EM Analytical Ltd (EM Analytical, we, us, our) is committed to protecting the privacy and security of your personal data. This Privacy Notice describes how we collect, use and look after your personal data when you visit our website pegasuslabportal.com (our Website) (regardless of where you visit it from), register an account with our Website (Account) and order products and services listed on our Website (Product and Services) from us and the supply of our Products and Services where we have accepted your order for the same. It also tells you about your rights and how the law protects you.
Important information
The data we collect about you
We will notify you of this at the relevant time.
How personal data is collected
We collect personal data in the following ways:
Direct interactions | We collect personal data when you set up an Account, order our Products and Services from our Website, make an enquiry with us, or otherwise correspond with us (by post, phone or email). |
Provision of our Services | We collect Special categories of personal data when you provide the Patient Information required for the purchase of each Fit2Fly COVID Home Test Kit and when we process Samples in our Lab in order to produce test results and create Fit2Fly Certificates (as applicable). |
Automated technology | We automatically collect personal data (technical and usage) when you browse or interact with our Website, by using cookies, server logs and other similar technologies. We may also receive technical data about you if you visit other websites which use our cookies. |
Publicly available sources | We may collect personal data from publicly availably sources based in the UK, such as Public Health England. |
Third parties | We may receive personal data from: (a) our lab technicians who carry out the testing services on our behalf (b) analytics providers; (c) advertising networks; (d) search information providers; (e) our other suppliers such as website support and maintenance providers; (f) third parties who provide your personal data on your behalf, such as your parents, guardians, those with parental responsibility or other authorised representatives of individuals; |
How we use your personal data
and have not opted out of receiving marketing communications, unsubscribed from our mailing list or withdrawn your consent.
Disclosure of your personal data
International transfers
Data security
Data retention
Your legal rights
Schedule
Part 1 Types of personal data
Contact data | Billing address, delivery address, email address and telephone number. |
Identity data | First name, maiden name, last name, date of birth, username or similar identifier. |
Special categories of personal data | Health data including medical and health information, and the result of your Fit2Fly COVID Home Test Kit. |
Marketing and communication data | Your preferences in receiving marketing from us. |
Profile data | Your username, password and login credentials for your Account. |
Technical data | 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 our Website. |
Transaction data | Details about payments to and from you and other details of Products and Services you have purchased from us. |
Part 2 Lawful basis for processing and processing activities
The lawful basis upon which we may rely on to process your personal data are:
Consent | You or your nominated representative (including parents, guardians, those with parental responsibility or who are otherwise authorised to act on your behalf) have given their express consent for us to process your personal data for a specific purpose. |
Contract | The processing is necessary for us to perform our contractual obligations with you under our contract, or because you have asked us to take specific steps before entering into a contract with you. |
Legal obligation | The processing is necessary for us to comply with legal or regulatory obligation. |
Legitimate interests | The processing is necessary for our or a third party’s legitimate interest e.g. in order for us to provide the best service to you via our Website. Before we process your personal data on this basis we make sure we consider and balance any potential impact on you, and we will not use your personal data on this basis where such impact outweighs our interest. |
Set out below are specific details of the processing activities we undertake with your personal data and the lawful basis for doing this.
Purpose/Activity | Type of data | Lawful basis for processing |
---|---|---|
To create your account and register you as a new customer. | Identity & contact | To perform our contract with you. |
To process and deliver your order, manage payments, fees and charges and debt recovery. | Identity, contact, transaction, marketing & communications |
(i) To perform our contract with you; (ii) As necessary for our legitimate interest in recovering debts due to us. |
To provide our Services to you and analyse your sample for a Fit2Fly COVID Home Test Kit. | Identity, contact, special categories of personal data | To perform our contract with you or provide our Products and Services to you where your representative has ordered our Products and Services on your behalf. |
To report results that have a produced a positive indicator of the presence of COVID 19 within a Sample. | Identity, contact and special categories of data | To comply with a legal obligation to notify government public health bodies of tests providing a positive indicator of the presence of COVID-19 within a sample. |
To manage our relationship with you and notify you of changes to our Terms or Privacy Notice. | Identity, contact, profile, marketing & communications |
(i) To perform our contract with you; (ii) As necessary to comply with a legal obligation; (iii) As necessary for our legitimate interests in keeping our records updated and analysing how customers use our Products and Services. |
To administer and protect our business and this Website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data). | Identity, contact & technical |
(i) As necessary for our legitimate interests in 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; (ii) As necessary to comply with any legal obligations. |
To deliver relevant website content/advertisements to you and measure or understand the effectiveness of our advertising. | Identity, contact, profile, usage, marketing, communications & technical | As necessary for our legitimate interests in studying how customers use our Products and Services, to develop them, to grow our business and to inform our marketing strategy. |
To use data analytics to improve our Website, Products and Services, marketing, customer relationships and experiences. | Technical & usage | As necessary for our legitimate interests to define types of customers for our Products and Services, to keep our Website updated and relevant, to develop our business and to inform our marketing strategy. |
Part 3 Your legal rights
You have the following legal rights in relation to your personal data:
Access your data | You can ask for access to and a copy of your personal data and can check we are lawfully processing it. |
Correction | You can ask us to correct any incomplete or inaccurate personal data we hold about you. |
Erasure |
You can ask us to delete or remove your personal data where: (a) there is no good reason for us continuing to process it; (b) you have successfully exercised your right to object (see below); (c) we may have processed your information unlawfully; or (d) we are required to erase your personal data to comply with local law. We may not always be able to comply with your request for specific legal reasons, which will be notified to you at the time of your request. |
Object |
You can object to the processing of your personal data where: (a) we are relying on our legitimate interest (or those of a third party) as the basis for processing your personal data, if you feel it impacts on your fundamental rights and freedoms; (b) 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 and in such circumstances, we can continue to process your personal data for such purposes. |
Restrict processing |
You can ask us to suspend or restrict the processing of your personal data, if: (a) you want us to establish the accuracy of your personal data; (b) our use of your personal data is unlawful, but you do not want us to erase it; (c) you need us to hold your personal data (where 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 personal data, but we need to verify whether we have overriding legitimate grounds to use it. |
Request a transfer | You can request a transfer of your personal data which is held in an automated manner and which you provided your consent for us to process such personal data or which we need to process to perform our contract with you, to you or a third party. We will provide your personal data in a structured, commonly used, machine-readable format. |
Withdraw your consent | You can withdraw your consent at any time (where we are relying on consent to process your personal data). This does not affect the lawfulness of any processing carried out before you withdraw your consent. |
Part 4 Third Parties
Service providers |
Acting as processors who provide IT and system administration services being: Microsoft Corporation registered in the State of Washington US, whose registered office is located at 1 Microsoft Way, Redmond, Washington 98052-8300 |
Payment Gateway Providers |
Acting as controller who require information to collect and process payments on our behalf for Products and Services which have been ordered through our Website or to issue refunds being: Barclays Bank PLC and Barclaycard International Payments Limited trading as Barclaycard: Barclays Bank PLC, authorised by the Prudential Regulation Authority and regulated by the Financial Conduct Authority and the Prudential Regulation Authority (Financial Services Register number: 122702). Registered in England No. 1026167. Registered Office: 1 Churchill Place, London E14 5HP. Barclaycard International Payments Limited, regulated by the Central Bank of Ireland. Registered Number: 316541. Registered Office: One Molesworth Street, Dublin 2, Ireland, D02 RF29. |
Professional advisors | Acting as processors or 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 controllers who require reporting of processing activities in certain circumstances such as Public Health England, Public Health Wales, Public Health Scotland and Public Health Agency (Northern Ireland). |
Third-party service providers |
Acting as data processors who provide laboratory testing and/or analytical services for processing and testing patient samples: London Medical Laboratory Limited, Unit 1, 2 Pensbury Street, London, SW8 4TJ AlphaBioLabs Ltd, 14 Webster Court, Carina Park, Warrington, WA5 8WD |
Other third parties | Such third parties 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 Notice. |
Part 5 Glossary
Aggregated data | Information such as statistical or demographic data which may be derived from personal data but which cannot by itself identify a data subject. |
Controller | A body that determines the purposes and means of processing personal data. |
Data subject | An individual living person identified by personal data (which will generally be you). |
Personal data | Information identifying a data subject from that data alone or with other data we may hold but it does not include anonymised or aggregated data. |
Processor | A body that is responsible for processing personal data on behalf of a controller. |
Special categories of personal data | Information about race, ethnicity, political opinions, religious or philosophical beliefs, trade union membership, health, genetic, biometric data, sex life and sexual orientation. |
ICO | Information Commissioner’s Office, the UK supervisory authority for data protection issues. |