Privacy Policy

Natalie Page Pharma Limited
Privacy Policy
Our approach
We are committed to protecting and respecting your privacy and this privacy policy sets out
how we process your data when you use our website and Instascript. Please read the following
carefully to understand our views and practices regarding your data and how we will deal with
it.
By clicking the “I Accept” box where indicated, submitting your data to us, or using the
services, you acknowledge and accept the practices described in this policy.
Introduction
This Policy (together with our Terms of Use and any additional terms of use incorporated by
reference into the Terms of Use, together our Terms of Use) applies to your use of:
 Our prescription ordering software, Instascript.
 Use of our Website: https://nataliepagepharma.co.uk/ (Website).
 Any of the services accessible through the Website (Services)
This Policy sets out the basis on which any personal data we collect from you, or that you
provide to us, will be processed by us. Neither the Website nor Instascript is intended for
children, and we do not knowingly collect data relating to children. Please read the following
carefully to understand our practices regarding your data and how we will treat it.
Important Information
Introduction
Natalie Page Pharma is the controller and is responsible for your personal data (collectively
referred to as “we”, “us” or “our” in this Policy).
Our full details are:
Full name of legal entity: Natalie Page Pharma Limited
Email address for data protection purposes: natalie@nataliepagepharma.co.uk
Complaints
You have the right to make a complaint at any time to the Information Commissioner’s
Office (ICO), the UK regulator for data protection issues.
Changes to this Policy

Changes to the Policy and your duty to inform us of changes. We keep our Policy under
regular review.
The personal data we hold about you must be accurate and current. Please keep us
informed if your data changes during our relationship with you.
Third party links
Our Website may, from time to time, contain links to and from the websites of our partner
networks and advertisers. Please note that these websites and any services that may be
accessible through them have their privacy policies and that we do not accept any
responsibility or liability for these policies or for any personal data that may be collected
through these websites or services. Please check these policies before you submit any
personal data to these websites or use these services.
The Data We Collect About You
Introduction
We may collect, use, store and transfer different kinds of personal data about you as
follows:
Identity Data: First name, last name, maiden name, username or similar identifier, marital
status, title, date of birth, gender.
Contact Data: Billing address, delivery address, email address and telephone numbers.
Health and Medical Data: Products prescribed, GP contact details, medical and health
information and history shared by you during consultations with your GP. This data is a
“Special Category of Personal Data”, to which greater protections apply under data
protection law.
Financial Data: Bank account and payment card details.
Transaction Data: Includes details about payments to and from you and details of Website
and Instascript purchases, and details of repeat prescriptions ordered by, and delivered to,
you.
Device 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, Website purchase and repeat
prescription ordering and delivery history.
Usage Data: Includes details of your use of our Website and Instascript.
Marketing and Communications Data: Includes your preferences in receiving marketing
from us and our third parties and your communication preferences.

We also collect, use and share Aggregated Data such as statistical or demographic data for
any purpose. Aggregated Data could be derived from your data but is not considered
personal data in law as this data will not directly or indirectly reveal your identity. However,
if we combine or connect Aggregated Data with your data so that it can directly or indirectly
identify you, we treat the combined data as personal data which will be used by this privacy
policy.
How Is Your Personal Data Collected
We will collect and process the following data about you:
Information you give us. This is information (including Identity, Contact, Health and
Medical, Financial, and Marketing and Communications Data) you consent to give us about
you by filling in forms on the Website or Instascript, by corresponding with us (for example,
by email or chat) or by telling us during a consultation or otherwise. It includes information
you provide when you register to set up an account on our Website, use our Services, and
when you report a problem with the Website, or our Services. If you contact us, we will keep
a record of that correspondence.
Information we collect about you and your device. Each time you visit our Website or
use Instascript, we will automatically collect personal data including Device, Content and
Usage Data. We collect this data using cookies and other similar technologies. Please see
our Cookie Policy for further details.
Information we receive from other sources including third parties and publicly
available sources. We will receive personal data about you from various third parties and
public sources as set out below:
Device Data from analytics providers, such as Google, and Bing; and search information
providers such as Google.
Contact, Financial and Transaction Data from providers of technical, payment and
delivery services
Medical and Health Data from your healthcare provider. Our pharmacists may have
access to your medical records to ensure patient care.
Cookies
We use cookies to distinguish you from other users of the Website and Services, and to
remember your preferences. This helps us to provide you with a good experience when you
use the Website or Instascript and also allows us to improve our Website. You can set your
browser to refuse all or some browser cookies, or to alert you when websites or apps set or
access cookies. If you disable or refuse cookies, please note that some parts of our Website
or Instascript may become inaccessible or not function properly.
For detailed information on the cookies we use, the purposes for which we use them and
how you can exercise your choices regarding our use of your cookies, see our Cookie Policy.
If you Fail to Provide Personal Data

Where you fail to provide personal data when requested, we may not be able to provide
some or all of our Services.
How we use your Personal Data
We will only use your personal data when the law allows us to do so. Most commonly we will
use your personal data in the following circumstances:
 Where you have consented (and in the case of Special Category Data, where you
have provided your explicit consent).
 Where we need to perform a contract, we are about to enter or have entered with
you.
 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.
We will only send you direct marketing communications by email or text if we have your
consent. You have the right to withdraw that consent at any time by contacting us.
Purposes for which we will use your personal data
Purpose/activity Type of data Lawful basis for processing
To register you as a new
Instascript user
To register your account on the
Website
Identity
Contact
Financial
Device
Your consent
To provide you with Services such
as reminders, repeat prescriptions,
and allow our pharmacist access to
your medical records
Identity
Contact
Transaction
Device
Health and
Medical
Profile
Your consent
Your explicit consent or for the
purposes of the provision of
health care (e.g., in the case of
Health and Medical Data)
Necessary for our legitimate
interests (to provide services to
you in an appropriate manner)
For our pharmacists to be able to
provide you with advice based on
your medical records
Identity
Contact
Health and
Medical
Your consent
Your explicit consent or for the
purposes of the provision of
health care (in the case of Health
and Medical Data)

To process Website and Instascript
purchases including managing
payments and collecting money
owed to us
Identity
Contact
Financial
Transaction
Device
Marketing and
Communication
Location
Your consent
Performance of a contract with
you
Necessary for our legitimate
interests (to recover debts due to
us)
To manage our relationship with
you including notifying you of
changes to the Website or any
Services
Identity
Contact
Financial
Profile
Marketing and
Communication
Your consent
Performance of a contract with
you
Necessary for our legitimate
interests (to keep records
updated and to analyse how
customers use our products/
Services)
Necessary to comply with legal
obligations (to inform you of any
changes to our terms and
conditions)
To administer and protect our
business and this Website
including troubleshooting, data
analysis and system testing
Identity
Contact
Device
Necessary for our legitimate
interests (for running our
business, provision of
administration and IT services,
network security)

To deliver content and
advertisements to you
To make recommendations to you
about goods or services which may
interest you
To measure and analyse the
effectiveness of the advertising we
serve you
To monitor trends so we can
improve the Website.
Identity
Contact
Device
Content
Profile
Usage
Marketing and
Communications
Location
Consent
Necessary for our legitimate
interests (to develop our
products/services and grow our
business)
Change of Purpose
We will only use your 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 us to explain how the processing for the new purpose is
compatible with the original purpose, please contact us.
If we need to use your 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 data without your knowledge or consent, in
compliance with the above rules, where this is required or permitted by law.
Disclosures Of Your Personal Data
We may share your personal data with the third parties set out below for the purposes set
out in the table above:
 Service providers acting as processors, who provide IT and system administration
services and video conferencing facilities, such as Microsoft Azure, Stripe, and
Amazon Web Services.
 Credit card providers and banks for the processing of payments.
 HM Revenue and Customs, regulators (including the General Pharmaceutical Council)
and other authorities acting as processors or joint controllers based in the UK who
require reporting of processing activities in certain circumstances.
 Third parties to whom we may choose to sell, transfer or merge parts of our business
or our assets. Alternatively, we may seek to acquire other businesses or merge with
them. If a change happens to our business, then the new owners may use your
personal data in the same way as set out in this Policy
Special Category Data: We will not ordinarily share any of your medical or health
information with any third party, including your healthcare provider, without your specific

and explicit consent (unless you are physically or legally unable to give consent and the
sharing is necessary to protect your vital interests).
Data Security
All information you provide to us is stored on cloud servers operated by leading operators
with high levels of security. Any payment transactions carried out by our chosen third-party
provider of payment processing services will be encrypted using Secured Sockets Layer
technology.
Once we have received your information, we will use strict procedures and security features
to try to prevent your data from being accidentally lost, used or accessed in an
unauthorised way, including encryption of your data “at rest” on our systems.
We have put in place procedures to deal with any suspected personal data breach and will
notify you and any applicable regulator when we are legally required to do so.
Data Retention
Details of retention periods for different aspects of your data are available in our retention
policy which you can request by contacting us.
In some circumstances you can ask us to delete your data: see your legal rights below for
further information.
In some circumstances, we will anonymise your data (so that it can no longer be associated
with you) for research or statistical purposes, in which case we may use this information
indefinitely without further notice to you.
If you do not use your account on the Website for a period of 2 years then we will treat the
account as expired and your data will be archived and may be deleted.
Your Legal Rights
Under certain circumstances you have the following rights under data protection laws in
relation to your personal data.
You have the right to:
Request access to your 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 data. This enables you to ask us to delete or remove personal
data where there is no good reason for us to continue to process it. You also have the right
to ask us to delete or remove your 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 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 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 your fundamental rights and
freedoms. You also have the right to object to where we are processing your 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 data. This enables you to ask us to suspend
the processing of your data in the following scenarios:
if you want us to establish the data’s accuracy;
where our use of the data is unlawful but you do not want us to erase it;
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
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 data to you or a third party.
We will provide to you, or a third party you have chosen, your 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 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.
You also have the right to ask us not to continue to process your personal data for
marketing purposes.
You can exercise any of these rights at any time by contacting us at
natalie@nataliepagepharma.co.uk
Glossary
Comply with a legal obligation means processing your data where it is necessary for
compliance with a legal obligation that we are subject to.

Consent means processing your data where you have signified your agreement by a
statement or clear opt-in to processing for a specific purpose. Consent will only be valid if it
is a freely given, specific, informed and unambiguous indication of what you want. You can
withdraw your consent at any time by contacting us.
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 data for our legitimate
interests. We do not use your 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.