At PharmaLean Limited, we are committed to protecting your privacy and ensuring the security of your personal data. This Privacy Policy explains how we collect, use, store, share, and protect your personal information when you visit our website www.pharmalean.com, place an order, or interact with us via our call centre, email, or other communication channels (e.g., Telegram or WhatsApp Business). It also outlines your rights regarding your personal data and how to contact us.

This policy applies to all users of our website, customers, and individuals who engage with our services. We comply with the UK General Data Protection Regulation (UK GDPR), the Data Protection Act 2018, and other applicable data protection laws.

1. Who We Are

‍PharmaLean Limited is a company registered in the United Kingdom (Company No. 15736853) with a registered office at 3 Ranelagh Crescent, Ascot, England, SL5 8LW. We are the data controller responsible for your personal data.

For questions or concerns about this Privacy Policy or your data, please contact our Data Protection Officer:

• Email: support@pharmalean.com
• Post: Data Protection Officer, PharmaLean Limited, 3 Ranelagh Crescent, Ascot, England, SL5 8LW

2. What Personal Data We Collect

‍We may collect and process the following categories of personal data:

Personal and Contact Information

• Name, address, email address, and phone number (provided when you place an order, contact us, or engage via Telegram/WhatsApp Business).
• Delivery address and billing details for order processing.

Transaction Information

• Details of products ordered, including quantities and payment information (e.g., payment method, but not full card details, as payments are processed via secure third-party providers).
• Order history and correspondence related to your purchases.

Communication Data

• Messages sent via Telegram, WhatsApp Business, email, or our call centre.
• Records of customer service interactions, including queries, complaints, or feedback.

Website Usage Data

• Technical information, such as IP address, browser type, device information, and operating system, collected when you visit our website.
• Information about your browsing behaviour, such as pages visited and time spent on the site (note: we do not use cookies, but server logs may capture this data).

Special Categories of Data

• In limited cases, we may collect health-related information (e.g., if you provide details about medical conditions when discussing product suitability). This is processed only with your explicit consent or where necessary for contractual purposes.

We do not collect more data than necessary for the purposes outlined in this policy.

3. How We Collect Your Data

‍We collect personal data through:

• Direct Interactions: When you place an order, contact us via email, Telegram, WhatsApp Business, or our call centre, or request information about our products.
• Website Usage: Automatically through server logs when you browse www.pharmalean.com (no cookies are used).
• Third-Party Platforms: When you engage with us via Telegram or WhatsApp Business, we collect data you provide during the order confirmation process.
• Customer Service: When you reach out with queries, complaints, or returns, including photographic evidence for returns or claims.

4. How We Use Your Data

‍We use your personal data for the following purposes, based on the legal bases outlined in the UK GDPR:

To Fulfil Contracts

• Purpose: Process and deliver your orders, confirm quantities, verify names and addresses, send payment links, and provide tracking information.
• Legal Basis: Necessary for the performance of a contract (Article 6(1)(b) UK GDPR).

To Communicate with You

• Purpose: Respond to queries, provide customer support, and send service-related communications (e.g., order confirmations, delivery updates, or return instructions).
• Legal Basis: Necessary for the performance of a contract or legitimate interests (Article 6(1)(b) or 6(1)(f) UK GDPR).

To Improve Our Services

• Purpose: Analyse website usage and customer feedback to enhance our website, products, and customer experience.
• Legal Basis: Legitimate interests (Article 6(1)(f) UK GDPR).

For Marketing (Optional)

• Purpose: Send promotional emails or messages about new products, offers, or updates (only with your consent).
• Legal Basis: Consent (Article 6(1)(a) UK GDPR). You can opt out at any time.

For Legal and Compliance Purposes

• Purpose: Comply with legal obligations, such as tax reporting, or respond to regulatory requests.
• Legal Basis: Compliance with a legal obligation (Article 6(1)(c) UK GDPR).

Special Categories of Data

• Health-related data, if provided, is processed only with your explicit consent (Article 9(2)(a) UK GDPR) or where necessary for contractual purposes.

5. How We Share Your Data

‍We do not sell your personal data or share it with third parties for marketing purposes. We may share your data with:

• Service Providers: Trusted third parties who assist with order processing, payment processing (e.g., Stripe, where applicable), and delivery (e.g., Deutsche Post, Royal Mail, or couriers). These providers are contractually obligated to protect your data and only process it on our instructions.
• Professional Advisors: Legal, accounting, or auditing professionals to comply with regulatory requirements.
• Authorities: If required by law, such as for tax purposes or in response to a court order.
• Business Transfers: In the event of a sale, merger, or reorganisation of PharmaLean Limited, your data may be transferred to the acquiring entity, subject to data protection laws.

Your data will not be transferred outside the UK or EU unless adequate safeguards are in place, such as Standard Contractual Clauses approved by the UK Information Commissioner’s Office (ICO).

6. How We Store and Secure Your Data

• Storage: Your data is stored securely on servers located in the UK or EU. Physical records, if any, are kept in secure facilities at our registered office.
• Retention: We retain your data only for as long as necessary to fulfil the purposes outlined in this policy, including legal or contractual obligations. For example:
  • Order data is retained for 6 years to comply with tax and accounting laws.
  • Customer service communications are retained for 2 years unless required for ongoing issues.
  • Marketing data is deleted upon withdrawal of consent.
  • Competition data is deleted immediately after the competition concludes.
• Security: We use industry-standard measures, such as encryption, secure servers, and access controls, to protect your data. However, no method is 100% secure, and we cannot guarantee absolute security.

7. Your Data Protection Rights

‍Under the UK GDPR and Data Protection Act 2018, you have the following rights:

• Access: Request a copy of your personal data.
• Rectification: Correct inaccurate or incomplete data.
• Erasure: Request deletion of your data (subject to legal or contractual obligations).
• Restriction: Request that we limit processing of your data in certain circumstances.
• Objection: Object to processing based on legitimate interests or for marketing purposes.
• Data Portability: Receive your data in a structured, machine-readable format or have it transferred to another controller.
• Withdraw Consent: Withdraw consent for marketing or special category data processing at any time.

To exercise these rights, contact us at support@pharmalean.com or by post at 3 Ranelagh Crescent, Ascot, England, SL5 8LW. We will respond within one month, though complex requests may take longer. There is no fee for reasonable requests, but we may charge for excessive or repetitive requests.

8. Marketing Communications

‍If you opt in to marketing communications, we may send you promotional emails or messages via Telegram/WhatsApp Business about our products or offers. You can unsubscribe at any time by:

• Clicking the “unsubscribe” link in our emails.
• Replying “STOP” to marketing messages on Telegram/WhatsApp Business.
• Contacting us at support@pharmalean.com.

Service-related communications (e.g., order confirmations, delivery updates) are mandatory and not affected by marketing opt-outs.

9. Cookies and Tracking

‍We do not use cookies or similar tracking technologies on www.pharmalean.com. However, our server logs may automatically collect technical data (e.g., IP address, browser type) for security and analytics purposes. This data is anonymised where possible and used only to improve our website’s functionality.

10. Third-Party Links

‍Our website may contain links to third-party websites (e.g., payment processors or delivery services). We are not responsible for their privacy practices. We recommend reviewing their privacy policies before providing personal data.

11. Children’s Privacy

‍Our services are not intended for individuals under 18. We do not knowingly collect personal data from children. If we become aware that a child has provided data, we will delete it immediately.

12. International Data Transfers

‍Your data is primarily processed within the UK or EU. If we need to transfer data outside these regions (e.g., for delivery to non-EU countries), we will ensure appropriate safeguards, such as Standard Contractual Clauses or adequacy decisions, are in place to protect your data.

13. Changes to This Privacy Policy

‍We may update this Privacy Policy to reflect changes in our practices or legal requirements. Updates will be posted at www.pharmalean.com/legal/privacy-policy, and significant changes will be communicated via email or a website notice. The latest version will apply to your data unless otherwise stated.

Last Updated: 1st March 2025

14. Complaints

‍If you have concerns about how we handle your data, please contact our Data Protection Officer at support@pharmalean.com. If we cannot resolve your issue, you have the right to lodge a complaint with the UK Information Commissioner’s Office (ICO):

• Website: www.ico.org.uk
• Phone: 0303 123 1113
• Address: Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF

15. Contact Us

‍For any questions, to exercise your data protection rights, or to provide feedback, please contact:

• Email: support@pharmalean.com
• Post: Data Protection Officer, PharmaLean Limited, 3 Ranelagh Crescent, Ascot, England, SL5 8LW

For more details, visit www.pharmalean.com/legal/privacy-policy.