PRIVACY AND COOKIE POLICY
This Privacy and Cookie Policy (the “Policy”) (together with WHC’s Terms & Conditions and any other documents referred to therein) sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us.
Please read the the Policy carefully to understand how your personal data will be treated. By using our online services including our Website, you agree to the use of all personal data you provide to us or we collect from you.
The Policy explains:
- What information WHC may collect from you.
- The types of cookies WHC may use and how you can reject these cookies.
- Where WHC store your personal data.
- The way in which WHC keeps your information secure.
- What WHC does with the data it collects.
- Uses WHC makes of your data.
- Your rights.
Information WHC may collect from you
- In the Policy your “data” means information or pieces of information relating to you or that could allow you to be directly or indirectly identified.
Information you voluntarily provide
- All the information you provide by filling out WHC’s online consultation and medical information questionnaires. This also includes information you include when you sign up to WHC’s services.
- If you contact WHC via email, we may keep a record of that correspondence.
- WHC may ask you to complete surveys that WHC use for research purposes. These are however not mandatory.
- Details of transactions you carry out through WHC online services.
- The information WHC collect from the device you are using to access our services.
- WHC and other third-party service providers, may also use various different technologies to automatically collect information about how you use and access our services. These may include, but are not limited to:
Device information
- the type of device you use;
- a unique device identifier (for example, your device’s IMEI number or the MAC address of the device’s wireless network interface);
- network information;
- your operating system;
- your IP address;
- your login information;
- the browser you are using and what version it is;
- your time zone setting.
Other information
- the full Uniform Resource Locators (URL) clickstream to, through and from our online properties (including date and time);
- the different types of services/products you viewed or searched for;
- page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), and methods used to browse away from the page;
Information we may receive from third-parties
- WHC business relies on the collaboration with third-parties (such as the Pharmacy, payment and delivery services, analytics providers, search information providers, identity verification providers).
- WHC may therefore receive information about you from them.
Cookies, pixels and other similar technologies
- cookies are small pieces of data that are stored on your computer, mobile phone or other device. Pixels are small blocks of code on web pages that do things like allow another server to measure viewing of a webpage and often are used in connection with cookies.
- WHC uses the following cookies:
- Operationally necessary cookies. These are cookies that are required for the operation of WHC’s online services.
- Performance cookies. These cookies allow WHC to track how WHC’s users use the service, the number of visits on each page, and behaviour on each page. This helps WHC optimise the platform so you can find the things you are looking for and have the best experience possible.
- Functionality cookies. These cookies allows WHC to recognise you by name and create a more personalised experience for you.
- Targeting cookies. These cookies record your visit to WHC’s platform, the pages you have visited and the links you may have clicked. WHC will use this information to curate services and content based on your needs. This information may also be shared with third-party providers.
- Advertising cookies. WHC use cookies to help us show adverts to you on other websites across the internet. An example of this being: based on your actions on WHC’s website. If you have viewed a page about something specific on our website, we may advertise our prescribing services to you on other websites. If you would like more information on behavioural advertising/retargeting, including how to opt out of it, please visit www.youronlinechoices.com.
Cookies are essential to the improvement of our services and platform. They enable us:
- To estimate the size of WHC’s audience and their behaviours.
- To customise WHC’s site according to your individual interests.
- To speed up your searches.
- To recognise you when you return to WHC’s site.
You may refuse to accept cookies by activating the setting on your browser which allows you to refuse the setting of cookies. However, if you select this setting you may be unable to access certain parts of the WHC online system. Unless you have adjusted your browser setting so that it will refuse cookies, WHC’s system will issue cookies when you log on to WHC’s online system.
For more information about cookies or if you would like to learn how to remove cookies set on your device, visit: http://www.aboutcookies.org.
Where does WHC store your personal data
- The data that WHC collects from you may be transferred to, and stored at, a destination outside the European Economic Area (“EEA”), including to countries that do not offer the same level of protection with respect to personal data as required in the EEA.
- It may also be processed by staff operating outside the EEA who work for us or for one of our suppliers.
- Such staff may be engaged in, among other things, the processing of your payment details and the provision of services.
- By submitting your personal data, you acknowledge and consent to this transfer, storing or processing. WHC will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this privacy policy.
Information security
- WHC takes appropriate security measures to protect against unauthorised access to or unauthorised alteration, disclosure or destruction of data.
- These include internal reviews of WHC’s data collection, storage and processing practices and security measures, including appropriate encryption and physical security measures to guard against unauthorised access to systems where WHC store personal data.
- All information you provide to WHC is stored on our secure servers. Any payment transactions will be encrypted using SSL or other secure technology.
The transmission of information via the internet is not completely secure. Although WHC shall do their best to protect your personal data, we cannot guarantee the security of your data transmitted to our site; any transmission is at your own risk. Once WHC has received your information, WHC shall use strict procedures and security features to try to prevent unauthorised access.
Uses made of your data
WHC use information held about you in the following ways:
- To ensure that our content is presented to you in the most effective manner.
- To provide you with information, products or services that you request from WHC or which WHC feel may interest you.
- To carry out our obligations arising from any contracts entered into between you and WHC. You understand that in order to provide WHC’s services to you WHC need to share your personal data (including sensitive medical data) with doctors and non-medical staff working at WHC as well as with The Pharmacy. WHC ensure that any personal data WHC disclose in accordance with WHC’s Policy is kept to the minimum required to allow the safe and effective delivery of services to you, and will never share with non GDPR compliant third parties.
- To facilitate the delivery of Prescription Products and Non-Prescription Products to you. You also understand and agree, that WHC or the Pharmacy use third party delivery companies, such as Royal Mail and other delivery service companies (“Delivery Providers”), to deliver these to you.
- To evaluate the performance of our business at a granular level. You understand that in order to evaluate the performance of WHC’s service, WHC may occasionally send data to validated third parties for the purposes of evaluating ongoing performance. WHC ensure that any personal data that is disclosed in accordance with WHC’s Policy is kept to the minimum required to allow the safe and effective delivery of services to you, and WHC shall never share with non GDPR compliant third parties.
- To notify you about changes to our services.
WHC shall never sell your data. You understand that third party services that WHC uses change and may not always be reflected concurrently in this Privacy and Cookie Policy. WHC may also occasionally use your data, or permit selected third parties to use your data, to receive feedback about WHC’s services or to provide you with information about WHC’s products and services which may be of interest to you.
Disclosure of your information
When you share your personal data with WHC, WHC may share your personal data with our suppliers, (including partner pharmacies) and other third parties to allow delivery of the Prescription and Non-Prescription Products and services. Any such suppliers or third parties are not authorised by us to use your personal data in any other way.
WHC may disclose your personal information to third parties:
- In the event that WHC sell or buy any business or assets, in which case we may disclose your personal data to the prospective seller or buyer of such business or assets.
- If WHC disposes substantially or part thereof, of its assets which are acquired by a third party, in which case personal data held by WHC about its customers will be one of the transferred assets.
- If WHC are under a duty to disclose or share your personal data in order to comply with any legal obligation, or in order to enforce or apply WHC’s Terms & Conditions and other agreements; or to protect the rights, property, or safety of WHC, our customers, or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction.
- In order to detect, prevent or otherwise add personal information and either to correct this data if it is inaccurate, and/or if it is not otherwise required to be retained by law or for legitimate business purposes.
Changes to our Policy
- Any changes WHC may make to our Policy in the future will be posted on this page.
WHC’s rights and obligations
WHC may change, modify, amend or remove some or all of the functionality or content on the Website at any time.
You agree that WHC are free to use any comments, information or ideas contained in any communication you may send to WHC without compensation, acknowledgement or payment to you for any purpose whatsoever, including, but not limited to, developing, manufacturing and marketing the Prescription and Non-Prescription products and services and creating, modifying or improving the Website, Services, Prescription and Non-Prescription products.
Informed Consent
By checking the box associated with "Informed Consent", you acknowledge that you understand and agree with the following:
- That you hereby consent to receiving WHC’s services via telehealth technologies. You understand that WHC and its providers offer telehealth-based medical services, but that these services do not replace the relationship between you and your primary care doctor. You also understand it is up to WHC to determine whether or not your specific clinical needs are appropriate for a telehealth encounter.
- You understand that the law requires health care providers to protect the privacy and the security of health information. You understand that WHC shall take steps to make sure that your health information is not seen by anyone who should not see it. You understand that telehealth may involve electronic communication of your personal medical information to other health practitioners who may be located in other areas.
- You understand that there is a risk of technical failures during the telehealth encounter beyond the control of WHC. You agree to hold WHC harmless for delays in evaluation or for information lost due to such technical failures.
- You understand that even though our success rate in terms of achieving hair regrowth, stopping the balding process and sustaining hair regrowth is considered to be amongst the very highest of any medical hair regrowth clinic in the world, results are not guaranteed nor assured and will vary from person to person.
- You understand that the diagnosis and management of patients by WHC is performed by personnel who have been trained in the diagnosing and management of hair loss patients, using the techniques and protocols which have been successfully applied by Dr Kevin Alexander over the last thirty years. These WHC personnel may or may not have a background of formal medical training but they are trained to the level of expertise which is required by WHC. All interaction with WHC staff-members is done via email.
- You understand that allergy to our treatment is a rare possibility and will usually present with a rash on your scalp and/or other allergic-type symptoms. If this were to occur, please stop your treatment immediately and contact WHC for further instructions.
Ownership
WHC are the owners of the Website and all intellectual property rights in the Website, which includes (but without limitation) any software, applications and domains made available through the Website, and the content, video, photos, audio, graphics, logos, icons, and service names which appear on the Website. You do not have any rights to such intellectual property except as expressly set out in these Terms and Conditions.
Our right to cancel
WHC may cancel your contract if you notify WHC of any adverse side effects, being, inter alia, allergy, intolerance, etc. to the Prescription Products which, in the opinion of WHC, warrants cessation of your treatment programme. In such circumstances, WHC will instruct the Pharmacy to cease the delivery of further Prescription Products to you and refund, (the quantum of which will be determined by WHC) such an equitable amount.
Your Responsibilities
You are responsible for the information you provide to WHC about yourself, your health and your medication. You are responsible for letting WHC know if there are any changes to this information and for keeping it up to date. In particular, you need to tell WHC about any changes in your health, your medication and your delivery address. You confirm that this information is accurate and acknowledge that if you do not provide accurate and up to date information you could be putting your health at serious risk. You can update your information by email. You must complete the patient information form, sign the informed consent, and follow the clinical directions provided with each Prescription Product before using it.
You are responsible for notifying your personal doctors that you are using any Prescription Products if you so wish.
You agree that you will only use the Website, the Services and the Prescription Products for your own personal use. WHC do not offer the Website, the Services nor the Prescription Products for you to make available to other people, including partners or other family members.
Our Right to make changes to these Service Terms
We may make changes to these Service Terms.
Our liability to you
WHC are only liable to you for losses which you suffer as a direct result of our breach of these Terms and Conditions and which are reasonably foreseeable. Loss or damage is foreseeable if either it is obvious that it will happen or if, at the time you accepted the Terms and Conditions, both WHC and you knew it might happen.
The maximum loss or damage WHC will be responsible for under these Terms and Conditions is limited to the price you have paid WHC for the subscription to which the loss or damage you suffer relates; including for:
- death or personal injury caused by our negligence.
- any breach of terms implied by law.
WHC is responsible for reviewing your treatments, and is responsible for any diagnoses.
Disclaimers
Other than as set out in these Terms and Conditions, the Website, the Services, and any Prescription Products are provided on an “as is” and “as available” basis.
WHC MAKES NO REPRESENTATIONS NOR WARRANTIES OF ANY KIND, EXPRESS OR IMPLIED, AS TO THE OPERATION OF THE WEBSITE, THE SERVICES, THE PRESCRIPTION PRODUCTS, OR ANY INFORMATION, CONTENT, MATERIALS, OR PRESCRIPTION PRODUCTS INCLUDED IN OR REFERENCED ON THE WEBSITE.
WHC shall do it’s best to ensure that the information accessed through the Website and/or the Services is accurate and up to date but cannot guarantee that this will always be the case. The information and content on the Website is not medical advice, and is not intended to be a substitute for medical advice, diagnosis or treatment. We will not be liable to you for any loss or damage which may arise as a result of the use of any of the information or content on the Website, advice and/or Prescription Products linked to your WHC subscription.
WHC aim to make the Website and the WHC Services available to you all the time but sometimes they may be unavailable due to maintenance or to factors outside of our control.
WHC follow industry standards and processes to prevent against the introduction of viruses, malware and malicious attacks that may infect emails, harm the Website or the device that you use to access the Website, but we cannot guarantee that our online systems will be totally free from viruses and malware.
WHC do not guarantee that the Website will be compatible with all hardware and software that you may use.
The Website may contain links to third party web sites or programs that are not controlled by WHC. WHC are not responsible for the content, terms and conditions, offers or privacy policies of such sites and programs. Your dealings with third party sites are solely between you and the applicable third party and you should read their terms and conditions and policies before using them.
General
These Terms and Conditions and all communications between you and WHC will be in English. No other languages will apply to these Terms and Conditions.
You may not transfer any of your rights under these Terms and Conditions to any other person.
WHC may transfer any of our rights under these Terms and Conditions to any person, entity or ask any person, entity to fulfil any aspect of these Terms and Conditions.
Only you and WHC have any rights under these Terms and Conditions. No other person shall have any rights under these Terms and Conditions.
Each of the paragraphs of these Terms and Conditions operates separately. If any court or relevant authority decides that any of them are unlawful, the remaining paragraphs will remain in full force and effect.
Even if WHC delay in enforcing these Terms and Conditions, WHC can still enforce them later.
These Terms and Conditions will be governed by English law and English Courts.
Pharmacy Terms
These terms of service (referred to as the “Pharmacy Terms”) Terms & conditions - Roseway Labs apply to the fulfilment of prescriptions for the Prescription Products by Galenic Laboratories Ltd trading as Roseway Laboratories (General Pharmaceutical Council registration number 9011719) of Zetland House, 5-25 Scrutton Street, London EC2A 4HJ, United Kingdom (referred to as the “The Pharmacy”).
The Pharmacy dispense products on prescription (referred to as the “Prescription Products”) directly to you. This is based on information sent to them by WHC. The Pharmacy does not dispense the Prescription Products to anybody on your behalf. Your contractual relationship for the Prescription Products is directly with The Pharmacy.
You confirm that all of the information you have provided to WHC in relation to your medical condition is complete and accurate. You confirm that you have consented to your health data being processed by WHC, and for your health data being shared with The Pharmacy.
You acknowledge that should you terminate your relationship with WHC, WHC may notify the Pharmacy. In this case these Pharmacy Terms Terms & conditions - Roseway Labs may also be terminated and The Pharmacy will cease to dispense the Prescription Products to you.
The Pharmacy will only dispense the Prescription Products to you if a valid prescription has been issued by a licensed prescriber based upon an assessment by WHC. The Pharmacy will only send the Prescription Products to you if The Pharmacy approves the prescription for the Prescription Products that has been issued for you. In addition, The Pharmacy will only send the Prescription Products to you if WHC has received your subscription payment.
Subject to the above, The Pharmacy will send the Prescription Products to you promptly following receipt of your prescription. You will be informed via email that a prescription for the Prescription Products has been sent on your behalf by the prescriber to The Pharmacy. You should inform WHC if you do not receive the Prescription Products from The Pharmacy within 10 working days of the prescription being issued.
WHC shall not be liable for any damage and/or loss that may occur in transit. We shall not be liable for any delay nor failure in delivery caused by circumstances beyond our reasonable control.
WHC do not accept returns of any of the Prescription and Non-Prescription Products and any returns to the Pharmacy are subject to the terms and conditions of the Pharmacy Terms & conditions - Roseway Labs.
You must carefully read the information leaflet and labels that accompany the Prescription Products before using the Prescription Products. You are responsible for use of the Prescription Products in accordance with these instructions. The Prescription Products are dispensed to you for the treatment of a specific hair loss condition that has been identified as applicable to you. The Prescription Products must not be shared with or used by any other person.
To the maximum extent permitted by law, we disclaim all warranties and representation, express or implied, in relation to the Prescription and Non-Prescription Products supplied by The Pharmacy, including without limitation implied warranties and suitability for any particular purpose.
You may not assign any of your rights or obligations under these terms to any third party. You understand that we may at our sole discretion assign or license our rights and obligations under these terms to any third party. No delay in enforcing any right arising under these terms shall be construed as a waiver of such right.
WHC may make changes to these Terms and Conditions from time to time.