PRIVACY STATEMENT

The following Privacy Statement (the “Statement”) explains how The Hairloss Shop (“HLS”, “us”, “our” or “we”) handles personal information about you (the “Customer” or “you”). As a “controller” for the purposes of the General Data Protection Regulation (EU) 2016/679 (“GDPR“), the Data Protection Act 2018 and the Privacy and Electronic Communications Regulations (EU) 2003/2426 (collectively, “Data Protection Laws“) we respect your privacy and we are committed to protecting your Personal Data.

As a Customer or user of our website, https://thehairloss.shop/ (our “Website“), this Statement applies both during your use of the Website and when you make a purchase through it.

To ensure the completion of your order, it may also be necessary for us to share your data with other data controllers. These controllers include Harry’s Pharmacy, 92 Milford Street, Stretford, Manchester, M32 8AQ (the “Pharmacy“) and the clinicians we collaborate with (collectively, our “Partners”).

PURPOSE

The purpose of this Statement is to provide you with information regarding how we collect and process your Personal Data. This includes data that you directly provide to us through various channels such as our website, emails, phone calls, postal correspondence, social media, or face-to-face interactions. It encompasses situations where you make purchases, engage with us, use our products or services, provide services to us, or in any other relevant context.

We strongly encourage you to read this Statement in conjunction with any other applicable notices we may provide on specific occasions when collecting or processing your Personal Data. This will ensure that you have a comprehensive understanding of how and why we utilize your data. Please note that this Statement supplements other notices and is not intended to override them.

YOUR RIGHTS

Requests and objections

You have the right to:

• Request access to your Personal Data, which 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 Personal Data that we hold about you, which 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, which 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 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, which 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 a 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.

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 the 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.

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 certain circumstances.

Complaints

You have the right to lodge a complaint with the Information Commissioner’s Office (“ICO”), which serves as the supervisory authority for data protection matters in the UK (www.ico.org.uk). However, we kindly request that you allow us the opportunity to address any concerns you may have before contacting the ICO for assistance. Please reach out to us initially should the need arise.

If you would like to access, correct, amend or delete any personal information we have about you, have any questions about this Statement or wish to exercise your legal rights, please contact our Privacy Compliance Officer at: either yourself, Cora-Jay Maddock or Ryan Brooks (either email?)

Changes to this Statement and your right to rectification

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.

SECTION 1 – WHAT INFORMATION DO WE COLLECT?

Personal Data, or personal information, means any information about an individual (“Data Subject”) from which the person can be identified. It does not include data where the identity has been removed (“anonymised data”).

Under various circumstances, we may collect, use, store and transfer different kinds of Personal Data about you. For clarity, categories of Personal Data are grouped together as follows:

1. Identity Data includes data such as first name, maiden name, last name, username or similar identifier, marital status, title, date of birth and gender.
2. Contact Data includes billing address, delivery address, email address and telephone numbers.
3. Financial Data includes bank account and payment card details.
4. Transaction Data includes details about payments to and from you and other details of products and services you have purchased from us.
5. Technical Data includes internet protocol (IP) address, website traffic data, your login data, browser type and version, time zone setting and location, pages viewed, referral source, length of visit, clickstream data, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this website.

This kind of data forms the basis of some kinds of cookies (see Cookies section at the end of this Statement)

1. Profile Data includes your username and password, purchases or orders made by you, your interests, preferences, feedback and survey responses.

Usage Data includes information about how you use our Website, products and services. This kind of data forms the basis of some kinds of cookies (see Cookies section at the end of this Statement)

1. Marketing and Communications Data includes your preferences in receiving marketing from us and our Partners and your communication preferences.
2. Personal Data from Publicly Available Sources including information that you have shared on a publicly available platform (e.g. such as a public Facebook page).

This list is not exhaustive and in specific instances we may collect additional data for the purposes set out within this Statement.

We may also collect, use and share Aggregated Data, such as statistical or demographic data. Aggregated Data may be derived from your Personal Data but is not considered Personal Data in law; as this data 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 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 Statement.

Special Category Data

Certain types of data about Data Subjects that are demonstrably sensitive or private, and which could be used in a discriminatory way are viewed as sensitive – and as such, identified as Special Category Data under Data Protection Laws.

When information is collected from a Data Subject, Special Category Data may be collected and processed. Special Category Data is only collected and used where it’s needed to provide you with a product or service you have requested or to comply with our legal obligations.

These kinds of information are to be treated with additional care, in comparison to other forms of Personal Data.

Sensitive Personal Data may include, but are not limited to, categories of information such as:

1. Racial or ethnic origin
2. Religious beliefs (or similar)
3. Genetic information
4. Physical or mental health status
5. Sex life
6. Sexual orientation

Only with your explicit consent, we will collect, store and use your health data, including your medical questionnaire answers and prescription details, which falls under this category of Sensitive Personal Data. This may include any photographs, medical reports or anything of the like you submit to us with your medical consultation. Any processing of health data will be handled with utmost confidentiality and will never be utilised for direct marketing purposes.

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 and 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.

SECTION 2 – HOW DO WE COLLECT YOUR INFORMATION?

We use different methods to collect Personal Data from you and about you, including:

1. Direct interactions. You may give us your Identity, Contact and Financial Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
1. apply for or use our products or services;
2. create an account on our website;
3. subscribe to our service or publications;
4. request marketing to be sent to you;
5. enter a competition, promotion or survey; or
6. give us some feedback.
2. Automated technologies or interactions. As you interact with our website, we may automatically collect Technical Data about your equipment (e.g. to display web pages properly on your device), browsing actions and patterns (e.g. to inform optimizations to our website). We collect this personal data by using cookies, please see below for further details on how we use cookies, server logs and other similar technologies. We may also receive Technical Data about you if you visit other websites employing our cookies.

Third parties or publicly available sources.

We may share and receive personal data about you from various third parties and public sources as set out below:

1. Technical Data from the following parties:
1. analytics providers such as Google based outside the EU;
2. advertising networks; and
3. search information providers.
2. Contact, Financial and Transaction Data from providers of technical, payment and delivery services.
3. Identity and Contact Data from data brokers or aggregators.

In each case of the above, we will alert you when Data Protection Laws legally requires us to do so.

SECTION 3 – WHAT DO WE DO WITH YOUR INFORMATION?

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.

PURPOSE/ACTIVITY	TYPE OF DATA	LAWFUL BASIS FOR PROCESSING INCLUDING BASIS OF LEGITIMATE INTEREST
General Enquiries or Complaints	Identity Contact	Necessary for our legitimate interests (to assist with your query/complaint)
To register you as a new user on our Website	Identity Contact	Performance of an agreement with you
To process and deliver your goods and/or deliver our services including: (a) to provide treatment advice and related relevant services; (b) to manage and administer our business relationships; (c) to manage billing and manage payments, fees and charges and to keep records; (d) Collect and recover money owed to us;	Identity Contact Financial Transaction Marketing and Communications	Performance of an agreement with you
To manage our relationship with you which, for example, will include: (a) Notifying you about changes to our terms or this Statement (b) Asking you to leave a review or take a survey	Identity Contact Profile Marketing and Communications	Performance of an agreement with you Necessary to comply with a legal obligation Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services)
To enable you to partake in a prize draw, competition or complete a survey	Identity Contact Profile Usage Marketing and Communication	Positive opt-in consent Necessary for our legitimate interests (to study how customers use our products/services, to develop them and grow our business)
To administer, provide, conduct and protect our business (including provision of our goods and/or services) and our website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)	Identity Contact Technical Financial Transaction Marketing and Communications	Necessary for our legitimate interests (for running our business, provision of our goods and/or services (directly or on behalf of a third party), provision of administration and IT services, network security, to prevent fraud 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	Identity Contact Profile Usage Marketing and Communications Technical	Necessary for our legitimate interests (to study how customers use our products/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. This includes monitoring and recording your use of our website	Technical Usage	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)
To make suggestions and recommendations to you about goods or services that may be of interest to you	Identity Contact Technical Usage Profile	Necessary for our legitimate interests (to develop our products/services and grow our business)
To ask you to partake in surveys	Identity Contact Technical Usage Profile

Prescription Customers

To provide and deliver our goods and services, it is necessary for us to process Special Category Data, such as your health information obtained from your medical questionnaire or prescription. This Special Category Data comprises of the information you provide in the questionnaire and may be shared with clinicians determine if it is safe for you to use the medical products you have ordered, and subsequently issue a prescription. When handling such Special Category Data, we must fulfil additional conditions as mandated by Data Protection Laws. We will only process Special Category Data upon obtaining your explicit consent, for example when you have granted us consent to access your health data provided in your prescription for the purpose of delivering our services and goods to you.

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 at hello@hairloss.shop

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.

SECTION 4 – CONSENT

How do you get my consent?

When you provide us with personal information to complete a transaction on our Website, verify your credit card, place an order, arrange for a delivery or return a purchase (if applicable), we imply that you consent to our collecting it and using it for that specific reason only.

If we ask for your personal information for a secondary reason, like marketing, we will either ask you directly for your expressed consent, or provide you with an opportunity to say no.

How do I withdraw my consent?

If you are a recipient of our marketing and communications after you opt-in and you change your mind, you may withdraw your consent for us to contact you, for the continued collection, use or disclosure of your information, at anytime, by contacting us at info@mhrclinic.co.uk. or hello@hairloss.shop.

SECTION 5 – DISCLOSURES AND SHARING OF YOUR PERSONAL DATA

We may disclose your personal information if we are enforcing our legal rights, defending legal claims, are required by law to do so or if you violate our Terms of Service.

Our Partners

The Pharmacy

Our dispensing pharmacy is:

Harry’s Pharmacy

92 Milford Street,

Stretford,

Manchester,

M32 8AQ

Our dispensing Pharmacy will process your Personal Data to provide its services, namely to process your orders and sell, supply dispense and post prescription medication to you in accordance with our Terms and Conditions and managing its relationship with you, which may include but is not limited to dealing with any queries you may have.

Our Clinicians/Doctors

Our network of clinicians consists of licensed individuals who are registered with the General Pharmaceutical Council in the United Kingdom. These clinicians possess the necessary qualifications as accredited pharmacist independent prescribers and are skilled in conducting remote consultations and prescribing medication online. They will evaluate your request for the prescribed treatment to determine its clinical suitability. In order to provide this service by means of remote consultations and issuing prescription medicine online, our Partner clinicians will process your Personal- and Special Category Data to assess your health information and determine whether the treatment you have selected is clinically appropriate and, if so, issue your prescription. Our Partner clinicians may also need to request further information from you in certain circumstances to inform their decision.

Third-Party Services

We may share your Personal Data with our third-party providers who process your Personal Data as part of the service they offer to us. We implement measures to guarantee that our service providers adhere to legal requirements, utilize your data solely based on our contractual agreement, and maintain its security. In general, the third-party providers used by us will only collect, use and disclose your information to the extent necessary to allow them to perform the services they provide to us.

Our third-party service providers can be divided into the following categories:

• Data storage and hosting: Superchance Ltd
• Web Hosting: Superchance Ltd
• Analytics or development for web services/business intelligence: Superchance Ltd
• Advertising and marketing: Facebook, Instagram, Google AdWords, BuyMe.media Ltd

However, certain third-party service providers may act as separate controllers of your Personal Data and have their own privacy policies in respect to the information we are required to provide to them for your purchase-related transactions. For these providers, we recommend that you read their privacy policies so you can understand the manner in which your personal information will be handled by these providers.

1. Harry’s Pharmacy assess your medical information in order to prescribe, sell and deliver the prescription products
2. Superchance Limited administers payment for the Products

Third Party Links

Our Website may contain links to third-party websites, plug-ins, and applications. By clicking on these links or enabling such connections, you may allow third parties to collect or share data about you. Please note that we do not have control over these third-party websites and we cannot be held responsible for their privacy practices. When you navigate away from our Website, we recommend that you review the privacy notice of every website you visit to understand how your data will be handled.

Internet-based Transfers

As the Internet operates on a global scale, utilizing it for the collection and processing of personal data entails the international transfer of data. Regrettably, transmitting information over the Internet is not entirely secure. While we will make every effort to safeguard your Personal Data, we cannot assure the security of data transmitted to our website through third-party networks. Any transmission is undertaken at your own risk. Once we receive your information, we will employ rigorous procedures and security measures to mitigate the risk of unauthorized access.

If we choose to sell, transfer or merge parts of our business or our assets or seek to acquire or merge with other businesses, we may have to share or transfer your Personal Data and/or Special Category Data to the new owners so that we may continue to sell products to you. 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 Statement.

SECTION 6 – INTERNATIONAL TRANSFERS

The majority of Personal Data undergoes processing within the UK and EEA, and as a general practice, we refrain from transferring Personal Data outside the EEA. However, there may be exceptional circumstances where such transfers are necessary. In such cases, we strictly adhere to the conditions outlined in the GDPR to maintain the same level of protection for Data Subjects’ Personal Data when it is transferred to a third country.

During these instances, we take measures to ensure appropriate safeguards are in place, such as utilizing approved Model Clauses or relying on the EU/US Privacy Shield framework. Additionally, if required, we obtain explicit consent from you. We take utmost care to ensure that the recipient of the data possesses the capability, willingness, and legal obligation to uphold the standards mandated by the GDPR.

This includes ensuring that the following appropriate measures are in place:

• information security (e.g. encryption, network security, etc.)
• organisational measures (e.g. training and confidentiality measures)
• limiting processing to instructions within a written agreement
• ensuring we can review and audit the Sub-processor’s ability to comply on an ongoing basis
• the application of further proportionate measures in cases where Special Category Personal Data is transferred to countries outside the EEA.

In particular, remember that certain providers may be located in or have facilities that are located in a different jurisdiction than either you or us. So, if you elect to proceed with a transaction that involves the services of a third-party service provider, then your information may become subject to the laws of the jurisdiction(s) in which that service provider or its facilities are located.

As an example, if you are located in Canada and your transaction is processed by a payment gateway located in the United States, then your personal information used in completing that transaction may be subject to disclosure under United States legislation, including the Patriot Act. Once you leave our stores website or are redirected to a third-party website or application, you are no longer governed by this Privacy Policy or our websites Terms of Service.

SECTION 7 – DATA SECURITY

To protect your personal information, we have implement appropriate security measures, take reasonable precautions and follow industry best practices to make sure it is not accidentally or inappropriately lost, misused, accessed, disclosed, altered or destroyed.

If you provide us with your credit card information, the information is encrypted using secure socket layer technology (SSL) and stored with AES-256 encryption. Although no method of transmission over the Internet or electronic storage is 100% secure, we follow all PCI-DSS requirements and implement additional generally accepted industry standards.

Further, we limit access to your Personal Data to those employees, third-party providers, clinicians and any other third parties who have a business need to access and process the material. In such scenarios, these individuals will handle your Personal Data solely based on our instructions and are bound by confidentiality obligations. We adhere to the principle of “Data Protection by Design” as mandated by the GDPR, ensuring that protection of Personal Data is inherently integrated into all our business activities.

We have implemented procedures to address any potential instances of suspected Personal Data breaches and will notify you and any applicable regulator of a breach where we are legally required to do so.

SECTION 8 – DATA RETENTION

How long we use/hold/store your Personal Data

We will only retain your Personal Data for as long as necessary to fulfil the purposes for which it is collected; furthermore, including the purposes of satisfying any: legal, accounting or reporting requirements.

To determine the appropriate retention period for Personal Data, we consider the amount, nature and sensitivity of the Personal Data; the potential risk from unauthorised use or disclosure of your Personal Data, the purposes for which we process your Personal data, whether we can achieve such purposes through other means, and applicable legal requirements.

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.

SECTION 9 – COOKIES

What are cookies?

Cookies are small file of letters and numbers that we store in your web browser that allows The Hairloss Shop or a third party to recognise you. Cookies contain information that is transferred to your computer’s hard drive. Cookies can be used to collect, store and share bits of information about your activities across websites, including on MHR Clinic website. This helps us to provide you with a good experience when you browse our website and also allows us to improve our site. By continuing to browse the site, you are agreeing to our use of cookies.

Cookies fall under the “Usage” and “Technical” categories of Personal Data described above might be used for the following purposes:

• To enable certain functions
• To provide analytics
• To store your preferences
• To enable ad delivery and behavioural advertising

We use the following cookies:

• Strictly necessary cookies. These are cookies that are required for the operation of our website. They include, for example, cookies that enable you to log into secure areas of our website, use a shopping cart or make use of the online payment services.
• Analytical/performance cookies. They allow us to recognise and count the number of visitors and to see how visitors move around our website when they are using it. This helps us to improve the way our website works, for example, by ensuring that users are finding what they are looking for easily.
• Functionality cookies. These are used to recognise you when you return to our website. This enables us to personalise our content for you, greet you by name and remember your preferences (for example, your choice of language or region).
• Targeting cookies. These cookies record your visit to our website, the pages you have visited and the links you have followed. We will use this information to make our website and the advertising displayed on it more relevant to your interests. We may also share this information with third parties for this purpose.

• Session Cookies. These cookies are used to identify a particular visit to our Website. These cookies expire after a short time, or when you close your web browser after using our Website. We use these cookies to identify you during a single browsing session, such as when you log into our Website.
• Persistent cookies: These kinds of cookies will remain on your devices for a set period of time specified in the cookie. We use these cookies where we need to identify you over a longer period of time. For example, we would use a persistent cookie if you asked that we keep you signed in.

How do third parties use cookies on our Website?

Third party companies (including, for example, advertising networks and analytics companies) generally use cookies to collect user information on an anonymous basis. They may use that information to build a profile of your activities on the MHR Clinic and other websites that you’ve visited, over which we have no control.

What are your cookies options?

If you don’t like the idea of cookies or certain types of cookies, you can change your browser’s settings to block and/or delete cookies that have already been set and to not accept new cookies. To learn more about how to do this, visit the help pages of your browser.

Please note, however, that if you set your browser settings to block all cookies (including essential cookies) or delete cookies, you may not be able to access all or parts of our site, or experience limited or incomplete functionality.

SECTION 10 – AGE OF CONSENT

By using this site, you represent that you are at least the age of majority in your state or province of residence, or that you are the age of majority in your state or province of residence and you have given us your consent to allow any of your minor dependents to use this site.

SECTION 11 – CHANGES TO THIS PRIVACY POLICY

We reserve the right to review and modify this Privacy Statement at any time, so please review it frequently.

Changes and clarifications will take effect immediately upon their posting on the Website.

As a Data Subject you will be notified of any further amendments to this policy which result in substantial effects to your rights.

CONTACT US

If you would like to contact a representative at our organisation in relation to: this agreement, your Personal Data, or to assert any of your rights, please contact us:

• By post:
• By email:

Our contact will endeavour to get back to you as soon as possible and legally obligated time limits.