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

Full name, Tympa Patient ID, User ID, date of birth and gender.

Contact Data

Full name, Tympa Patient ID, User ID, date of birth and gender.

Technical Data

Your login data and location.

Profile Data

Information contained on your MyTympa account including your username and password, referrals made by you, your interests, preferences, feedback and survey responses.

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 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 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 notice.

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 goods or services). In this case, we may have to cancel a product or service you have with 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:

When you set up an account on MyTympa through the desktop site or MyTympa App.

In order to set up an account and use MyTympa, you will need to provide information to set up an account including Identity and Contact data.

Information you give us.

This is information you provide to us about you by filling in forms on MyTympa or by corresponding with us (for example, by email or chat).

It includes information you provide when you register to use MyTympa, download or register the MyTympa App, subscribe to any of the MyTympa Services, search for the MyTympa App, and when you report a problem with MyTympa. If you contact us, we will keep a record of that correspondence.

Information we collect about you and your device.

Each time you access MyTympa we will automatically collect personal data including Technical and Profile Data. We collect this data using cookies and other similar technologies.

Automated technologies or interactions.

As you interact with MyTympa, we will automatically collect Technical Data. 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.

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

Where we need to perform the contract, we are about to enter into or have entered into with you.

Performance of a 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.

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.

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.

Where we need to comply with a legal obligation.

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

For other personal data, we do not rely on consent as a legal basis for processing your personal data although we will get your consent before sending third party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us.

We have set out below, 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 below.

PURPOSE/ACTIVITY

When you set up your account on MyTympa

Type of data

(a) Identity

(b) Contact

Lawful basis for processing including basis of legitimate interest

• Performance of a contract with you

PURPOSE/ACTIVITY

To process and deliver MyTympa Services including:

(a) Manage referrals

Type of data

(a) Identity

(b) Contact

(c) Marketing and Communications

Lawful basis for processing including basis of legitimate interest

(a) Performance of a contract with you

(b) Necessary for our legitimate interests

PURPOSE/ACTIVITY

To manage our relationship with you which will include:

(a) Notifying you about changes to our terms or privacy notice

(b) Asking you to leave a review or take a survey

Type of data

(a) Identity

(b) Contact

(c) Profile

(d) Marketing and Communications

Lawful basis for processing including basis of legitimate interest

(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 how you and other customers use our products/services)

PURPOSE/ACTIVITY

To enable you to complete a survey

Type of data

(a) Identity

(b) Contact

(c) Profile

(d) Usage

(e) Marketing and Communications 

Lawful basis for processing including basis of legitimate interest

(a) Performance of a contract with you

(b) Necessary for our legitimate interests (to study how you and other customers use our products/services, to develop them and grow our business)

PURPOSE/ACTIVITY

To administer and protect our business and MyTympa (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)

Type of data

(a) Identity

(b) Contact

(c) Technical

Lawful basis for processing including basis of legitimate interest

(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

PURPOSE/ACTIVITY

To deliver relevant content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you

 Type of data

(a) Identity

(b) Contact

(c) Profile

(d) Usage

(e) Marketing and Communications

(f) Technical

Lawful basis for processing including basis of legitimate interest

Necessary for our legitimate interests (to study how users use our products/services, to develop them, to grow our business and to inform our marketing strategy)

PURPOSE/ACTIVITY

To use data analytics to improve MyTympa, products/services, marketing, customer

Type of data

(a) Technical

(b) Usage

Lawful basis for processing including basis of legitimate interest

Necessary for our legitimate interests (to define types of u for our products and services, to keep MyTympa updated and relevant, to develop our business and to inform our marketing strategy)

PURPOSE/ACTIVITY

To make suggestions and recommendations to you about goods or services that may be of interest to you

Type of data

(a) Identity

(b) Contact

(c) Technical

(d) Usage

(e) Profile

(f) Marketing and Communications

Lawful basis for processing including basis of legitimate interest

Necessary for our legitimate interests (to develop our products/services and grow our business)

Marketing

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

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).

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 logging onto your account on MyTympa and checking or unchecking relevant boxes to adjust your marketing preferences or by contacting us at any time.

Cookies

We use cookies to help you navigate efficiently and perform certain functions. You will find detailed information about all cookies under each consent category in your cookie settings.

The cookies that are categorised as “Necessary” are stored on your browser as they are essential for enabling the basic functionalities of the site.

We also use third-party cookies that help us analyse how you use this website, store your preferences, and provide the content and advertisements that are relevant to you. These cookies will only be stored in your browser with your prior consent.

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.

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.

If we need to use your personal 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 personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

We do not share your personal data with anyone else for the purposes of providing the services through MyTympa.

Where you choose to manage or change your appointments with third parties i.e., pharmacists or audiologists, and/or asking us to update records held by such third parties, we are collecting this personal data as a data processor for these third parties and shall not hold this personal data for our own purposes.

We may share your personal data with the third parties we use to help deliver MyTympa and other services provided through MyTympa.

We may occasionally also share your personal data with 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 notice.

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.

International Transfers

We do not transfer your personal data outside the UK.

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.

If we share your personal data with a third party, your personal data will be stored separately in accordance with that third party’s privacy policies. We have no control over this personal data that is stored with third parties.

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.

By law we have to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for six years after they cease being customers for tax purposes. Details of our retention periods are set out in our retention policy which is available on request.

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 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.

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

• • • • 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:
        • • 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.

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.