Privacy policy

This Privacy Policy sets out how CFW Healthcare Limited (trading as Pharmacy Prime) uses and protects your personal data.

This website is not intended for children and we do not knowingly collect data relating to children.

 

General

Controller

CFW Healthcare Limited (the Company, us, we or our) is the Controller and responsible for your Personal Data.

We have appointed a Data Protection Officer (DPO) who is responsible for overseeing questions in relation to this Privacy Policy. If you have any questions about this Privacy Policy, including any requests to exercise your legal rights (as detailed below), please contact the DPO using the following contact details:

DPO, Pharmacy Prime (clinic@pharmacyprime.com)

Changes to our Privacy Policy & Your Duty to Inform Us of Changes

We keep our Privacy Policy under regular review. This version was last updated on 13th April 2026 and previous versions are available on request.

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, for example a new address or email address.

Third Party Links

This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy policy of every website you visit.

Complaints

You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK regulator for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.

 

Your Personal Data

Introduction

Pharmacy Prime respects your privacy and is committed to protecting your Personal Data. This Privacy Policy tells you about to how we look after your Personal Data, including when you:

·       visit and use our website (regardless of where you visit it from);

·       use our products and services;

·       create an account on our website;

·       provide your contact details as a potential client (or your employer does so); or

·       contact us (including to make a complaint),

and tells you about your privacy rights and how the law protects you.

Types of Personal Data We Collect About You

Personal Data means any information about an individual from which that person can be identified. We may collect, use, store and transfer different kinds of Personal Data about you which we have grouped together as follows:

·       Identity Data, includes first name, last name, any previous names, username or similar identifier, marital status, title, date of birth, NHS number and gender.

·       Contact Data, includes billing address, delivery address, email address and telephone numbers.

·       Financial Data, includes online payment account details (including paypal and other express wallets) and payment card details.

·       Transaction Data, includes details about payments to and from you and other details of products and services you have purchased from us.

·       Technical Data, includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, device ID and other technology on the devices you use to access this website.

·       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 interact with and use our website, products and services.

·       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 which is not Personal Data as it does not directly (or indirectly) reveal your identity. For example, we may aggregate individuals' Usage Data to calculate the percentage of users accessing a specific website feature in order to analyse general trends in how users are interacting with our website to help improve the website and our service offering.

We do collect Special Categories of Personal Data about you, including information about your health, and genetic and biometric data. We do this so that we can provide our products and services to you and comply with our duties under the relevant regulations. We collect this data with your explicit consent when you use our services, agree to our terms and this Privacy Policy, and this data is under the overall supervision of an appropriate medical professional.

We do not collect any information about criminal convictions and offences.

How is Your Personal Data Collected?

We use different methods to collect data from and about you including through:

·   Your interactions with us. You may give us your Personal Data by filling in online forms or by corresponding with us by post, phone, email or otherwise. This includes Personal Data you provide when you:

o    apply for our products or services;

o    create an account on our website;

o    subscribe to our services;

o    request marketing to be sent to you;

o    enter a competition, promotion or survey; or

o    give us feedback or contact us.

·       Automated technologies or interactions. As you interact with our website, we will automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this Personal Data by using cookies and other similar technologies. Please see our Cookies Policy below for further details.

·       Third parties or publicly available sources. We will receive Personal Data about you from various third parties and public sources as set out below:

o    identity verification service providers, including Lexis Nexis;

o    the health system (including local authorities, pharmacies, and other NHS organisations) and healthcare professionals in the care pathway;

o    analytics providers and search information providers (including Google);

o    providers of technical, payment and delivery services;

o    credit reference agencies; and

o    publicly available sources.

How We Use Your Personal Data

We will only use your Personal Data when the law allows us to. Most commonly, we will use your Personal Data in the following circumstances:

·       Performance of a contract with you: Where we need to perform the contract we are about to enter into or have entered into with you.

·       Legitimate interests: We may use your Personal Data where it is necessary to conduct our business and pursue our legitimate interests, for example to prevent fraud and enable us to give you the best and most secure customer experience. We make sure we consider and balance any potential impact on you and your rights (both positive and negative) 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).

·       Legal obligation: We may use your Personal Data where it is necessary for compliance with a legal obligation that we are subject to. We will identify the relevant legal obligation when we rely on this legal basis.

·       Consent: We rely on consent only where we have obtained your active agreement to use your Personal Data for a specified purpose, for example if you subscribe to an email newsletter.

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.

Please 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 Personal 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 in the table below.

Purpose / Use	Type of Data	Legal Basis
To register you as a new customer	(a) Identity (b) Contact (c) Health	Performance of a contract with you
To process and deliver your order including: (a) Manage payments, fees and charges (b) Collect and recover money owed to us	(a) Identity (b) Contact (c) Financial (d) Transaction (e) Marketing and Communications	(a) Performance of a contract with you (b) Necessary for our legitimate interests (to recover debts due to us)
To process and deliver your order by providing services to you, including: (a) Assessing your health data to deliver the relevant products and services (b) Ongoing check ins around your use of our products and services (c) Verifying your identity before providing some products and / or services (including medicines)	(a) Identity (b) Contact (c) Profile (d) Transaction (e) Health	(a) Performance of a contract with you (b) Necessary to comply with a legal obligation (c) Necessary for our legitimate interests (to manage our relationship with you)
To manage our relationship with you which will include: (a) Notifying you about changes to our terms or privacy policy (b) Dealing with your requests, complaints and queries (c) Contacting you to complete a partially complete consultation for our products or services	(a) Identity (b) Contact (c) Profile (d) Marketing and Communications (e) Health	(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 manage our relationship with you) (d) Consent, having obtained your prior consent to being contacted for such purposes
To enable you to partake in a prize draw, competition or complete a survey	(a) Identity (b) Contact (c) Profile (d) Usage (e) Marketing and Communications	(a) Performance of a contract with you (b) Necessary for our legitimate interests (to study how customers use our products / services, to develop them and grow our business)
To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)	(a) Identity (b) Contact (c) Technical	(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
To deliver relevant website content and online advertisements to you and measure or understand the effectiveness of the advertising we serve to you	(a) Identity (b) Contact (c) Profile (d) Usage (e) Marketing and Communications (f) 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, customer relationships and experiences and to measure the effectiveness of our communications and marketing	(a) Technical (b) 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 send you relevant marketing communications and make personalised suggestions and recommendations to you about goods or services that may be of interest to you based on your Profile Data	(a) Identity (b) Contact (c) Technical (d) Usage (e) Profile (f) Marketing and Communications (g) Health	(a) Necessary for our legitimate interests (to carry out direct marketing, develop our products / services and grow our business). (b)Consent, having obtained your prior consent to receiving direct marketing communications.
To send you relevant marketing in relation to third parties’ products and / or services	(a) Identity (b) Contact (c) Technical (d) Usage (e) Profile (f) Marketing and Communications (g) Health	(a) Necessary for our legitimate interests (to carry out direct marketing, develop our products / services and grow our business). (b) Consent, having obtained your prior consent to receiving direct marketing communications.
To carry out market research through your voluntary participation in surveys	(a) Identity (b) Contact (c) Profile (d) Usage (e) Marketing and Communications	Necessary for our legitimate interests (to study how customers use our products/services and to help us improve and develop our products and services).
To complete audits of our services	(a) Identity (b) Contact (c) Technical (d) Usage (e) Profile (f) Health	(a) Performance of a contract with you (b) Necessary to comply with a legal obligation (c) Necessary for our legitimate interests (to manage our relationship with you and to improve our services, ensuring that they are in compliance with applicable laws and regulations)

 

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.

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 our products 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.

Marketing

Direct Marketing

At various points on our website when your Personal Data is collected, including during the ordering and registration process, you may be asked to indicate your preferences for receiving direct marketing communications from us by opting-in. We may also analyse your Identity, Contact, Technical, Usage and Profile Data to form a view which products, services and offers may be of interest to you so that we can then send you relevant marketing communications.

Third Party Marketing

Unless we are required to refer you to another service, we will not share your personal data with any third party for marketing purposes. However, on the rare occasion that we do so, we will get your express consent before we share your personal data with any third party for their own direct marketing purposes.

We will not sell your personal data under any circumstances.

Opting Out of Marketing

You can ask to stop sending you marketing communications at any time by following the unsubscribe instructions set out in the relevant communication.

If you opt out of receiving marketing communications, you will still receive service-related communications that are essential for administrative or customer service purposes (for example, relating to order confirmations for products and / or services).

Disclosures & Transfers

Disclosures of Your Personal Data

We may share your Personal Data (where necessary) with the third parties set out below for the purposes for which we use your Personal Data (as detailed in the table above):

·       healthcare professionals involved in your care pathway;

·       regulators who monitor our delivery of the products and services;

·       the police for the prevention and detection of crime, including fraud;

·       service providers acting for you in the provision of related services, including the prescribing, dispensing and supply of medication;

·       service providers acting as processors based in the UK and European Economic Area (EEA) who provide IT and system administration services;

·       professional advisors acting as processors or joint controllers including lawyers, bankers, auditors and insurers based in UK and EEA who provide consultancy, banking, legal, insurance and accounting services;

·       HM Revenue & Customs, regulators and other authorities acting as processors or joint controllers based in the United Kingdom who require reporting of processing activities in certain circumstances; and

·       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 Policy

We require all third parties to respect the security of your Personal Data and to treat it in accordance with the law. Where engaged as processors, 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. Where the third party service providers act for you in the provision of related services, they will be an independent controller in relation to your Personal Data and you should refer to their privacy policy to understand how they will process your Personal Data – please refer to our T&Cs on our website for details on these service providers.

International Transfers

Information that you provide to us is stored on our secure servers which are located within the UK / EEA.

We may also transfer your Personal Data to service providers that carry out certain functions on our behalf. This may involve transferring Personal Data outside the UK to countries which have laws that do not provide the same level of data protection as the UK law.

Whenever we transfer your Personal Data out of the UK to countries which have laws that do not provide the same level of data protection as the laws which apply in the UK, we always ensure that a similar degree of protection is afforded to it by ensuring that the following safeguards are implemented:

·       the UK has decided that the country or the organisation we are sharing your information with will protect your information adequately;

·       such processors are using systems that are ISO27001 and / or SOC-2 certified; or

·       we have entered into a contract with the organisation with which we are sharing your information (on terms approved by the UK) to ensure your information is adequately protected. To obtain a copy of these contractual safeguards, please contact us at the details set out above.

Security & Retention

Data Security

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.

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.

Data Retention

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. Also, where your Personal Data constitutes a ‘health record’ it will be retained in line with the NHS guidance (https://transform.england.nhs.uk/information-governance/guidance/records-management-code/).

In some circumstances you can ask us to delete your Personal Data – see Your Legal Rights in the section 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.

Data Processing with Omnisend

Our store utilises Omnisend for email marketing and customer engagement. When you sign up for our newsletter, make a purchase, or interact with our website, some of your personal data (e.g., email address, purchase history, browsing behavior) may be collected and processed by Omnisend. This data allows us to personalise your shopping experience and tailor our email marketing efforts. We take measures to ensure your data is handled securely and only used in accordance with this Privacy Policy. You can unsubscribe from these communications at any time by clicking the "unsubscribe" link included in any of our emails. 

Your Rights

Legal Rights

Under certain circumstances, you have rights under data protection laws in relation to your Personal Data.

You have the right to the below.

·       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:

o    If you want us to establish the data's accuracy.

o    Where our use of the data is unlawful but you do not want us to erase it.

o    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.

o    You have objected to our use of your Personal 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 using the details set out above.

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.

 

Cookies Policy

Our website uses cookies to distinguish you from other users of our website. This helps us to provide you with a good experience when you browse our website and also allows us to improve our site.

A cookie is a small file of letters and numbers that we store on your browser or the hard drive of your computer if you agree. Cookies contain information that is transferred to your computer's hard drive.

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 e-billing services. You can switch off these cookies in your browser settings but you may then not be able to access all or parts of our website.
• Analytical or performance cookies. These 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.

You can find more information about the individual cookies we use and the purposes for which we use them in the table below:

 

 

Please note that we have no control over the third party cookies listed above. These name third parties include advertising networks and providers of external services like web traffic analysis services. These third party cookies are likely to be analytical cookies or performance cookies or targeting cookies. To deactivate the use of third party advertising cookies, you may visit the relevant consumer page to manage the use of these types of cookies. To opt out of being tracked by Google Analytics across all websites, visit http://tools.google.com/dlpage/gaoptout

If you do not want to accept cookies, you can change your browser settings so that cookies are not accepted. If you do this, please be aware that you may lose some of the functionality of this website. For further information about cookies and how to disable them please go to the Information Commissioner’s webpage on cookies: https://ico.org.uk/for-the-public/online/cookies/. Alternatively, you may wish to visit www.allaboutcookies.org which contains comprehensive information on how to do this on a wide variety of browsers. You will also find details on how to delete cookies from your computer, as well as more general information about cookies. Please note that, as these websites are not owned or operated by us, we are not responsible for any of the content on them.