and interests in case of a dispute or a claim.

Note that the account cannot be deleted but suspended which means that access is revoked. If we have no reason to keep the data as explained above, we will anonymise the account.

Research

If you have provided your data for research purposes, we retain the data for 4 years. After 4 years, the data is anonymised and so no longer falls under the data protection regulations

Analytics

Data about the usage of our services and technical data used for analytics are retained in a pseudonymous manner for as long as you have a non-suspended account with us or until you action a right to erasure.

Marketing

Data used for marketing purposes is retained for as long as you have a non-suspended account with us until you ask for the deletion of your non-medical data. If you ask to unsubscribe to marketing, then the data is moved to a suppression list to ensure that there is no danger of you being added to any marketing lists in the future.

As a user of our website and depending on the cookie preferences you gave, we collect your individual usage data which includes information about how you use our website, products, and services. This is used to create aggregated data.

If cookies are loaded, we will process information about the pages you have visited, your searches on our website, load and download times, time spent on our pages, interaction with the page (click, scrolling, mouse-overs) and what led you to our website (like a link in an article or a Google search etc).

We perform analytics based on this data. Performing analytics is vital for us to understand how you interact with our website and various services in order to improve them and to give you a good user experience.

We do not use your browsing data to predict or make any assumptions about you.

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 the patient privacy notice.

Note: For the browsing data while on www.asda.com, please refer to their privacy notice directly.

Our lawful basis for processing your data is legitimate interest for security purposes and for business purposes.

Like most companies, we use a number of suppliers as part of our data processing, for example cloud services, technology services, and analytics tools. We have data processing agreements in place with these providers. If data is transferred from the UK to the EEA or from the EEA to the UK, then it is done so on the basis of those countries receiving the data are having a comparable data protection regime to the country sharing the data (adequacy). Where data is transferred outside of the EEA, we ensure that appropriate protection and mechanisms are in place, for example Standard Contractual Clauses.

Finally, we may need to share your information for legal reasons:

• Should we sell or buy any business or assets, we may need to share aggregated data with the future seller or buyer.
• If we are asked to share your personal data as a result of a court order, legal processing or any other legal obligation.
• To protect the rights, property, or safety of Health Bridge Limited, our patients, suppliers and partners, or others. This includes exchanging information for fraud protection, reducing credit risk and verifying your identity by an ID&V provider.

Rest assured, we only share information that is absolutely necessary and we go to great lengths to make sure everyone we work with takes your privacy as seriously as we do.

If any usage and technical data are linked to you directly once you register with us, we will keep them until you ask for the deletion of your data or until you inform us that you want to stop using our services.

As a research participant of Asda Online Doctor by ZAVA, we hold the information you provide when answering a survey, or participating in an interview, face to face or remotely.

We hold personal data and aggregated data such as statistical or demographic data.

Once data is aggregated it is not considered personal data, as you cannot be identified from it directly or 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 the patient privacy notice.

We use these data in order to continually get feedback on our services and understand our customers’ expectations and experiences.

When you use our website we also collect additional information. Please see our web browsing privacy notice for more details.

Our lawful basis for processing your data is based on legitimate interest or consent depending on the type of research made.

If you provided consent, you may withdraw this consent at any time by emailing Patient Care team or your research team contact.

Like most companies, we use a number of suppliers as part of our data processing, for example cloud services and technology services. In order to perform the interviews, we might reach out to external agencies and use tools to record sessions, your image and/or voice.

We have data processing agreements in place with these providers to secure the use of your data by these suppliers.

Where data is transferred outside of the EEA, we ensure that appropriate protection and mechanisms are in place.

Finally, we may need to share your information for legal reasons:

• Should we sell or buy any business or assets, we may need to share your data with the future seller or buyer.
• If we are asked to share your personal data as a result of a court order, legal processing or any other legal obligation.

Rest assured, we only share information that is absolutely necessary and we go to great lengths to make sure everyone we work with takes your privacy as seriously as we do.

If research data is linked to you as an individual then, we will keep the data for 4 years.

As a supplier of Asda Online Doctor by ZAVA, we hold information about you that you provided as part of our negotiations, our due diligence results and also the information provided in order to put contracts in place between our companies.

We also hold your data in order to pay you for the services provided.

When you use our website we also collect additional information. Please see our web browsing privacy notice for more details.

Our lawful basis for processing your data is either based on performance of the contract and/or to defend our rights in case of claims and/or legal obligation.

We might have to share your data to third parties due to a legal obligation (for example, to financial authorities).

If data is transferred from the UK to the EEA or from the EEA to the UK, then it is done so on the basis of those countries receiving the data are having a comparable data protection regime to the country sharing the data (adequacy). Where data is transferred outside of the EEA, we ensure that appropriate protection and mechanisms are in place, for example Standard Contractual Clauses.

We may need to share your information for legal reasons:

• should we sell or buy any business or assets, we may need to share your data with the future seller or buyer
• if we are asked to share your personal data as a result of a court order, legal processing or any other legal obligation
• to protect our rights, property, or safety

Rest assured, we only share information that is absolutely necessary and we go to great lengths to make sure everyone we work with takes your privacy as seriously as we do.

We will keep your data for the duration of our contract and for a period of 7 years after the end of our relationship or longer if submitted due to a legal or regulatory obligation.

Please note, this privacy notice explains our processing of your data when using our website onlinedoctor.asda.com (the "website") and our services. The website is run and operated by Health Bridge Limited, trading as ZAVA (“ZAVA”), a trusted partner of Asda Stores Limited ("Asda"). By using the website you are transacting with Health Bridge Limited. Although Asda has authorised its trade mark to be used in conjunction with the website, Health Bridge Limited is solely responsible for all orders made through the website, save for the dispensing and/or dispatch of medication by Asda that is the responsibility of Asda.