4 September 2023

Privacy & Cookies Policy

Version number: 2.1.1

Effective date: Friday 15th September 2023

  1. Who are we?
    1. We are Medical Business Consulting Limited.For privacy queries, you can contact us at enquiries@thefreshuk.com. Other contact details are on our website. 
  2. What’s the purpose of this policy? 
    1. It tells you what to expect when we collect personal information from users of our website/services. Please only use them if you are completely happy with this policy. 
    2. Generally, the policy covers only information provided to us. If you give personal information to other people, such as payment providers or other websites, please check their privacy policies. Nor does this policy apply to personal information that we collect as a “processor”, e.g., relating to your customers or users of websites that we host. For this data, our legal obligations are set out separately in our contract with our clients.
  3. Might the policy change?
    1. Yes. We will give you notice of the new version by posting it on our service and communicating it otherwise if appropriate.
  4. What do we collect? 
    1. Information that you upload to our service or otherwise give us such as:
      • your name and contact details;
      • information about your authorised users;
      • details about your transactions with us;
      • information that you include in communications with us including surveys and feedback; and
      • contact or other information which you give or allow us to use for newsletters or other marketing.
    2. Automated information about your use of our service such as: the internet protocol (IP) address used to connect your device to the internet, connection information such as browser type and version, information about your device including device-type and device identifier, operating system and platform, mobile network data, a unique reference number linked to the data you enter on our system, login details, the site from which you arrived at our service, details of your activity with date / time stamps including pages you visited and your searches / transactions.  
  5. What’s our reason / legal basis for collecting the information?
    1. Because it’s necessary to take steps at your request to enter into a contract with you and/or to perform such a contract. This applies to information such as initial enquiries and to contact, transaction and authorised user information. 
    2. Because it’s in our “legitimate interests”, e.g., sending you marketing communications about our similar products/services, managing and improving our service including tracking usage patterns and preventing or detecting fraud or abuse. This applies to information such as contact details, automated usage data and to surveys and feedback.
    3. Because you’ve specifically agreed on our service (e.g., by selecting a consent box). This may apply to contact or other information that you specifically agree to us using for certain kinds of marketing. You can withdraw permission at any time as explained on our service or by emailing us at the above email address.  
    4. Because it’s necessary to comply with legal or regulatory obligations.
  6. How long do we keep personal information? 
    1. We will generally hold your information for our default standard retention period of six years after the end of our contract/relationship with you, but we may delete it earlier/later as set out below or in our terms and conditions.
    2. We will keep your information that we use for email newsletters or other marketing until you tell us to stop sending you such messages.
    3. We will generally keep automated browsing information for up to 14 months.     
    4. Even if our contract/relationship with you is over, we may continue to display reviews/testimonials provided by you until you ask us to remove them.
  7. To whom do we send or make available your personal information? 
    1. To other people who supply us with services, e.g.,web/app hosting and management, payment, customer service, chatbots, live chat services, messaging, email distribution, online advertising, analytics, etc. 
    2. To other users of our website if you include your name in a review/testimonial on the site. 
    3. To regulators, the police and other law enforcement or official authorities to help deal with fraud and abuse and/or comply with legal requirements and/or to protect us or others.
    4. To insurers and professional advisers in connection with our insurance cover or to deal with legal claims.
    5. To potential buyers so far as reasonably necessary, in the case of an actual or proposed (including negotiations for a) sale or merger or business combination involving all or the relevant part of our business.
  8. Do we send your information outside the UK?
    1. Your personal information (e.g., name, username, contact details, IP address, browsing information) is transferred to companies outside the UK (generally to the US) that provide us with the services mentioned above (see: To whom do we send or make available your personal information?). Where this happens, we will ensure that there is a legal basis to do so, for example under contracts with standard contractual clauses sanctioned by the Information Commissioner that are designed to provide adequate safeguards for your personal information. 
  9. What rights do you have? 
    1. If the legal requirements are met: To ask us for access to your personal information, to rectify it if there are mistakes, to delete it or restrict its use in certain circumstances or to “data portability” or to withdraw any consent you’ve given (e.g., marketing).
    2. You may also have the right to object to use of your personal information in certain circumstances.
    3. If you have a complaint about how we are dealing with your personal information, please contact us via the email address above. If you are not happy with our response or think we are not handling your personal information in accordance with the law, you have the right to complain to the Information Commissioner’s Office (ICO).
    4. For more information about your rights, visit the ICO’s website: www.ico.org.uk .
  10. What about cookies?
    1. We and/or other companies use cookies and other tracking technologies on our website. A cookie is an identifier (a small file of letters and numbers) that is sent to your web browser.  Cookies are widely used to make websites work, or work more efficiently, as well as to provide information to the website owner or others. Some are session temporary “session” cookies that remain in the cookie file of your browser only until your browser is closed. Whereas persistent cookies stay for longer (depending on the lifetime of the specific cookie). For further information on cookies, including how to use your browser to block them and how to delete existing cookies, visit: www.allaboutcookies.org . Our site’s functionality will be limited if you configure your browser to reject cookies.
    2. We ourselves may place the following types of cookies:
      Type of cookiePurpose
      Logged-in statusAssess whether you are logged in to our site
      AuthenticationIdentify and authenticate you to help you move easily through the site 
      PreferencesStore information about the preferences you’ve selected (e.g., favourites, currency, wish-lists) and personalise the site
      Shopping cartRemember contents of your cart and related preferences
      AffiliateTrack whether you have visited us from websites affiliated with us so we can pay affiliates and assess the effectiveness of the affiliate links
      SecurityProvide security-related features to protect our site, for example to help stop fraudulent logins
      Cookie noticeStore your response to our cookie notice
    3. Companies which provide us with a service also place cookies. Some of these cookies (e.g., from Google) may involve certain information, such as your name and contact details and/or the IP and web address of the page you’re visiting, being sent to the company concerned. Below is a summary of the kinds of cookies used together with details about who places them and where you can go to get more information and to opt out (where possible):
      • Analytics cookies: These kinds of cookies recognise and count the number of website visitors as well as providing other information about the visit such as duration, route through the website and where the visitor came from. This information helps us to improve the way our website works, for example by making sure users find what they need easily. These cookies are provided by:
      • Advertising cookies: These kinds of cookies are typically used to personalise ads on this or other sites based on your use of our site, to measure ad effectiveness (for example, how often you click on or view ads and whether you go on to buy something from the advertiser) and to stop you being shown the same ad repeatedly. These cookies are provided by:
        • Facebook (including “Facebook Pixel”)
          • Facebook’s cookies policy (see especially under “Advertising, recommendations, insights and measurement”) including how to control Facebook’s use of cookies
          • Facebook’s privacy policy
        • Hotjar Analytics. More:
          • information about the types of cookies placed by Hotjar script on our site
          • Hotjar’s privacy policy (see under “Personal Data collected from Hotjar’s… Users”)
      • Live Chat cookies: Tawk.to, our live chat provider, may place cookies in connection with its live chat widget on our website. See its cookies policy .

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