Privacy & Cookie Policy

“We are committed to protecting your privacy and will ensure that any information you provide to us will be collected and used in accordance with the General Data Protection Regulation and the Data Protection Act 2018 and the Privacy and Electronic Communications Regulations 2003. We will not share your data with any third party except for administrative purposes relating to the services we provide and where we may be required to do so by law.” The Mole Clinic

Introduction

This privacy notice explains how The Mole Clinic, use your personal data when we are providing a service to you or you are visiting one of our websites and your legal rights in respect of our use of your data. It applies to our clients and prospective clients.

For the purpose of applicable data protection legislation (including but not limited to the UK General Data Protection Regulation (the “GDPR”), the Data protection Act 2018 and the Privacy and Electronic Communications Regulation 2003.

It is important that you read this privacy notice together with any other privacy notice we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully informed of how and why we are using your data.

1. Important Information and who we are

2. The Data we collect about you

3. How is your personal data collected

4. How we use your personal data and our legal basis for doing so

5. Disclosures of your personal data

6. International Transfers

7. Data Security

8. Data Retention

9. Your Legal Rights

10. Glossary

1. Important Information and who we are

Data Controller

The Mole Clinic is the data controller and responsible for your personal data (collectively referred to as The Mole Clinic. “we”, “us” or “our” in this privacy notice). If you have any questions about this privacy notice, including any requests to exercise your legal rights, please contact us using the details set out below.

Full name of legal entity: The Mole Clinic Limited

DPO Name: David Taylor

Email address for our DPO: dpo@themoleclinic.co.uk

Postal address: The Mole Clinic, 7 Moorgate, London EC2R 6AF

You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.

Changes to the Privacy Notice and your duty to inform us of changes

This version was last updated 14/11/24 and historic versions can be obtained by contacting us. It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.

Third-Party Links

This website may include links to third-party websites, 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 are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy notice of every website you visit.

2. 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 and retain different categories of personal data about you which we have grouped together follows:

• Identity Data includes first name, last name, former names, username or similar identifier, NHS number, social media identifiers, marital status, title, date of birth and gender.

• Contact Data includes billing address, delivery address, home address, email address and telephone numbers. We may also ask you for an emergency contact number.

• Financial Data includes bank account, payment card details. When applying for credit this may also include salary, outgoings, ability to pay and credit references.

• Transaction Data includes details about payments to and from you and other details of products and services you have purchased from us.

• 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 this website.

• Profile Data includes your username and password, purchases or orders made by you, your interests, preferences, feedback and survey responses.

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

• Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.

• Treatment Data includes information about the treatment you wish to (or have) received from us. This information could include ‘health data’ which is a special category of personal data and therefore requires us to take extra steps to ensure it is adequately protected. Depending on your treatment this may also include photographs which form an important part of your treatment record.

We also collect and use aggregated (anonymous) data such as statistical or demographic data for any purpose. Aggregated data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your website 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 this privacy notice.

With the exception of treatment data, we do not collect any other special categories of personal data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.

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 with goods or services). In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.The TMC website logs IP addresses and uses tracking technology, such as cookies and pixels, to provide a more fluid user experience and allow us to better understand how visitors use our website. These non-essential tracking technologies will only be used with your consent.

3. How Is Your Personal Data Collected?

We use a number of different channels to collect your personal data. These include: Direct interactions with you. You may give us your Identity, Contact and Financial Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:

• order or make an enquiry regarding any of our products or services, either online, over the phone or in one of our clinics;

• from your healthcare practitioner if they refer you to us;

• create an account on our website;

• subscribe to our service or publications;

• request marketing to be sent to you;

• enter a competition, promotion or complete a survey;

• give us some feedback or post on one of our social media accounts;

• contact, financial and transaction data from providers of technical, payment and delivery services such as Worldpay based inside the EU;

• Identity and contact data from data brokers or aggregators Experian based inside the EU;

• Identity and contact data from publicly available sources such as Companies House and the Electoral Register based inside the EU.

• Data is also collected by Intake Q online booking and patient intake system based outside of the EU. Please view the Intake Q privacy policy here.

4. How We Use Your Personal Data

We will only use your personal data when the law allows us to and in accordance with this privacy notice. Most commonly, we will use your personal data in the following circumstances:

• where we need to perform the contract we are about to enter into or have entered into with you for the provision of a product or service;

• 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;

• where we need to comply with a legal or regulatory obligation;

• marketing Activities; and

• to respond to any complaint and help us to establish, exercise or defend legal claims.

Generally, we do not rely on consent as a legal basis for processing your personal data other than in some circumstances in relation to sending direct marketing communications to you via email or text message and the use of non-essential cookies and similar tracking technologies. You have the right to withdraw consent to marketing at any time by contacting us.

Using Your Health Data

In light of the services which we provide to our customers, it will often be necessary for us to use information about your health. Even in the broadest sense of the word, ‘health’ information is a special category of personal data which requires us to have an additional lawful basis for using this information. Where we use information about your health for the purpose of providing our services to you (or in preparation for us to provide services to you), the additional lawful basis on which we shall rely will be that such use is necessary in order for us to provide you with health care or treatment.

Purposes for Which We May Use Your Personal Data and Our Legal Basis

We have set out below, in a table format, a description of all the ways we may 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. 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 require further details about the specific legal basis we are relying on to process your personal data where more than one basis has been set out in the table below.

Marketing

We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising. You can choose the channel by which you will receive marketing and change your preferences at any time. We rely on legitimate interest (soft opt in) as our lawful basis to send marketing.

Service Notifications

We recommend our patients at higher risk of skin cancer are screened on a regular basis and we will therefore email them periodically to remind them to book screening if they have not already done so. Any such emails will be sent in accordance with the terms of our Privacy Policy.

Promotional Offers from Us

We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you (we call this marketing). You will only receive marketing communications from us if you have requested information from us or have not opted out from receiving marketing by email or SMS. We may also send marketing my post or call you by telephone where permitted to do so by law.

Third-Party Marketing

We will never sell or disclose your data to a third party for the purpose of marketing. We may promote third party products or services on behalf of another organisation but will only do so where we have your explicit consent.

Opting Out

You can ask us or to stop sending you marketing messages at any time following the opt-out links on any marketing message sent to you or by Contacting us anytime. You will also be given the opportunity to opt-out when completing the enquiry form on this website.Where you opt out from receiving marketing messages, this will not apply to other communications, for example appointment reminders.

COOKIES & WEBTRACKING

i. WHAT ARE COOKIES?

Our site uses cookies to keep track of progress and to provide our visitors with a tailored user experience. With the help of cookies, we can present you with customised content and adverts that will be of more interest to you. We also use cookies to remember your passwords for you so you don’t have to re-enter them each time you visit the site. You have the option of setting your browser to reject cookies. However, if certain cookies that track your details are rejected then we won’t be able to pre-fill any data on the site or direct you to the correct stage on your next visit.

ii. COOKIE UPDATE

TMC use necessary cookies to make the website easier for you to use and to ensure you get the best experience. If you choose to continue without changing these settings, you consent to this, but should you want to, you can change your settings at any time. We will only read or write cookies for the preference level set, cookies set prior to you changing your settings will still be on your computer and you can remove them using your browser settings.

We use a cookie to remember your cookie preferences this has a couple of consequences

• If you delete all your cookies you will have to update your preferences with us again.

• If you use a different device, computer profile or browser you will have to tell us your

preferences again.

iii. ADVERTISER COOKIES

You may be served cookies from our advertisers while visiting our site. We do not

control, nor do we have access to, any of the information they may collect.

iv. HOW WE USE COOKIES AT THEMOLECLINIC.CO.UK

Functional and required cookies

Analytics and performance cookies

v. INFORMATION THIS WEBSITE GATHERS/TRACKS

As web tracking offers more chances to market to website visitors across the Internet, you as a visitor to the The Mole Clinic website may be targeted with adverts on other websites. Google and third party vendors might show targeted adverts with the ability to opt out. First and third party cookies are used to provide information and offer improvements to optimise quality of adverts served. You can change the cookie management settings in your web browser to stop these adverts.

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.

5. DISCLOSURES OF YOUR PERSONAL DATA

We may have to share your personal data with the parties set out below for the purposes set out in the table in paragraph 4 above. Such third parties consist of:

• IT: Service providers acting as processors who provide IT and system administration and development services.

• Advisors: Professional advisers including lawyers, bankers, auditors and insurers who provide consultancy, banking, legal, insurance and accounting services.

• Authorities: HM Revenue & Customs, regulators and other authorities who require reporting of processing activities in certain circumstances.

• IntakeQ - appointment booking and payments systems.

• Paypal & WorldPay - payment systems.

• Google Cloud - surveys and complaint forms.

In certain circumstances we may rely on the support of third parties to assist in the effective operation of our business - such areas include:

• Customer Appointment Management

• Reception Services

• Medical Billing

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 themto process your personal data for specified purposes and in accordance with ourinstructions.

6. INTERNATIONAL TRANSFERS

We may transfer your personal data outside the United Kingdom (UK) or European Economic Area (EEA) when your data is shared with the parties set out above. Where there is a requirement to process your data outside of the UK or EEA we take prudent steps to assess the risk to your personal data and ensure that measures are taken to manage risk appropriately and as regulated.

7. 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, 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 legallyrequired to do so.

8. DATA RETENTION

HOW LONG WILL YOU USE MY PERSONAL DATA FOR?

TMC 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. Details of retention periods for different aspects of your personal data are available in our retention policy which you can request from us by Contacting us. In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for training, research or statistical purposes in which case we may use this information indefinitely without further notice to you.

9. YOUR LEGAL RIGHTS

Under certain circumstances, you have rights under data protection laws in relation to your

personal data.

• Request access to your personal data.

• Request correction of your personal data.

• Request erasure of your personal data.

• Object to processing of your personal data.

• Request restriction of processing your personal data.

• Request transfer of your personal data.

• Right to withdraw consent.

If you wish to exercise any of the rights set out above, please Contact us

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.

10. GLOSSARY

LAWFUL BASIS

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

Performance of Contract

means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.

Comply with a legal or regulatory obligation

means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.

Necessary for us to provide health care or treatment

means processing your special categories of personal data (i.e. health data) where it is necessary for the purposes of preventive or occupational medicine, the provision of health or social care or treatment or the management of health or social care systems and services on the basis of EU or UK law or pursuant to contract with a health professional (subject to required conditions and safeguards).

YOUR LEGAL RIGHTS

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.