0203 370 4321 
London 
www.dosegb.com (our website) is provided by Burlington Pharma Ltd (‘we’, ‘our’ or ‘us’). We are the controller of personal data obtained via our website, meaning we are the organisation legally responsible for deciding how and for what purposes it is used.
We take your privacy very seriously. Please read this privacy policy carefully as it contains important information on who we are and how and why we collect, store, use and share any information relating to you (your personal data) in connection with your use of our website. It also explains your rights in relation to your personal data and how to contact us or a relevant regulator in the event you have a complaint.
We collect, use and are responsible for certain personal data about you. When we do so we are subject to the UK General Data Protection Regulation (UK GDPR).
This version of our privacy policy is primarily written for adults, including parents and guardians of child users.
By clicking the “I Accept” box at a point of registration and each time you make a payment, submitting your personal data to us, and using the Website you are accepting the practices described in this Privacy Policy.
This privacy policy is divided into the following sections:
- What this policy applies to
- Personal data we collect about you
- How your personal data is collected
- How and why we use your personal data
- Marketing
- Who we share your personal data with
- How long your personal data will be kept
- Transferring your personal data out of the UK
- Cookies
- Your rights
- Keeping your personal data secure
- How to complain
- Changes to this privacy policy
- How to contact us
What this policy applies to
This privacy policy relates to your use of our website only.
Throughout our website we may link to other websites owned and operated by certain trusted third parties for your convenience (eg make additional products and services available to you)]. Those third-party websites may also gather information about you in accordance with their own separate privacy policies. For privacy information relating to those third-party websites, please consult their privacy policies as appropriate.
Personal data we collect about you
The personal data we collect about you depends on the particular activities carried out through our website. We will collect and use the following personal data about you:
- your name, address and contact information, including email address and telephone number
- information to check and verify your identity, eg date of birth
- your gender,
- location data, (if you choose to give this to us)
- medial data and prescriptions you have ordered
- your billing information, transaction and payment card or other payment method information
- bank account and payment details
- details of any information, feedback or other matters you give us by phone, email, post or via social media
- your account details, such as username and login details
- your activities on, and use of, our website
- your professional online presence, eg LinkedIn profile
- information about the services we provide to you
- your contact history, purchase history and saved items
- information about how you use our website and technology systems
- your responses to surveys, competitions and promotions
If you do not provide personal data we ask for where it is ‘required’, it may delay or prevent us from providing products and services to you.
We collect and use this personal data for the purposes described in the section ‘How and why we use your personal data’ below.
- directly, when you enter or send us information, such as when you register with us, contact us (including via email), send us feedback, purchase products or services via our website, post material to our website and complete customer surveys or participate in competitions via our website, and
- indirectly, such as your browsing activity while on our website; we will usually collect information indirectly using the technologies explain in the section on ‘Cookies’ below
- where you have given consent
- to create and maintain your customer account
- to enable the provision of health services to you
- to handle orders and payments
- to allow you to participate in interactive features of our Website and services
- to communicate to you any changes to our services, website, goods or products
- to respond to queries, complaints and refunds
- for the purpose of record keeping
- to track and analyse activity on our Website
- to comply with our legal and regulatory obligations
- for the performance of a contract with you or to take steps at your request before entering into a contract, or
- for our legitimate interests or those of a third party
A legitimate interest is when we have a business or commercial reason to use your information, so long as this is not overridden by your own rights and interests. We will carry out an assessment when relying on legitimate interests, to balance our interests against your own. You can obtain details of this assessment by contacting us (see ‘How to contact us’ below).
The table below explains what we use your personal data for and why.
| What we use your personal data for | Our reasons |
|---|---|
| Create and manage your account with us | To perform our contract with you or to take steps at your request before entering into a contract |
| Providing products and services to you | To perform our contract with you or to take steps at your request before entering into a contract |
| Conducting checks to identify you and verify your identity or to help prevent and detect fraud against you or us | To comply with our legal and regulatory obligations and for our legitimate interests or those of a third party, ie to minimise fraud that could be damaging for you and/or us |
| Conducting checks to identify you and verify your identity or to help prevent and detect fraud against you or us | To comply with our legal and regulatory obligations and for our legitimate interests or those of a third party, ie to minimise fraud that could be damaging for you and/or us |
| To enforce legal rights or defend or undertake legal proceedings | Depending on the circumstances
|
| Customise our website and its content to your particular preferences based on a record of your selected preferences or on your use of our website | Depending on the circumstances
If you have provided such a consent you may withdraw it at any time by eg by changing the setting on the cookies tool. However, that will not affect the lawfulness of our use of your personal data in reliance on that consent before it was withdrawn. |
| Retaining and evaluating information on your recent visits to our website and how you move around different sections of our website for analytics purposes. This helps us to understand how people use our website so that we can make it more intuitive or to check our website is working as intended | Depending on the circumstances
If you have provided such a consent, you may withdraw it at any time by emailing your request. However, this will not affect the lawfulness of our use of your personal data in reliance on that consent before it was withdrawn. |
| Communications with you not related to marketing, including about changes to our terms or policies or changes to the products and services or other important notices | Depending on the circumstances
|
| Protecting the security of systems and data | To comply with our legal and regulatory obligationsWe may also use your personal data to ensure the security of systems and data to a standard that goes beyond our legal obligations, and in those cases our reasons are for our legitimate interests or those of a third party, ie to protect systems and data and to prevent and detect criminal activity that could be damaging for you and/or us |
| Statistical analysis to help us manage our business, eg in relation to our financial performance, customer base, product range or other efficiency measures | For our legitimate interests or those of a third party, ie to be as efficient as we can so we can deliver the best service to you at the best price |
| Updating and enhancing customer records | Depending on the circumstances
|
| Disclosures and other activities necessary to comply with legal and regulatory obligations that apply to our business, eg to record and demonstrate evidence of your consents where relevant. | To comply with our legal and regulatory obligations |
| Marketing our services to existing and former customers | For our legitimate interests or those of a third party, i.e. to promote our business to existing and former customersSee ‘Marketing’ below for further information |
| External audits and quality checks, eg for the audit of our accounts | For our legitimate interests or a those of a third party, i.e. to maintain our accreditations so we can demonstrate we operate at the highest standards |
| To share your personal data with members of our group and third parties in connection with a significant corporate transaction or restructuring, including a merger, acquisition, asset sale, initial public offering or in the event of our insolvency. In such cases information will be anonymised where possible and only shared where necessary | Depending on the circumstances
|
Certain personal data we collect is treated as a special category to which additional protections apply under data protection law:
- personal data revealing racial or ethnic origin, political opinions, religious beliefs, philosophical beliefs or trade union membership
- Medical data and genetic data
- Biometric data (when used to uniquely identify an individual)
- Data concerning health, sex life or sexual orientation
Where we process such special category personal data, we will also ensure we are permitted to do so under data protection laws.
See ‘Who we share your personal data with’ for further information on the steps we will take to protect your personal data where we need to share it with others.
Marketing
We may use your personal data to send you updates by email, text message, telephone or post about our products and services, including exclusive offers, promotions or new products and services.
We have a legitimate interest in using your personal data for marketing purposes (see above ‘How and why we use your personal data’). This means we do not usually need your consent to send you marketing information. However, where consent is needed, we will ask for this separately and clearly.
You have the right to opt out of receiving marketing communications at any time by:
- contacting us at Contact Us details below
- using the ‘unsubscribe’ link in emails or ‘STOP’ number in texts, or
We may ask you to confirm or update your marketing preferences if you ask us to provide further products and services in the future, or if there are changes in the law, regulation, or the structure of our business.
We will always treat your personal data with the utmost respect and never sell or share it with other organisations outside the Burlington Pharma group for marketing purposes.
For more information on your right to object at any time to your personal data being used for marketing purposes, see ‘Your rights’ below.
Who we share your personal data with
We routinely share personal data with:
- Your GP, where you have consented to us keeping them informed of your treatment
- Our suppliers and other third parties whom we rely on to deliver our services (for example, we may share your name and postal address with a courier)
- Other business entities within the Burlington Pharma Ltd group
- Analytics and search engine providers that assist us in the improvement and optimisation of our Website. Your personal data is generally shared in a form that does not directly identify you
- Public authorities where we are required by law to do so
- Legal partners, if required, to receive legal advice
- Another legal entity, on a temporary or permanent basis, for the purposes of a joint venture, collaboration, financing, sale, merger, reorganisation, change of legal form, dissolution or similar event. In the case of a merger or sale, your personal data will be permanently transferred to a successor company
- Third party service providers and consultants in order to protect the security or integrity of our business, including our databases and systems, for business continuity reasons and the prevention of fraud
- third parties we use to help deliver our products and services to you, eg payment service providers, warehouses and delivery companies
We only allow those organisations to handle your personal data if we are satisfied, they take appropriate measures to protect your personal data
We or the third parties mentioned above may occasionally also need to share personal data with:
- external auditors, eg in relation to the audit of our accounts, in which case the recipient of the information will be bound by confidentiality obligations
- professional advisors (such as lawyers and other advisors), in which case the recipient of the information will be bound by confidentiality obligations
- law enforcement agencies, courts, tribunals and regulatory bodies to comply with our legal and regulatory obligations
- other parties in connection with a significant corporate transaction or restructuring, including a merger, acquisition, asset sale, initial public offering or in the event of our insolvency—usually, information will be anonymised, but this may not always be possible, however, the recipient of the information will be bound by confidentiality obligations
If you would like more information about who we share our data with and why, please contact us (see ‘How to contact us’ below).
Patient Confidentiality
Your medical data may be collected via our online medical questionnaires, telephone and web consultations, secure messaging as well as photographic assessments. None of our staff can access your medical data unless they are a health professional, or owe a similar duty of confidentiality.
Your medical data will not be used for marketing purposes unless you give us your permission to use your medical data this way. Your medical data will never be disclosed without your consent unless legally required or permitted to do so.
How long your personal data will be kept
We will not keep your personal data for longer than we need it for the purpose for which it is used. Different retention periods apply for different types of personal data. If you stop using your account, we will delete or anonymise your account data after seven years. Following the end of the of the relevant retention period, we will delete or anonymise your personal data.
Transferring your personal data out of the UK and EEA
The EEA and other countries outside the UK have differing data protection laws, some of which may provide lower levels of protection of privacy.
It is sometimes necessary for us to share your personal data to countries outside the UK. In those cases we will comply with applicable UK and EEA laws designed to ensure the privacy of your personal data.
As we are based in the UK we will also transfer your personal data from the EEA to the UK.
We will also ensure all protections required by applicable UK laws are in place before transferring personal data to any organisation or body (or its subordinate bodies) governed by public international law or set up by, or on the basis of, an agreement between two or more countries (international organisations).
Under data protection laws, we can only transfer your personal data to a country outside the UK or EEA or to an international organisation where:
- in the case of transfers subject to UK data protection law, the UK government has decided the particular country ensures an adequate level of protection of personal data (known as an ‘adequacy regulation’) further to Article 45 of the UK GDPR.
- in the case of transfers subject to EEA data protection laws, the European Commission has decided that the particular country ensures an adequate level of protection of personal data (known as an ‘adequacy decision’) further to Article 45 of the EU GDPR.
- there are appropriate safeguards in place, together with enforceable rights and effective legal remedies for you, or
- a specific exception applies under relevant data protection law
Where we transfer your personal data outside the UK, we do so on the basis of an adequacy regulation or (where such is not available) legally-approved standard data protection clauses recognised or issued further to Article 46(2) of the UK GDPR. In the event we cannot or choose not to continue to rely on either of those mechanisms at any time we will not transfer your personal data outside the UK unless we can do so on the basis of an alternative mechanism or exception provided by UK data protection law.
Any changes to the destinations to which we send personal data or in the transfer mechanisms we use to transfer personal data internationally will be notified to you in accordance with the section on ‘Change to this privacy policy’ below.
For further information about such transfers and the safeguards we employ please contact our Data Protection Officer (see ‘How to contact us’ below).
Cookies
We may use ‘cookies’ on our website, in common with many other website providers. Most browsers automatically accept cookies, but you can usually change your browser to prevent cookies being stored.A cookie is a small text file which is placed onto your device (eg computer, smartphone or other electronic device) when you use our website. We use cookies on our website. These help us recognise you and your device and store some information about your preferences or past actions.
For further information on cookies and our use of ‘cookies’, when we will request your consent before placing them and how to disable them, please see below.
Your rights
You generally have the following rights, which you can usually exercise free of charge:
| Access to a copy of your personal data | The right to be provided with a copy of your personal dataA more detailed explanation of this right under UK law is available at the following link:-https://ico.org.uk/your-data-matters/your-right-to-data-portability/ |
| Correction (also known as rectification) | The right to require us to correct any mistakes in your personal dataA more detailed explanation of this right under UK law is available at the following link:-https://ico.org.uk/your-data-matters/your-right-to-data-portability/ |
| Erasure (also known as the right to be forgotten) | The right to require us to delete your personal data—in certain situationsA more detailed explanation of this right under UK law is available at the following link:-https://ico.org.uk/your-data-matters/your-right-to-data-portability/ |
| Restriction of use | The right to require us to restrict use of your personal data in certain circumstances, eg if you contest the accuracy of the dataA more detailed explanation of this right under UK law is available at the following link:-https://ico.org.uk/your-data-matters/your-right-to-data-portability/ |
| Data portability | The right to receive the personal data you provided to us, in a structured, commonly used and machine-readable format and/or transmit that data to a third party—in certain situationsA more detailed explanation of this right under UK law is available at the following link:-https://ico.org.uk/your-data-matters/your-right-to-data-portability/ |
| To object to use | The right to object:
A more detailed explanation of this right under UK law is available at the following link:-https://ico.org.uk/your-data-matters/your-right-to-data-portability/ |
| Not to be subject to decisions without human involvement | The right not to be subject to a decision based solely on automated processing (including profiling) that produces legal effects concerning you or similarly significantly affects youWe do not make any such decisions based on data collected by our website.
A more detailed explanation of this right under UK law is available at the following link:-https://ico.org.uk/your-data-matters/your-right-to-data-portability/ |
| The right to withdraw consents | If you have provided us with a consent to use your personal data you have a right to withdraw that consent easily at any time. You may withdraw consents by contacting us. Withdrawing a consent will not affect the lawfulness of our use of your personal data in reliance on that consent before it was withdrawn. |
For further information on each of those rights, including the circumstances in which they do and do not apply, please contact us (see ‘How to contact us’ below). You may also find it helpful to refer to the guidance from the UK’s Information Commissioner on your rights under the UK GDPR.
If you would like to exercise any of those rights, please email, call or write to us—see below: ‘How to contact us’. When contacting us please:
- provide enough information to identify yourself [(eg your full name, address and customer or matter reference number)] and any additional identity information we may reasonably request from you, and
- let us know which right(s) you want to exercise and the information to which your request relates
Keeping your personal data secure
We have appropriate security measures to prevent personal data from being accidentally lost, or used or accessed unlawfully. We limit access to your personal data to those who have a genuine business need to access it.
We also have procedures in place to deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected data security breach where we are legally required to do so.
If you want detailed information from Get Safe Online on how to protect your information and your computers and devices against fraud, identity theft, viruses and many other online problems, please visit www.getsafeonline.org. Get Safe Online is supported by HM Government and leading businesses.
How to complain
Please contact us if you have any queries or concerns about our use of your information (see below ‘How to contact us’). We hope we will be able to resolve any issues you may have.
You also have the right to lodge a complaint with:
- the Information Commissioner in the UK,
- The UK’s Information Commissioner may be contacted at https://ico.org.uk/make-a-complaint or by telephone: 0303 123 1113.
Changes to this privacy policy
We may change this privacy policy from time to time—when we make significant changes we will take steps to inform you, for example via a prominent link to a description of those changes on our website for a reasonable period or by other means, such as email.
How to complain
Individuals in the UK
You can contact us and/or our Data Protection Officer by post, email or telephone if you have any questions about this privacy policy or the information we hold about you, to exercise a right under data protection law or to make a complaint.
Our contact details are shown below:
| Our contact details | Our Data Protection Officer’s contact details |
|---|---|
|
Unit 217b Mirror Works 12 Marshgate Lane London E15 2NH 0203 370 4321 |
Mr Cheung Hoe Leong |
Do you need extra help?
If you would like this policy in another format (for example audio, large print, braille) please contact us (see ‘How to contact us’ above).