Privacy Policy

This is the Privacy Policy for Millennium Health Focus (MHF)

Terminology

The following terminology applies to this privacy policy. “Client”, “you” or “your” means the individual accessing or using the service, or the company, or other legal entity on behalf of which such individual is accessing or using the service as applicable. “We”, “Us” or “Our” refers to MHF, a trading name of Millennium Health Focus Limited.  “Cookies” are small files that are placed on your computer, mobile device or any other device by a website containing the details or your browsing history on that website among its many uses.  “Personal data” is any information that relates to any identified or identifiable individual. “Usage Data” refers to data collected automatically either generated by the use or the service or from the service infrastructure itself (the duration of a page visit). “Service” refers to the website. “Service Provider” means any natural or legal person who processes the data on behalf of us. It refers to third party companies or individuals employed by us to facilitate the service to provide the service on behalf of us or to perform services related to the service or to assist us in analysing how the service is used.

About This Policy

We collect, use and are responsible for storing personal information about you. When we do so, we are regulated under the General Data Protection Regulation which apply across the European Union (including the United Kingdom) and we are responsible as a controller of that personal information for the purposes of those laws.

We respect your privacy and protect your personal data. This policy describes our policies and procedures on the collection, use and disclosure of your information when you use the service and tells you about your privacy rights and how the law protects you. We use your personal data to provide and improve the service. By using the service you agree to the collection and use of information with this Privacy Policy.

Who We Are

We are Millennium Health Focus Limited, registered in England and Wales under company number 09226542. We have our registered office at 170 Vauxhall Bridge Road, London, SW1V 1DX.

Contact

To contact us please email us at info@mhfcovidtesting.co.uk or phone us at 02070601136.

Collecting and Using Your Personal Data

Information we collect includes:

1. Personal data

Whilst using our service, we may ask you to provide us with certain personally identifiable information that can be used to contact or identify you. Personally identifiable information may include but is not limited to:

• Email Address;
• Title;
• First and Last Names;
• Phone Number;
• Address, Postal Code;
• Gender; and
• Biometric Data (such as saliva swab);
• Date of Birth
• Passport Number/ ID card reference number
• NHS Number
• Vaccination status
• Ethnicity
• Coach/flight/vessel number
• Quarantine address
• Dates on which you departed countries, countries through which you moved/ have previously transited through and date of arrival in the UK.
• Ethnicity

Please note third parties and other companies who form contracts with us to deliver your tests, such as your employees and companies you have engaged to perform our services, may also provide us your personal data with your consent.

2. Usage Data

Usage data is collected automatically when using the service.

Usage data may include information such as your devices’ Internet Protocol address (e.g. IP address), browser type, browser version, the pages of our service that you visit, the time spent on those pages, unique device identifiers and other diagnostic data.

When you access there service by or through a mobile device we may collect certain information automatically, including, but not limited to, the type of mobile device you use, your mobile device unique ID, the IP address of your mobile device, your mobile operating system, the type of mobile internet browser you use, unique device identifiers and other diagnostic data.

We may also collect information that your browser sends whenever you visit our service or when you access the service through or by a mobile device.

3. Cookie and Tracking Technology Data

We use cookies and similar tracking technologies to track the activity on our service and store certain information. Tracking technologies used are beacons, tags and scripts to collect and track information and to improve and analyse our service.  The technologies we use may include;

• Cookies or Browser Cookies.

A cookie is a small file placed on your device. You can instruct your browser to refuse cookies or to indicate when a cookie is being sent.

However, if you do not accept cookies you may not be able to use some parts of our service. Unless you have adjusted your browser setting so that it will refuse cookies, our service may use cookies.

• Flash Cookies

Certain feature of our service may use local stored objects (or flash cookies) to collect and store information about your preferences or your activity on our service. Flash cookies are not managed by the same browser settings as those used for browser cookies.

• Web Beacons

Certain sections of our service and our emails may contain small electronic files know as web beacons, also referred to as clear gifs, pixel tags and single pixel gifs that permit us, for example, to count users who have visited those pages or opened an email and for other related website statistics.

For example, to record the popularity or a certain section and to verify system and server integrity.

• Persistent and Session Cookies

Cookies can be “persistent” or “session” cookies. Persistent cookies remain on your personal computer or mobile device when you go offline, while session cookies are deleted as soon as you close your web browser. We use both persistent and session cookies set out below;

• Necessary/ Essential Cookies (type; session cookies). These cookies are essential to provide you with services available through the website and to enable you to use some of its features. They help to authenticate users and prevent fraudulent use of user accounts. Without these cookies the services that you have asked for cannot be provided, and we only use these cookies to provide you with those services.
• Notice Acceptable Cookies (type; persistent cookies). These cookies identify if users have accepted the use of cookies on the website.
• Functionality Cookies (type; persistent cookies). These cookies allow us to remember choices you make when you use the website, such as remembering your login details or language preference. The purpose of these cookies is to provide you with a more personal experience and to avoid you having to re-enter your preferences every time you use the website.

Other cookies may come from companies we use may also place cookies on your computer and store personal data. These will have their own Privacy Policies concerning how they process your personal data. Companies we may use include Google

Use of and Purposes for Collecting your Personal Data

The company may use your personal data for the following purposes:

• To Provide and Maintain our Service, including to monitor the usage of our service. The personal information we process that is provided to us directly by you is provided for the purpose that you can obtain results from the service we provide;
• To Manage your Requests: To attend and manage your request to us;
• To Manage your Account: To manage your registration as a user of the service. The personal data you provide can give access to you to different functionalities of the service that are available to you as a registered user;
• For the Performance of a Contract: The development compliance and undertaking of the purchase contract for the products or services you have purchased or of any other contract with us through the service.
• To Contact You: To contact you by email, telephone calls, SMS, or other equivalent of electronic communication, such as a mobile application’s push notifications regarding updates or informative communications related to our service; and
• For other Purposes: We may use your information for other purposes such as data analysis, identifying usage trends, business transfers, determining the effectiveness of our promotional campaigns and to evaluate and improve our service, products, services, marketing, and your experience.
• To comply with our legal obligations to provide certain information to public health authorities.

Sharing of Personal Information

Please note, we may share your personal information in the following situations:​

• With Service Providers: We may share your personal information with service providers to monitor and analyse the use of our service to contact you.
• With Affiliates; We may share your information with our affiliates in which case we will require those affiliates to honour this privacy policy.  Affiliates include our parent company and any other subsidiaries, joint venture partners or other companies that we control or are under common control with us.
• With associated parties; We may share your information with medical professionals who are contracted to the company, such as Doctors who sign Fit to Fly and Test to Release certificates. We will act as the Data Controller and them as a data sub-processor. Agreements will be in place to prevent your information being passed to third parties and will also describe retention rights. 

Legality (General Data Protection Regulation)

We will reserved the right to use your personal data wherever and whenever the law permits us. The lawful basis we rely on for processing this information includes;

(a) When we have a contractual obligation and need to perform the contract that we are about to enter into or have entered into with you;

(b) When we have a legal obligation or regulatory obligation and must comply with it (for example providing details to public health authorities);

(c) Your implied consent through using this website or any of our services, which means you accept how we may process your data. You

may withdraw your consent for us to process your personal data by contacting us when the law permits.

(d) When it is needed for our legitimate interests (or those of the third party) and your interests and fundamental rights do not override those interests.

Retention of Your Personal Data

The company will retain your personal data only for as long as is necessary for the purposes set out in this privacy policy. We will retain and use your personal data to the extent necessary to comply with our legal obligations for example if we required to retain your data to comply with applicable laws, resolve disputes and enforce our legal agreements and policies.

The company will retain usage data for internal analysis purposes.  This data is generally retained for a shorter period of time except when this data is used to strengthen the security or to improve the functionality of our service, or we are legally obligated to retain this data for longer time periods.

Transfer of Your Information (Both domestically and internationally)

Your information, including personal data, is securely stored and processed at our operating offices and any other places where the parties involved in the processing of information are located. It means that this information may be transferred to – and maintained on – computers located outside of your state, county, country or other governmental jurisdiction where the data protection laws may differ from those of your jurisdiction.

The company will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this policy and that no transfer of your data will take place to an organisation or a country unless there are adequate controls in place there including the security of your data and other personal information.

External third parties used in our processes may process your information outside the EEA and we may use contracts approved by the European Commission as a result of using certain service providers.  For instance should we use American providers we may transfer data to them as required. We may also transfer your personal data to countries that have been deemed to provide and adequate level of protection for personal data by the European Commission.

It is a requirement of law that we retain basic information about our customers including contact, identity, financial and transaction data for six years after they cease being customers for tax purposes, unless a data audit intervenes. Regarding test results we will notify the local public health governing body and retain required data as stipulated by them.

We will always keep your personal data only for as long as required for the purposes set out in this privacy policy and your consent to this policy followed by your submission of such information represents your agreement to that transfer.

Disclosure of Your Personal Data

• Business transactions

If we​ are involved in a merger, acquisition or asset sale, your personal data may be transferred in the event it is being stored and processed still for the purposes set out in this policy.

• Law Enforcement

Under certain circumstances, we may be required to disclose your personal data if required to do so by law or in response to valid requests by public authorities (for example a court).

• Third Party Affiliates

We may provide your personal data when it is reasonable to third party affiliates to improve our service.

• Other Legal Requirements

The company may disclose your personal data in the good faith belief that such action is necessary to

• Comply with a legal obligation (such as passing information to Public Health England)
• Protect and defend the rights and property of the company
• ​Prevent or investigate possible wrong doing in connection with the service
• Protect the personal safety of the users of the service or the public
• ​Protect against legal liability

Consent

We do not rely on consent as a legal basis when for instance it is required by law for us to have to submit results to Public Health Authorities.

By using our website you consent to us processing your personal data. You have the right to withdraw consent in instances on which we rely on consent to process your personal data. You can do this by contacting info@mhfcovidtesting.co.uk

Your Legal Rights

You have a legal right to request in relation to your personal data; access to it, transfer of it, correction of it, deletion of it. You can also request restriction of its processing or object to how it is processed. Further, you have a right to withdraw consent to it being processed at any time.

If you have a complaint about how we process your personal data you should contact us at info@mhfcovidtesting.co.uk. You also have the legal right to complain to the Information Comissioner’s Office (ICO) at www.ico.org.uk.

Security of Your Personal Data

Under data protection law you have rights including:

• Your right of access – you have the right to ask us for copies of your personal information;

• Your right to rectification – you have the right to ask us to rectify personal information you think is inaccurate. You also have the right to ask us to complete information you think is incomplete;

• Your right to erasure – you have the right to ask us to erase your personal information in certain circumstances;

• Your right to restriction of processing – you have the right to object to the processing of your personal information in certain circumstances; and

• Your right to data portability – you have the right to ask that we transfer the personal information you gave us to another organisation or to you in certain circumstance. 

You are not required to pay any charge for exercising your rights. Please contact us if you wish to make a request.

Links to other websites

Our service may contain links to other websites that are not operated by us. We have no control and assume no responsibility for the content privacy policies or practices of any third party sites or services. This privacy policy has been created with the help of the Privacy Policy Generator and the Information Commissioners Office.

Changes to This Privacy Policy

We may update this privacy policy from time to time and will notify you of any changes by posting the new privacy policy on this page. You are advised to review this privacy policy for any changes if you use us again. Changes to this privacy policy are effective when they are posted on this page.