Privacy Policy

1. Introduction

In the following, we provide information about the collection of personal data when using

  • our website https://nuggmd.co.uk
  • our profiles in social media.

Personal data is any data that can be related to a specific natural person, such as their name or IP address.

1.1. Contact details

The controller within the meaning of Art. 4 para. 7 United Kingdom General Data Protection Regulation (UK GDPR) is MD Access Global Limited, Queen Victoria Street 26 Q, Reading, United Kingdom, email: support@nuggmd.co.uk. We are legally represented by Robert Jappie.

Our data protection officer can be reached via heyData GmbH, Schützenstraße 5, 10117 Berlin, Germany. Website: www.heydata.eu, E-Mail: datenschutz@heydata.eu.

1.2. Scope of data processing, processing purposes, and legal bases

We detail the scope of data processing, processing purposes and legal bases below. In principle, the following come into consideration as the legal basis for data processing:

  • Art. 6 para. 1 s. 1 lit. a UK GDPR serves as our legal basis for processing operations for which we obtain consent.
  • Art. 6 para. 1 s. 1 lit. a UK GDPR is the legal basis insofar as the processing of personal data is necessary for the performance of a contract.
  • Art. 6 para. 1 s. 1 lit. c UK GDPR applies if we fulfill a legal obligation.
  • Art. 6 para. 1 s. 1 lit. f UK GDPR serves as the legal basis when we can rely on legitimate interests.
  • Article 9(2)(a) UK GDPR is the relevant legal basis for the processing of health data based on explicit consent.
  • Article 9(2)(h) UK GDPR in conjunction with Schedule 1 of the UK Data Protection Act 2018 is the legal basis for processing health data for the purposes of preventive or occupational medicine and the provision of health or social care.

1.3. Data processing outside the EEA

Insofar as we transfer data to service providers or other third parties outside the United Kingdom (UK), the security of the data is guaranteed by:

  • UK Adequacy Regulations (Art. 45 UK GDPR), where the UK government has determined a country ensures an adequate level of protection (e.g., EEA countries, Canada).
  • In other cases (e.g., USA), the legal basis for the transfer is the International Data Transfer Agreement (IDTA) or the UK Addendum to the Standard Contractual Clauses (SCCs) pursuant to Art. 46 UK GDPR, or the UK Extension to the EU-US Data Privacy Framework where applicable.

1.4. Storage duration

Unless expressly stated in this privacy policy, the data stored by us will be deleted as soon as they are no longer required for their intended purpose. Please note that medical records and consultation notes are retained for a minimum period as required by UK Department of Health and Social Care guidelines and clinical record-keeping standards (typically 10 years or more).

1.5. Rights of data subjects

Data subjects have the following rights against us with regard to their personal data:

  • Right of access,
  • Right to correction or deletion,
  • Right to limit processing,
  • Right to object to the processing,
  • Right to data transferability,
  • Right to revoke a given consent at any time.

    • Data subjects also have the right to complain to the UK data protection supervisory authority, the Information Commissioner’s Office (ICO). Contact details are available at https://ico.org.uk/

1.6. Obligation to provide data

Within the scope of the business or other relationship, customers, prospective customers or third parties need to provide us with personal data that is necessary for the establishment, execution and termination of a business or other relationship or that we are legally obliged to collect. Without this data, we will generally have to refuse to conclude the contract or to provide a service or will no longer be able to perform an existing contract or other relationship.

Mandatory data are marked as such.

1.7. No automatic decision making in individual cases

As a matter of principle, we do not use a fully automated decision-making process in accordance with article 22 UK GDPR to establish and implement the business or other relationship. Should we use these procedures in individual cases, we will inform of this separately if this is required by law.

1.8. Making contact

When contacting us, e.g. by e-mail or telephone, the data provided to us (e.g. names and e-mail addresses) will be stored by us in order to answer questions. The legal basis for the processing is our legitimate interest (Art. 6 para. 1 s. 1 lit. f UK GDPR) to answer inquiries directed to us. We delete the data accruing in this context after the storage is no longer necessary or restrict the processing if there are legal retention obligations.

2. Newsletter

Interested parties have the option to subscribe to a free newsletter. We process the data provided during registration exclusively for sending the newsletter. Subscription takes place by selecting the corresponding field on our website, by ticking the corresponding field in a paper document or by another clear action, whereby interested parties declare their consent to the processing of their data, so that the legal basis is Art. 6 para. p. 1 lit. a UK GDPR. Consent can be revoked at any time, e.g. by clicking the corresponding link in the newsletter or notifying our e-mail address given above. The processing of the data until revocation remains lawful even in the event of revocation.

Based on the consent of the recipients (Art. 6 para. 1 s. 1 lit. a UK GDPR), we also measure the opening and click-through rate of our newsletters to understand what is relevant for our audience.

  • We send newsletters with the tool Ortto of the provider Ortto Inc., 1390 Market Street, Suite 200, San Francisco, CA 94102, USA . The provider processes content, usage, meta/communication data and contact data in the process in the USA. Further information is available in the provider's privacy policy at https://ortto.com/privacy/.

3. Data processing on our website

3.1. Notice for website visitors

Our website stores information in the terminal equipment of website visitors (e.g. cookies). This storage and access is based on the following provisions:

  • Insofar as this storage or access is strictly necessary for us to provide the service expressly requested by website visitors, it is carried out on the basis of Regulation 22 of the Privacy and Electronic Communications Regulations 2003 (PECR).
  • Otherwise, this storage or access takes place on the basis of the website visitor's consent pursuant to Regulation 22 PECR.
  • The subsequent data processing is carried out in accordance with the UK GDPR.

3.2. Informative use of our website

During the informative use of the website, i.e. when site visitors do not separately transmit information to us, we collect the personal data that the browser transmits to our server in order to ensure the stability and security of our website. This is our legitimate interest, so that the legal basis is Art. 6 para. 1 s. 1 lit. f UK GDPR.

These data are:

  • IP address
  • Date and time of the request
  • Time zone difference to Greenwich Mean Time (GMT)
  • Content of the request (specific page)
  • Access status/HTTP status code
  • Amount of data transferred in each case
  • Website from which the request comes
  • Browser
  • Operating system and its interface
  • Language and version of the browser software

This data is also stored in log files. They are deleted when their storage is no longer necessary, at the latest after 14 days.

3.3. Web hosting and provision of the website

Our website is hosted by Amazon AWS. The provider is Amazon Web Services EMEA Sàrl, Avenue John F. Kennedy 38, 1855 Luxemburg. In doing so, the provider processes the personal data transmitted via the website, e.g. content, usage, meta/communication data or contact data, in the EU. Further information can be found in the provider's privacy policy at https://aws.amazon.com/privacy/.

It is our legitimate interest to provide a website, so the legal basis of the described data processing is Art. 6 para. 1 s. 1 lit. f UK GDPR.

We use the content delivery network Cloudflare for our website. The provider is Cloudflare, Inc., 101 Townsend St., San Francisco, CA 94107, USA . The provider thereby processes the personal data transmitted via the website, e.g. content, usage, meta/communication data or contact data in the USA. Further information can be found in the provider's privacy policy athttps://www.cloudflare.com/de-de/privacypolicy/.

We have a legitimate interest in using sufficient storage and delivery capacity to ensure optimal data throughput even during large peak loads. Therefore, the legal basis of the described data processing is Art. 6 para. 1 s. 1 lit. f UK GDPR.

Legal basis of the transfer to a country outside the EEA are adequacy decision. The security of the data transferred to the third country (i.e. a country outside the EEA) is guaranteed because the EU Commission has decided as part of an adequacy decision in accordance with Art. 45 para. 3 GDPR that the third country ensures an adequate level of protection.

3.4. Contact form

When contacting us via the contact form on our website, we store the data requested there and the content of the message. The legal basis for the processing is our legitimate interest in answering inquiries directed to us. The legal basis for the processing is therefore Art. 6 para. 1 s. 1 lit. f UK GDPR. We delete the data accruing in this context after the storage is no longer necessary or restrict the processing if there are legal retention obligations.

3.5. Booking of appointments

Site visitors can book appointments with us on our website. For this purpose, we process meta data or communication data in addition to the data entered. We have a legitimate interest in offering interested parties a user-friendly option for making appointments. Therefore, the legal basis for data processing is Art. 6 para. 1 s. 1 lit. f UK GDPR. Insofar as we use a third-party tool for the agreement, the information on this can be found under "Third parties".

3.6. Customer account

Site visitors can open a customer account on our website. We process the data requested in this context based on the consent of the site visitor. We process the data requested in this context to fulfill the respective user contract concluded for the account, so that the legal basis for the processing is Art. 6 para. 1 p. 1 lit. b UK GDPR.

3.7. Offer goods and services

We offer goods and services via our website. In order to process your order and provide our healthcare-related services, we process the following categories of data:

  • Identification and Contact Data (Full name, date of birth, email address)
  • Shipping and Billing Data (Shipping address, billing information)
  • Health and Special Category Data (Medical history, health questionnaire responses, current medical conditions, medications, treatment history, and physician consultation notes)

The legal basis for processing your personal data is Article 6(1)(b) UK GDPR (performance of a contract). As we process health data, which is classified as "special category data," we also rely on Article 9(2)(h) UK GDPR (health or social care) and, where applicable, your explicit consent under Article 9(2)(a) UK GDPR.

For the technical processing of your order, the retrieval of medical records, and the physical delivery of your goods, we share your data with the following service providers:

  • Medi2Data Ltd, One Central Park, Northampton Road, Manchester, M40 5BP, United Kingdom (for clinical data extraction and medical record management)
  • Royal Mail Group PLC, 185 Farringdon Road, London, EC1A 1AA, United Kingdom (for shipping and delivery)

The transfer of data to these providers is necessary to fulfil our contract with you (Article 6(1)(b) UK GDPR). All health data is handled with the highest level of confidentiality and is stored only for as long as necessary to comply with legal record-keeping obligations in the healthcare sector.

3.8. Technically necessary cookies

Our website sets cookies. Cookies are small text files that are stored in the web browser on the end device of a site visitor. Cookies help to make the offer more user-friendly, effective, and secure. Insofar as these cookies are necessary for the operation of our website or its functions (hereinafter "Technically Necessary Cookies"), the legal basis for the associated data processing is Art. 6 para. 1 s. 1 lit. f UK GDPR. We have a legitimate interest in providing customers and other site visitors with a functional website. Specifically, we set technically necessary cookies for the following purpose or purposes:

  • to save the shopping cart
  • to save login data
  • to remember search terms
  • to enable payment providers to process payments and not to analyze user behavior

3.9. Third parties

3.9.1. heyData

We have integrated a data protection seal on our website. The provider is heyData GmbH, Schützenstraße 5, 10117 Berlin, Germany. The provider processes meta/communication data (e.g. IP addresses) in the EU.

The legal basis of the processing is Art. 6 para. 1 s. 1 lit. f UK GDPR. We have a legitimate interest in providing website visitors with confirmation of our data privacy compliance. At the same time, the provider has a legitimate interest in ensuring that only customers with existing contracts use its seals, which is why a mere image copy of the certificate is not a viable alternative as confirmation.

As the data is masked after collection, there is no possibility to identify website visitors. Further information is available in the privacy policy of the provider at https://heydata.eu/en/privacy-policy.

4. Data processing on social media platforms

We are represented in social media networks in order to present our organization and our services there. The operators of these networks regularly process their users' data for advertising purposes. Among other things, they create user profiles from their online behavior, which are used, for example, to show advertising on the pages of the networks and elsewhere on the Internet that corresponds to the interests of the users. To this end, the operators of the networks store information on user behavior in cookies on the users' computers. Furthermore, it cannot be ruled out that the operators merge this information with other data. Users can obtain further information and instructions on how to object to processing by the site operators in the data protection declarations of the respective operators listed below. It is also possible that the operators or their servers are located in non-EU countries, so that they process data there. This may result in risks for users, e.g. because it is more difficult to enforce their rights or because government agencies access the data.

If users of the networks contact us via our profiles, we process the data provided to us in order to respond to the inquiries. This is our legitimate interest, so that the legal basis is Art. 6 para. 1 s. 1 lit. f UK GDPR.

4.1. Facebook

We maintain a profile on Facebook. The operator is Meta Platforms Ireland Ltd., 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland. The privacy policy is available here: https://www.facebook.com/policy.php. A possibility to object to data processing arises via settings for advertisements: https://www.facebook.com/settings?tab=ads. We are joint controllers for processing the data of visitors to our profile on the basis of an agreement within the meaning of Art. 26 UK GDPR with Facebook. Facebook explains exactly what data is processed at https://www.facebook.com/legal/terms/information_about_page_insights_data. Data subjects can exercise their rights both against us and against Facebook. However, according to our agreement with Facebook, we are obliged to forward requests to Facebook. Data subjects will therefore receive a faster response if they contact Facebook directly.

4.2. Instagram

We maintain a profile on Instagram. The operator is Meta Platforms Ireland Ltd., 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland. The privacy policy is available here: https://help.instagram.com/519522125107875.

4.3. Tiktok

We maintain a profile on Tiktok. The operator is TikTok Technology Limited, whose registered office is at 10 Earlsfort Terrace, Dublin, D02 T380, Ireland. The privacy policy is available here: https://www.tiktok.com/de/privacy-policy.

4.4. YouTube

We maintain a profile on YouTube. The operator is Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland. The privacy policy is available here: https://policies.google.com/privacy?hl=de.

4.5. X (formerly Twitter)

We maintain a profile on X. The operator is Twitter Inc, 1355 Market Street, Suite 900, San Francisco, CA 94103, USA. The privacy policy is available here: https://twitter.com/de/privacy. One way to object to data processing is via the settings for advertisements: https://twitter.com/personalization.

4.6. LinkedIn

We maintain a profile on LinkedIn. The operator is LinkedIn Ireland Unlimited Company, Wilton Place, Dublin 2, Ireland. The privacy policy is available here: https://www.linkedin.com/legal/privacy-policy?_l=de_DE. One way to object to data processing is via the settings for advertisements: https://www.linkedin.com/psettings/guest-controls/retargeting-opt-out.

5. Changes to this privacy policy

We reserve the right to change this privacy policy with effect for the future. A current version is always available here.

6. Questions and comments

If you have any questions or comments regarding this privacy policy, please feel free to contact us using the contact information provided above.