1.Important information and who we are
The Website is not intended for children and we do not knowingly collect data relating to children.
Full name of legal entity: Hutchings Consultants Ltd
Name or title of data privacy manager: Scott Hayton
Email address: [email protected]
Postal address: Maple House, 53-55 Woodside Rd, Amersham, Bucks, HP6 6AA
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.
The 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 the Website, we encourage you to read the privacy notice of every website you visit.
2.The data we collected about you
Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).
We may collect, use, store and transfer different kinds of personal data about you which we have grouped together follows:
- Identity Data includes first name, last name, and username or similar identifier.
- Contact Data includes email address and telephone numbers.
- Technical Data includes Internet protocol (IP) address, any login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access the Website.
- Profile Data includes your username and password, enquiries made by you in respect of businesses listed on our database, information provided by you for listing on our database, your interests, your preferences and your survey responses.
- Usage Data includes information about how you use the Website and our database.
- Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.
We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.
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, or in order to provide you with information or services that you have requested from us, 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, or provide you with information requested (for example, to provide you information about a particular business listed on our database). In this case, we may have to cancel our contract with you or not provide information to you, but we will notify you if this is the case at the time.
3.How do we collect personal information from you?
You may provide this to us through our Website forms, emails, phone conversations, documents that you provide to us or when you meet us in person, or when you contact us for any other reason by any media, for example when you:
- Enquire about pharmacy businesses for sale or register with us as a buyer to be listed on our database
- Ask us to provide you with a valuation of your pharmacy business
- Register for any of our free reports, books, webinars, seminars, trade shows etc.
- Participate in any survey for us or provide feedback to us
- Interact with us on any social media sites
- Request marketing to be sent to you
This includes Identity, Contact, Profile, Usage and Marketing and Communications Data.
Automated technologies or interactions
Information we receive from other sources.
We may combine the information you provide to us with other information that we collect from 3rd party sources such as, the General Pharmaceutical Society and its register, NHS England and other freely available information from the internet.
We may receive information about you that is shared within the Hutchings Group of Companies namely Hutchings Accountants Ltd and Hutchings Consultants Ltd. We may also receive personal data about you from various third parties and public sources as set out below:
- Technical Data from analytics providers such as Google based outside the EU
- Contact Data from providers of technical or professional services such as lawyers, accountants e.t.c based inside the EU
- Identity and Contact Data from publicly availably sources such as Companies House and the Electoral Register based inside the EU
4. How we use your information
The following processes may utilise various types of personal information that you have provided to us, specifically Identity, Profile, Contact, Usage and Marketing and Communications Data. Please note that to respect your confidentiality, we will not normally correspond with parties who are thinking of buying or selling a pharmacy business at their business e-mail address, postal address or telephone numbers unless you instruct us to do so.
- To carry out our obligations arising from any contracts entered into between you and us and or to provide you with the information, products and services which you have requested from us.
- To manage our relationship with you, including asking you to provide feedback or take part in a survey. This is necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services).
- To provide you with information about similar or related services to those that you have already enquired about that we or Hutchings Accountants (being part of the Hutchings Group of companies) offer. This is necessary for our legitimate interests (to develop our products/services and grow our business).
- We may send you relevant marketing communications, if you have chosen to receive these which may include information about pharmacy businesses for sale, the current pharmacy market and pharmacy related events or offers. This is necessary for our legitimate interests (to develop our products/services and grow our business).
- Where you have entered into a contract with us or we have provided you with services, we may use your information to contact you to ask for your feedback about the services we have provided to you. This is necessary for our legitimate interests (to define types of customers for our products and services, to keep the Website updated and relevant, to develop our business and to inform our marketing strategy).
- To notify you about changes to our service. This is in our performance of a contract with you, necessary to comply with a legal obligation, and necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services).
- To assist us in the improvement and optimisation of advertising, marketing material and content, our services and the Website. This is necessary for our legitimate interests (to define types of customers for our products and services, to keep the Website updated and relevant, to develop our business and to inform our marketing strategy).
- To verify your identity where this is required by Anti Money Laundering Regulations. This is 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), and necessary to comply with a legal obligation.
- To prevent against fraud and detect crime. This is 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), and necessary to comply with a legal obligation.
- To comply with the requirements imposed by law or any court order. This is 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), and necessary to comply with a legal obligation.
We may also make use of Technical Data to:
- Administer our site and for troubleshooting, testing, research and statistical purposes. We use Google Analytics, a third-party website monitoring tool. No data that personally identifies an individual (such as a name or e-mail address) is tracked, collected or uploaded. This is 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).
- Measure or understand the effectiveness of our own advertising activity. This is necessary for our legitimate interests (to define types of customers for our products and services, to keep the Website updated and relevant, to develop our business and to inform our marketing strategy).
- Measure or understand the effectiveness of our marketing emails. This is necessary for our legitimate interests (to define types of customers for our products and services, to keep the Website updated and relevant, to develop our business and to inform our marketing strategy).
We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising:
- We may use your Identity, Contact, Technical, Usage, Profile and Marketing and Communications Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you (we call this marketing).
- You will receive marketing communications from us if you have requested information from us, or if you provided us with your details when you entered a competition or registered for a promotion and, in each case, you have not opted out of receiving that marketing.
- Third-party marketing: We will get your express opt-in consent before we share your personal data with any company outside of our group of companies for marketing purposes.
- Opting out: You can ask us or third parties to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you or by contacting us at any time. Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a product/service product/service experience or other transactions.
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.
5.Where we store your information
Your information may be transferred, stored and processed securely on servers based within the EU and subject to the EU standards and regulations on data protection. By using the Website, or otherwise submitting your personal information to us, you agree to this transfer, storing or processing. We will take all reasonable steps to ensure that your data is treated securely and in accordance with data protection laws. We also take all reasonable steps to ensure that any personal information stored by us on site in non-electronic formats is done so securely.
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.
6.Who has access to your information?
We will never sell or rent your information to third parties. We will not share your information with third parties outside of the Hutchings Group of companies (consisting of Hutchings Consultants Ltd and Hutchings Accountants Ltd) for any marketing purposes.
In the course of our day to day business activities and communication with you, we will occasionally make 3rd party recommendations to you or seek to put you in touch with other relevant business operators such as pharmacy specialist law firms, financial brokers and accountants. We will always seek your permission directly before passing your personal information to these firms and in most cases will provide you with a list of their contact details so you have freedom of choice to contact which ones you see fit.
Any of our staff with access to your information have a duty of confidentiality under the high ethical standards that this firm follows.
7.Disclosures of your personal data
In order to provide an efficient service to our clients and other users of Hutchings Consultants services, we may pass your information to third party service providers, including but not limited to:
- Our CRM Database Operator (where we store data)
- Client / Buyer Identity Verification Companies (Electronic ID Checks required when buying or selling under UK law)
- Selected Confidential Document Disposal Companies (if paper documents are required to be confidentially disposed of in bulk)
- A secure data room provider if utilised in conducting a sale
- Service providers based in the United Kingdom who provide IT and system administration services.
- Professional advisers acting as processors or joint controllers including lawyers, bankers, auditors and insurers based in the United Kingdom 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.
When we use third party service providers, we disclose only the personal information that is necessary to deliver the service you have requested and we have a contract in place that requires them to keep your information secure and otherwise use your information in accordance with applicable data protection law.
We may in a few other limited cases need to disclose your information to third parties:
- In the event that you buy or sell a pharmacy, in which case we may disclose some personal information to the prospective seller or buyer of the business and respective lawyers and accountants in the form of heads of terms for that deal and solely for contact purposes and deal progression.
- If you complete a sale or purchase then we may in future for marketing purposes make reference to that deal and the fact that Hutchings Consultants brokered the deal.
- If Hutchings Consultants Ltd or substantially all of its assets are acquired by a third party, in which case personal data held by it about its clients and users will be one of its transferred assets;
- To our insurers and /or professional advisers insofar as reasonably necessary for the purposes of obtaining and maintaining insurance coverage, managing risks, obtaining professional advice and managing legal disputes.
We do not transfer your personal data outside the European Economic Area (EEA).
In this section we have summarised the rights that you have under data protection law. Some of the rights are complex, applying only in certain circumstances and subject to certain exceptions, and in the interests of keeping this policy concise, not all of the details have been included in our summaries. Accordingly, you should read the relevant laws and guidance from the regulatory authorities for a full explanation of these rights.
You have the right:
- To object to us processing your personal information for marketing purposes. If you object, we will stop processing your personal information for this purpose. When we collect your data, you can choose whether you wish to receive marketing communications from us. If you wish to stop receiving marketing communications, you can opt out at any time by clicking an ‘unsubscribe’ link at the bottom of one of our emails.
- To access the information we hold about you and certain information about our processing of it and your rights in relation to it.
- In certain circumstances, to obtain erasure of the personal information we hold about you, subject to certain exceptions.
- To rectification of the information we hold about you.
- In certain circumstances, to restrict our processing of your personal information or object to us processing it. If you object, we will stop processing your personal information unless certain exceptions apply.
- To request a transfer of your personal data.
- Where our legal basis for processing your personal information is your consent or the performance of a contract and we process it by automated means, to be provided with the personal information we hold about you in structured, commonly used and machine-readable format and to transmit the information to another controller.
- To not be subject to a decision based solely on automated processing, including profiling, that produces legal effects concerning you or similarly affecting you, subject to certain exceptions.
- Where our processing of your personal information is based on your consent, to withdraw that consent at any time. If you withdraw your consent, we will stop the relevant processing, but it will not affect the lawfulness of our processing before the withdrawal.
To exercise any of these rights, email us at [email protected] or write to us at Hutchings Consultants, Maple House 53-55 Woodside Road, Amersham, Bucks HP6 6AA. In addition, you can exercise your right to object to direct marketing at any time by clicking an ‘unsubscribe’ link at the bottom of one of our emails.
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 may 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 may 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.
9.How long do we retain your personal information?
We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements. We review our retention periods for personal data on a regular basis. We are legally required to hold some types of information for certain prescribed periods to fulfil our statutory obligations – generally this is at least 6 years. Outside of specific statutory obligations, we will hold your personal data on our systems for as long as is necessary for the relevant purposes for which we use it, or in accordance with any retention periods set out in any relevant contract you hold with us. You have rights regarding your personal information of which we have tried to list as fully as possible above and if these do not conflict with any legal requirement, contract clause or obligation that we are required to fulfil then you may at any time request that we remove and delete any personal identifiable information of yours that we hold by contacting us at [email protected].
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 requirements.
In some circumstances 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.
10.Security precautions in place to protect your information
We take appropriate technical and organisational precautions to secure your personal information and prevent its loss, misuse or alteration. All information you provide to us is stored on our secure servers. Where we have given (or where you have chosen) a password which enables you to access certain parts of our websites, you are responsible for keeping this password confidential. We ask you not to share your password with anyone. Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your information, we cannot guarantee the security of information transmitted to our site. Any transmission is at your own risk and you agree that we will not be liable for any breach of security unless it has been proved that we have been negligent.
The transmission of unencrypted (or inadequately encrypted) data over the internet is inherently insecure, and for this reason we cannot guarantee the security of data sent between us over the internet.
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The Website may from time to time contain links to and from the websites of affiliates, business partners, suppliers or advertisers. If you follow a link to any of these websites, please be aware that these have their own privacy policies and that we do not accept any responsibility or liability for these policies. Please check these policies before submitting information to these websites.
You can obtain further information about data protection laws by visiting the Information Commissioner’s Office website at www.ico.org.uk
You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority 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.