PRIVACY POLICY

Welcome to the Build It Medical Ltd's privacy policy.

Build it Medical Ltd trading as GP Widget ("GP Widget", "we", "our" or "us"), a private company limited by shares registered in England and Wales with company number 13118815 whose registered office is at 4 South Avenue, Exeter, Devon, United Kingdom, EX1 2DZ respects your privacy and is committed to protecting your personal data.

This privacy policy (the "Policy") will inform you as to how we look after your personal data when you visit our website (regardless of where you visit it from) or use our mobile application software available from time to time (together, the "Platform") as either an individual user ("Individual") or organisation (such as GP practices or primary care networks) ("Organisation") (together, "user", "your" and "you") or interact with us on social media and tells you about your privacy rights and how the law protects you.

This Policy is provided in a layered format so you can click through to the specific areas set out below. Please also use the Glossary to understand the meaning of some of the terms used in this Policy.

• Important information and who we are
• The data we collect about you
• Location services/data
• How is your personal data collected?
• How we use your personal data
• Marketing
• Who we share your information with
• International transfers
• Data security
• Data retention
• Your legal rights
• Glossary
• Cookies policy

1. Important information and who we are

Purpose of this policy

1.1. This Policy aims to give you information on how GP Widget collects and processes your information through your use of the Platform, including any data you may provide when you register and/or use our Platform, sign up to our newsletter or e-mail subscription, interact with us on social media or take part in a competition, promotion or survey.

1.2. It also explains your rights in relation to your information and how to contact us or the relevant regulator in the event that you have a complaint. Our collection, storage, use and sharing of your information is regulated by law, including under the United Kingdom General Data Protection Regulation.

1.3. The Platform is not intended for children, and we do not knowingly collect data relating to children.

1.4. It is important that you read this Policy together with any other privacy policy or fair processing policy we may provide on specific occasions when we are collecting or processing information about you so that you are fully aware of how and why we are using your data. This Policy supplements the other policies and is not intended to override them.

1.5. Where applicable, Organisations may provide Individuals with their own data protection terms and policies. Otherwise, any other such processing of Individual's data shall be governed by this Policy.

Controller

1.6. GP Widget is the controller and responsible for your personal data. We have appointed a data protection officer ("DPO") who is responsible for overseeing questions in relation to this Policy. If you have any questions about this Policy, including any requests to exercise your legal rights, please contact the DPO using the details set out below.

How to contact us

1.7. If you have any questions about this Policy or our privacy practices, please contact us in the following ways:

• Full name of legal entity: Build it Medical Ltd (trading as GP Widget) (company registration number: 13118815)
• Postal address: GP Widget, 4 South Avenue, Exeter, Devon, United Kingdom, EX1 2DZ
• Via the "contact us" page on the Platform

1.8. You have the right to make a complaint at any time to the Information Commissioner's Office (the "ICO"), the United Kingdom's 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 Policy and your duty to inform us of changes

1.9. We keep our privacy policy under regular review.

1.10. It is important that the information we hold about you is accurate and current. Please keep us informed if your information changes during your relationship with us.

Third-party links

1.11. Our Platform 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 Platform, we encourage you to read the privacy policy of every website you visit or app you use.

2. The data we collect about you

2.1. 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 ("Anonymised Data").

2.2. The information we collect about you depends on the particular activities carried out through the Platform. We will collect and use the following information about you:

• "Identity Data" includes your first name, maiden name, last name, marital status, title, date of birth, gender and occupation;
• "Contact Data" includes your billing address, your e-mail address and telephone numbers;
• "Financial Data" includes your bank account (or similar, such as PayPal, as may be relevant from time to time) and payment card details;
• "Transaction Data" includes details about payments to and from you as a user, and other details of services or products you have purchased from us;
• "Technical Data" includes your internet protocol (IP) address, login data, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access our Platform;
• "Location Date" relates to geolocation data collected from any device you use to access our Platform;
• "Profile Data" includes your username (or similar identifier) and password, purchases or orders made or fulfilled by you, your interests, preferences, social media interactions, feedback and survey responses;
• "Usage Data" includes information about how you use our Platform and services;
• "Marketing and Communications Data" includes your preferences in receiving marketing from us and our third parties and your communication preferences; and
• "Special Category Personal Data" includes details about your health (including your COVID-19 vaccination status), race or ethnicity, religious or philosophical beliefs, and criminal convictions or offences if ever relevant to care requested or performed by you.

2.3. We also collect, use and share "Aggregated Data" such as statistical or demographic data for any purpose. Aggregated Data may be derived from your information but is not considered personal data in law as this information does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific Platform feature. However, if we combine or connect Aggregated Data with your information 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 Policy.

If you fail to provide personal data

2.4. 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 services). In this case, we may have to cancel a service you have with us (including withdrawing your registration as a user in exceptional cases), but we will notify you if this is the case at the time.

3. Location services/data

3.1. The Platform may request your consent to use location services to precisely identify your location each session.

3.2. If you do not provide your consent, you may not use the Platform. To withdraw your consent at any time, please contact us and disable the location data/services on your device (that will not affect the lawfulness of our use of that data in reliance on the consent before it was withdrawn).

3.3. We will not process your location data other than as strictly required.

3.4. The location services in the Platform will not operate unless location services/data are generally enabled on your device. You may disable such functionality at any time by disabling the location services on your device. When you allow your device to use location services/data, data will also be collected by the organisations providing the device operating system in accordance with their own privacy policies.

4. How is your personal data collected?

We use different methods to collect data from and about you including through:

4.1. Direct interactions. You may give us your Identity, Special Category, Contact, Technical, Profile, and Financial Data by completing forms or by liaising with us by post, phone, e-mail or otherwise. This includes the personal data you provide when you:

• interact with us or other Users on the Platform;
• purchase or sign up to our services;
• complete questionnaires;
• subscribe to our service or publications;
• request marketing to be sent to you;
• enter a competition, promotion or survey;
• contact us; or
• give us feedback directly through our Platform.

4.2. Automated technologies or interactions. As you interact with our Platform, we may automatically collect Profile, Usage and Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies. We may also receive Technical Data about you if you visit other websites employing our cookies. Please see our cookie policy for further details.

4.3. Location Data. We may also use GPS technology to determine your current location and match you with local Organisations. Some of our location-enabled services require your information for the feature to work. If you wish to use the particular feature, you will be asked to consent to your data being used for this purpose. You can withdraw your consent at any time by disabling Location Data in your settings.

4.4. Third parties or publicly available sources. We may receive personal data about you from various third parties and public sources as set out below:

• Technical and Usage Data from analytics providers, such as Google and Facebook, based outside of the European Union/United Kingdom;
• Identity, Technical, Profile, Usage, Marketing and Communications Contact, Financial and Transaction Data from providers of technical, payment and delivery services such as GP Widget's External Third Parties;
• Identity and Contact Data from data brokers or aggregators such as Facebook, Instagram and Gmail; and
• Identity and Contact Data from publicly availably sources such as Companies House and the Electoral Register or Organisation's business websites based inside the UK.

5. How we use your personal data?

5.1. Under data protection law, we can only use your information if we have a proper reason for doing so, for example where:

• you have given consent;
• we need to perform the contract we are about to enter into or have entered into with you;
• it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests; or
• we need to comply with a legal or regulatory obligation.

5.2. Generally, we do not rely on consent as a legal basis for processing your personal data other than in relation to sending third party direct marketing communications to you via e-mail or SMS text message. You have the right to withdraw consent to marketing at any time by contacting us or clicking the opt-out link in the marketing message.

5.3. We have set out in the below table, a description of all the ways we plan to use your information, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

5.4. 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 need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.

5.5. All of the personal data we collect and use from you is stored and analysed for the above, internal purposes only. We expressly do not use your personal data for marketing purposes.

5.6. 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.

5.7. If we need to use your information for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

5.8. 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.

6. Marketing

6.1. We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising.

6.2. 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.

6.3. You will receive marketing communications from us if you have requested information from us, purchased goods or services from us or if you provided us with your details when you entered a competition or registered for a promotion and, in each case, you have not opted out of receiving that marketing.

6.4. We will always treat your information with the utmost respect and never sell it with other organisations for marketing purposes. We will get your express opt-in consent before we share your personal data with any third-party company for marketing purposes.  If we do ask for your consent it will only be in relation to carefully selected third-parties who we think may be of interest to you due to their close connection with the beauty industry.

6.5. You can ask us or third parties to stop sending you marketing messages at any time by adjusting your marketing preferences on your account on the Platform, following the opt-out links on any marketing message sent to you or by contacting us at any time.

6.6. Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of purchasing a service or product, service experience or other transaction.

6.7. For more information on your right to object at any time to your information being used for marketing purposes, see 'Your legal rights' below.

7. Who we share your information with

7.1. We may have to share your personal data with the following parties for the purposes set out in the above table:

• External Third Parties as defined in the Glossary; and
• third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets.

7.2. 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.

7.3. We only allow External Third Parties to handle your information if we are satisfied that they take appropriate measures to protect your information.

7.4. 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 them to process your personal data for specified purposes and in accordance with our instructions.

7.5. We or the External Third Parties occasionally also need to share your information with certain recipients who will be bound by confidentiality obligations as follows:

• our or their external auditors;
• our or their professional advisors (such as lawyers and other advisors);
• law enforcement agencies, courts or tribunals and regulatory bodies to comply with legal and regulatory obligations; and
• other parties that have or may acquire control or ownership of our business (and our or their professional advisors) 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 such information will be anonymised, but this may not always be possible.

International Transfers

8.1. Many of our External Third Parties are based outside of the United Kingdom so their processing of your personal data will involve a transfer of data outside of the United Kingdom.

8.2. Whenever we transfer your personal data out of the United Kingdom, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

• we will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data;
• where we use certain service providers, we may use specific contracts approved for use in the United Kingdom which give personal data the same protection it has in the United Kingdom; and
• where we use providers based in the United States, we may transfer data to them if they are part of the Privacy Shield which requires them to provide similar protection to personal data shared between Europe and the United States.

8.3. Please contact us if you require further information on the specific mechanism used by us when transferring your personal data out of the United Kingdom.

9. Data Security

9.1. 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.

9.2. All information you provide to us is stored on our secure servers. Where we have given you (or where you have chosen) a password that enables you to access the Platform, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.

9.3. 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 legally required to do so.

9.4. If you want detailed guidance from Get Safe Online on how to protect your information and other 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.

10. Data Retention

10.1. We 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. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.

10.2. 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.

10.3. By law we have to keep basic information about our users (including Contact, Identity, Financial and Transaction Data) for six years after they cease being customers for tax purposes.

10.4. In some circumstances you can ask us to delete your data: see 'Request erasure of your personal data' below for further information.

10.5. In some circumstances we may anonymise your personal 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.

10.6. In the event that you do not use the Platform for a period of ninety days, then we will treat the account as expired and your personal data may be deleted.

11. Your Legal Rights

11.1. Under certain circumstances, you have Legal Rights under data protection laws in relation to your personal data. Please click on the following links below to find out more about these Legal Rights:

• 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.

11.2. If you wish to exercise any of your Legal Rights set out above, please contact us. When contacting us please:

• provide enough information to identify yourself (for example, your full name, address and account number) and any additional identity information we may reasonably request; and
• let us know which right(s) you want to exercise and the information to which your request relates.

11.3. 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.

11.4. 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.

11.5. 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 if you have made a number of requests. In this case, we will notify you and keep you updated.

11.6. For further information on each of your Legal Rights, including the circumstances in which they do and do not apply, please contact us. You may also find it helpful to refer to the guidance from the ICO (https://ico.org.uk/your-data-matters/).

12. Glossary

12.1. "External Third Parties" include:

• Service and analytics providers acting as processors who provide IT and system administration services and marketing agencies or hosts of the systems that deliver the Platform's functionalities.
• Professional advisors acting as processors or joint controllers including lawyers, bankers, auditors and insurers who provide consultancy, banking, legal, insurance and accounting services.
• HM Revenue & Customs, regulators and other authorities acting as processors or joint controllers based in the United Kingdom who require reporting of processing activities in certain circumstances.
• Advertisers and advertising networks such as Google and Facebook that require the data to select and serve relevant adverts to you and others. We do not disclose Identity Information about users to our advertisers, but we may provide them with aggregated information or anonymised data about our users. We may also use such aggregated information or anonymised data to help advertisers reach the kind of audience they want to target. We may make use of personal data we have collected from you to enable us to comply with our advertisers' wishes by displaying their advertisement to that target audience.
• Search engine providers such as Google that assist us in the improvement and optimisation of the Platform.
• Payment providers who allow us to take payments via the Platform.

12.3. "Lawful Basis" includes:

• Legitimate Interest. 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. The processing of 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.
• Complying with a legal or regulatory obligation. The processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.
• "Legal Rights" include the rights 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.

Cookie Policy

13.1. Our Platform uses cookies. A cookie is a small text file which is stored on your computer, tablet or phone when you visit a website. These cookies allow us to distinguish you from other users of our Platform. This helps us to provide you with a good experience when you browse our Platform and also allows us to improve our Platform.

13.2. There are two main types of cookie:

• Session cookies. These are deleted when you finish browsing a website and are not stored on your device longer than this.
• Persistent cookies. These are stored on your device after you have finished using a website so that the website provider can remember your preferences the next time you use it.

13.3. Cookies can be set by the website you have browsed, that is the website displayed in the uniform resource locator (URL) window. These are called first-party cookies. Third-party cookies are set by a website other than the one you are browsing.

13.4. You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of the Platform may become inaccessible or not function properly.

13.5. To find out more about cookies, including how to see what cookies have been set and how to manage and delete them, visit http://www.allaboutcookies.org/.

13.6. We use cookies to:

• estimate our audience size and usage pattern;
• store information about your preferences, and so allow us to customise our Platform according to your individual interests;
• speed up your searches; and
• recognise you when you return to our Platform.

13.7. If you continue to use our Platform we will assume that you are happy to receive all cookies from our Platform. However, if you would prefer to change your cookie settings, you can do so at any time.

13.8. Most browsers automatically accept cookies unless you change your internet browser settings. If you wish to restrict, block or delete the cookies which are set by any websites, you can generally do this through your browser settings. These settings are usually found in the ‘options' or ‘preferences' menu of your internet browser.

13.9. If you set your internet browser preferences to block all cookies, you may not be able to access all or parts of our Platform.

13.10. If you delete cookies relating to our Platform we will not remember things about you, including your cookie preferences, and you will be treated as a first-time visitor the next time you visit.

13.11. If you have any questions or comments regarding our cookies policy, please contact us.