Privacy Policy

Purpose of this privacy policy

This privacy policy aims to give you information on how Health Compare collects and processes your personal data through your use of this website, including any data you may provide through this website when you complete an Enquiry Form to contact a private or NHS hospital, Virtual GP, Care Home or to enquire about another service.

This website is not intended for children and we do not knowingly collect data relating to children. In addition, this website is not intended for citizens of the European Economic Area (EEA). If you are a citizen of the EEA you are not permitted to use this site.

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

Controller

Health Compare is the controller and responsible for your personal data (collectively referred to as "Health Compare", "we", "us" or "our" in this privacy policy).

We have appointed a data privacy manager who is responsible for overseeing questions in relation to this privacy policy. If you have any questions about this privacy policy, including any requests to exercise your legal rights, please contact the data privacy manager using the details set out below.

Contact details

If you have any questions about this privacy policy or our privacy practices, please contact our data privacy manager in the following ways:

Full name of legal entity: Health Compare Limited

Email address: datamanager@healthcompare.co.uk

Postal address: Health Compare Limited, The Plaza, Old Hall Street, Liverpool, England, L3 9QJ.

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 policy and your duty to inform us of changes

We keep our privacy policy under regular review. This version was last updated on 22 December 2020. 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, for example to Hospital Websites

This website includes links to third party websites, plug-ins and applications, for example it contains links to hospital websites. Clicking on those links or enabling those connections may allow third parties, such as the hospitals we link to, 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 policy of every website you visit. If you make an enquiry of those third parties through our website, such as hospitals, remember to consider who might be reading your enquiry, this may not be a doctor or a qualified clinician. Before you disclose personal data about yourself to those third parties, particularly sensitive medical information, ensure you are happy with their privacy policies. You should find their privacy policies on their websites or you can ask them directly.

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, store and transfer different kinds of personal data about you which we have grouped together as follows:

• Identity Data includes first name, maiden name, last name, username or similar identifier, marital status, title, date of birth and gender.
• Contact Data includes home address, email address and telephone numbers.
• Transaction Data includes details about payments to and from you and other details of products and services you have purchased from service providers to whom we have introduced you. We do not collect this data from you ourselves as the use of our site and services to consumers is free and therefore we do not need to, but we may be notified of this data from service providers, such as a hospital, if you have purchased services from them as a consequence of using our website or completing an enquiry form on our website. This is because while our services to you as a consumer are free we receive a fee from service providers, such as a private hospital, to whom we introduce you and we and they need to verify and audit introductions made. Please note, however we do not ourselves collect any financial data about you, such as bank account details and payment card details, and we do not receive this data about you from any service providers to whom we introduce you through our website.
• Technical Data includes internet protocol (IP) address, your login data (if you log in), 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 (if relevant), enquiries made by you from our website (including any health data you disclose), 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 (see Glossary below) 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 personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity. For example, we may aggregate your 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 policy.

Except for the limited health data we collect as mentioned below, we do not collect any 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, and information about your health, and genetic and biometric data). Nor do we collect data about criminal convictions and offences.

We do collect and process the health information you have disclosed by completing enquiry forms on our website, so we can forward it for you to the service provider you have chosen to contact. This information will be passed to the hospital, Virtual GP or Care Home or other service provider you have chosen to contact. We will keep a copy of the enquiry in our databases and once your enquiry is delivered to the service provider you have chosen to contact the data in the enquiry form will then also be subject to the privacy policies of that hospital or other service provider with whom you have chosen to contact. Please review the privacy policies of the service provider you have chosen to contact to make sure you are happy with the way they intend to manage your data, preferably, before you disclose your personal data, particularly health data. This is usually on their website. Please ask the hospital or service provider concerned if you wish to find out more information about their privacy policies and how they manage your personal data.

We are not responsible for a hospital's or other service provider's actions or privacy statements.

We also collect data about which procedures you have searched or enquired about on our site to help us improve our website and the services we provide.

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 services or referrals). In this case, we may have to cancel an enquiry you make or service you require from us but we will notify you if this is the case at the time.

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

• Direct interactions. You may give us your Identity or Contact Data by filling in enquiry or other forms on our website or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
  • complete an enquiry form on our website to be referred to a hospital or other service provider;
  • enter a promotion or survey; or
  • give us feedback or contact us.
• Automated technologies or interactions. As you interact with our website, we will automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies 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.
• Third Parties or publicly available sources. We will receive personal data about you from various third parties and public sources as set out below:
  • Technical Data from the following parties:
    (a) analytics providers such as Google or facebook;
    (b) advertising networks with whom we work such as Google or facebook or Twitter or Instagram; and
    (c) search information providers such as Google.
• Contact and Transaction Data from providers of medical, technical, payment and delivery services, or other service providers, such as hospitals or brokers listed on our website with whom we connect you.

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

• Where we need to perform a contract we are about to enter into or have entered into 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 obligation.

See the Glossary below under "Lawful Basis" to find out more about the types of lawful basis that we will rely on to process your personal data.

Generally, we do not rely on consent as a legal basis for processing your personal data, except for the processing of your health data which you include in an enquiry form which we pass on your behalf to hospitals or service providers when you chose to make an enquiry of them through our website, and by keeping a record of your enquiry in our databases.

We will always seek and obtain your consent before sending third party direct marketing communications to you via email or text message.

You have the right to withdraw consent at any time by contacting us. However, once we have passed an enquiry form to a service provider at your request we cannot retrieve that enquiry form from them as we do not control them. You would need to contact the service provider to whom you made an enquiry to retrieve any information you chose to send to them. We encourage you to familiarise yourself with the privacy policies of all service providers you choose to contact through our website.

Purposes for which we will use your personal data

We have set out below, in a table format, a description of all the ways we plan to 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 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.

Purpose/Activity	Type of data	Lawful basis for processing including basis of legitimate interest
To register you as a new user of our website and services (if registration required)	(a) Identity (b) Contact	Performance of a contract with you
To process and deliver your enquiry about a service offered by others, such as private hospitals, and recording that enquiry	(a) Identity (b) Contact (c) Profile (d) Transaction (e) Marketing and Communications	(a) Performance of a contract with you (b) Necessary for our legitimate interests (to keep our records updated and to study and record how customers use our services) (c) Consent, (in relation to health data) you consent to our making an enquiry on your behalf and keeping a record of that enquiry by clicking the “Make Enquiry” form on our website, in order for us to pass on your enquiry to your chosen hospital or service provider and to keep track of your enquiry
To manage our relationship with you which will include: (a) Notifying you about changes to our terms of use or privacy policy (b) Asking you to leave a review or take a survey	(a) Identity (b) Contact (c) Transaction (d) Profile (e) Usage (f) Marketing and Communications	(a) Performance of a contract with you (b) Necessary to comply with a legal obligation (c) Necessary for our legitimate interests (to keep our records updated and to study and record how customers use our services so we can develop them and grow our business) (d) Consent, to the extent required to process health data you pass to us to process
To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)	(a) Identity (b) Contact (c) Technical	(a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise) (b) Necessary to comply with a legal obligation
To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you	(a) Identity (b) Contact (c) Profile (d) Usage (e) Marketing and Communications (f) Technical	Necessary for our legitimate interests (to study and record how customers use our services, to develop them, to grow our business and to inform our marketing strategy)
To use data analytics to improve our website, products/services, marketing, customer relationships and experiences	(a) Technical (b) Usage (c) Profile	(a) Necessary for our legitimate interests (to define types of users of our services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy) (b) Consent, to the extent required with regard to marketing and the processing of health data, if relevant
To make suggestions and recommendations to you about goods or services that may be of interest to you	(a) Identity (b) Contact (c) Technical (d) Usage (e) Profile (f) Marketing and Communications	(a) Necessary for our legitimate interests (to communicate, develop our products/services and grow our business) (b) Consent, to the extent required with regard to marketing and the processing of health data, if relevant

Marketing

We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising. We have established the following personal data control mechanisms:

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 receive marketing communications from us if you have requested information from us or purchased goods or services from us and you have opted in to receiving that marketing.

Third Party marketing

We will get your express opt-in consent before we share your personal data with any third party for marketing purposes.

Opting out

You can ask us or third parties to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you or by contacting us at any time. Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a product/service purchase, enquiries made to service providers from our website, product/service experience or other transactions.

Cookies

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 this website may become inaccessible or not function properly. For more information about the cookies we use please see our cookie policy.

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.

We may share your personal data with the parties set out below for the purposes set out in the table under paragraph headed Purposes for which we will use your personal data, above

• Internal Third Parties as set out in the Glossary (below)
• External Third Parties as set out in the Glossary (below), including specifically any or all of the hospitals or other service providers mentioned on our website to whom you make an enquiry by completing an Enquiry Form and clicking "Make an Enquiry" on that form or a link to connect with them.
• 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 privacy policy.

We require all third parties with whom we contract to respect the security of your personal data and to treat it in accordance with the law. If you make an enquiry or connect with a service provider, such as a hospital or broker, through our website, remember we do not control their websites or actions and are not responsible for their actions or privacy statements. When you leave our website, or propose to make an enquiry of a provider through our website, we encourage you to read the privacy policy of every website you visit or to whom you wish to make an enquiry through our website to ensure you understand how they propose to use your data.

We share your personal data with companies who carry our webhosting and email services for us. For example, AWS (https://aws.amazon.com) and Google (https://gsuite.google.com). This may, but not always, involve transferring your data outside the European Economic Area (EEA).

Whenever we transfer your personal data out of the EEA, including to the US, 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 by the European Commission. For further details, see European Commission: Adequacy of the protection of personal data in non-EU countries.
• Where we use certain service providers, we may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe. For further details, see European Commission: Model contracts for the transfer of personal data to third countries.

Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.

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 legally required to do so.

How long will you use my personal data for?

We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, 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.

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, regulatory, tax, accounting or other 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 you can ask us to delete your data: see "Your Legal Rights" see below for further information.

In some circumstances we will anonymise your personal data (so that it can no longer be associated with you) for research, analytical or statistical purposes, in which case we may use this information indefinitely without further notice to you.

Under certain circumstances, you have rights under data protection laws in relation to your personal data. As follows:

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 with your consent or 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:

• 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.
• 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.

If you wish to exercise any of the rights set out above, please contact us at datamanager@healthcompare.co.uk.

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 could 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 could 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.

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

Third Parties

Internal Third Parties

Other companies in the Health Compare Group acting as joint controllers or processors based within or outside the EEA and provide IT and system administration services.

External Third Parties

• Service or product providers: who are also processors based within or outside the EEA who provide services or products to consumers or who provide IT and system administration services.
• facebook: we may share certain Identity Data and Technical Data and Profile Data (but not health data) with facebook to enable single sign on or to verify the effectiveness of our adds on their platform and to enable us to provide you with more relevant adds, so as to provide you with a better experience. Facebook's ability to store and to process information collected by them about you is governed by facebook's terms of use and privacy policies.
• Google: We may share certain Identity Data and Technical Data and Profile Data (but not health data) with Google to enable single sign on. We use Google's services to help us analyze the usage of our website so as to provide you with a better experience and improve our system. Google's ability to store and to process information collected by them about you is governed by Google's terms of use and privacy policies.
• Instagram: We may share certain Identity Data and Technical Data and Profile Data (but not health data) in order to verify the effectiveness of our adds on their platform and to enable us to provide you with more relevant adds, so as to provide you with a better experience. Instagram's ability to store and to process information collected by them about you is governed by Instagram's's terms of use and privacy policies.
• twitter: We may share  certain Identity Data and Technical Data and Profile Data (but not health data) in order to verify the effectiveness of our adds on their platform and to enable us to provide you with more relevant adds, so as to provide you with a better experience. twitter's ability to store and to process information collected by them about you is governed by twitter's terms of use and privacy policies.
• Professional advisers including lawyers, bankers, auditors and insurers based within or outside the EEA who provide consultancy, banking, legal, insurance and accounting services.
• HM Revenue & Customs, regulators and other authorities based in the United Kingdom who require reporting of processing activities in certain circumstances.
• Any or all of the hospitals, Virtual GPs, Care Homes, brokers or other service providers mentioned on our website to whom you make an enquiry by completing an enquiry form or clicking a link to connect with them. Their ability to store and to process information collected by them about you is governed by their terms of use and privacy policies.