Privacy Statement Primary Health Net Ltd (PHN) and all subsidiary web sites

Please read our Privacy Policy carefully as this sets out how and why we collect personal information. By providing us with personal information you consent to the processing and transferring of personal information as set out in this Privacy Policy.

For the purposes of the General Data Protection Act 2018, coming into force 25th May 2018 the data controller is Primary Health Net Ltd registered in United Kingdom with company number 2600134. The registered address is The Street, Preston St Mary, Sudbury, CO10 9NG.

1 – General provisions

PHN and all associated subsidiaries respect the personal privacy of all users of the www.primaryhealthnet.com and www.mylocaloptician.co.uk (‘Websites’), all readers, customers and visitors to our sites and to our online shop or those that we communicate with by any media. We take all our obligations for processing personal information very seriously. Any member of the PHN group may use and share (within PHN) the information you provide and other information it holds about you for the purposes set out below.

This Privacy Policy applies to any use of the Website and to communication you have with any member of PHN staff

2 – Supply of personal information

To process your order and enable us to care for your eye care and eye wear needs we will ask you for personal information at the time you register as a customer (which you are required to provide before you place your first order). We may also collect personal information for PHN promotions that will be of interest to you on this website. We may also ask you for your personal information when you request information from us, submit any comments to us or if you report a problem with the Website.

We may collect and process from time to time the following information about you: your name; date of birth; contact telephone numbers (including mobile); e-mail, billing and postal address; and information that you provide by filling in forms of any description on the Website; details of your visit to the Website and any transactions you carry out on the Website.

3 – Legitimate Interest

We are essentially a knowledge site created to assist our readership in areas that concern them in the preservation of good vision.

We do this in a number of ways dependent on our readership.

Our professional site, www.primaryhealthnet.com , which is not promoted outside of the optical sector’s professions, industry and academia with no SEO involvement and is run by independent personnel knowledgeable in optics to provide news and valuable information from recognised sources to the optical community.

This is of key legitimate interest to the optical community. Information is received and checked and transmitted to the community online within 2 -3 days. Again, focussing on the importance of the news and knowledge items we send only to registered recipients an e-news update every 14 days.

Registered receivers have the opportunity to unsubscribe at any time from any of our communications permanently.

The e-news system is also available for Primary Health Net to send to its registered users urgent safety and health alerts received from appropriate parties to primary care providers.

Our vision community has the ability to use our closed registrants’ forums providing intra-group transfers. The benefit is to the user in sharing knowledge and registrants can leave any or all forums at any time.

Primary Health Net provides to vetted third party registered Local Optical Committees secret hosting of knowledge websites for each LOC’s benefits. We ensure that the controllers of the site follow our exacting requirements for GDPR which they are obliged to do independently.

The contents of these sites are visible to each user group through passwords and to no other party save the requirements of our vetted technical crew where maintenance of the site is requested and required. Registrants of these communities, their names and email addresses are added to the Primary Health Net registrants list to allow for the transmission of information, the urgent and standard news transmission and access to the secret sites via the main PHN website. Registrants can unsubscribe at any time though the Register/Login tab.

Likewise, Primary Health Net delivers messages to its readership from time to time provided and paid for by vision care linked companies. We ensure the validity of the company and the message within the eblast ensuring that the message contained has a legitimate interest to our readers who are involved in the vision care sector. As with all our email messages the receiver has the opportunity to unsubscribe at any time, their information being permanently deleted and blocked from any reoccurrence.

Staying informed whether you are a vision care professional of sector worker is vital for the good eye health of the community, for improved understanding of professional matters and for the relating of statutory rules and guidelines laid down by the regulators or professional bodies. Primary Health Net takes its responsibilities very seriously in the legitimate interests for good eye care.

Our public site www.mylocaloptician.co.uk currently holds no information of its readership but contains a list of all contact details of optical practices in the UK and identifies their provision of products, specialisms and home sight testing capability. This is a service to the public allowing them to access vision care in the are they desire it. All practices are encouraged to check their details and ensure they are correct. They can also request to be removed at any time. Again, we consider this of a legitimate interest both to the public and the profession and the optical sector to encourage good vision care.

The mylocaloptician shop within the site collects the name, address of any customers purchasing on line in order to deliver the purchased goods. Their details are not kept within the site or by Primary Health Net after the transaction is complete.

4 – Our use of your personal information – order placement, promotional activity, or when contacting PHN and Website browsing

Personal information will only be used for the purposes of processing your order, entering a PHN promotion or forum, providing you with information on products or services that you request from us or which we feel may interest you (where you have consented to be contacted for such purposes) or as stated in this Privacy Statement and or at the point of collection of the data.

By ordering through the Website, you are required to register for online ordering and to accept the Terms and Conditions of Purchase. Please read the Terms and Conditions of Purchase carefully. This will include: processing data relating to your credit/debit card and order details to enable the fulfilment of your order; processing your personal information so that PHN can inform you about new healthcare related products and services available from PHN; processing your personal information to enhance the services and goods PHN makes available to its customers; processing your personal data to conduct research about your health and shopping habits; transferring personal data to offices located the United Kingdom for the purposes of processing by PHN; using cookies and traffic data.

If you do not register as a customer but wish to email PHN through the website info@primaryhealthnet.com you will be providing us with personal information about yourself, including your email address, name and contact details. You may also be required to supply personal information (but not medical information) through the website for entering a PHN forum or promotion. We will only use such information for the purposes of providing a reply, reviewing your feedback or improving the website. Such proceedings may include the purpose set out in the PHN privacy policy and transferring the personal information to our offices in United Kingdom.

If you are simply browsing our Website we will not collect any personal information which will identify you however, we will collect information using cookies and/or traffic data which uses IP addresses or other numeric identifiers which analyse navigation and use of the Website. See information on what cookies do for you below.

Personal information collected will be retained by PHN for only as long as is reasonably necessary (or as defined under applicable healthcare laws and regulations) to provide products and services (including after sales service) to you.

5 – Our use of cookies

Cookies are small text files that are placed on your computer by websites that you visit. They are widely used in order to make websites work, or work more efficiently, as well as to provide information to the owners of the site. By using this site, we will take it to mean that you are happy to accept our use of cookies.

The cookies used on this website serve a variety of functions. There are cookies required for the proper operation of this website and cookies used for monitoring visitor behaviour, cookies that magically vanish when you close your web browser (called session cookies) and cookies that stay on your computer/device for months or years.

Website operation cookies

A session cookie is used on this website on all pages; this is called ASPSESSIONIDQSRRCSQT and is removed when you close your browser. This cookie is used for general site functionality.

Visitor behaviour cookies

The site uses four Google Analytics cookies for the purpose of visitor behaviour analysis, allowing us to improve our website and understand where our visitors come from. This website uses the following cookies: __utmb, __utmv (both of which expire after 30 minutes), __utmz (expires after a year), __utma (expires after 2 years), __utmc (expires at the end of the browser session). If you want to learn more about these cookies, please review Google’s privacy policy.

The WWF cookie appears on the forum pages of this site. It manages your username.

Third-party cookies

We use third-party advertising companies or affiliates to display advertisements on our website from time to time. These third-party advertising companies or affiliates may separately place or recognise a cookie file on your browser in the course of delivering advertisements to the Site. We cannot see the information collected or stored in third party cookies. We do not provide personal data about you to these third-party advertisers or affiliates or to any other third party.

6 – The law provides you with the following rights

1. a subject access right which enables you to be told whether we hold any personal data about you and to obtain a copy of that information;

2. a right to get personal data relating to you rectified, completed, updated, blocked or erased when incomplete, unclear, obsolete or processed unlawfully;

3. a right to object to the processing of data relating to you on legitimate grounds and a right to object free of charge to the use of data for solicitation purposes.

We will comply with such rights as provided under applicable law. If you wish to exercise your subject access right, please contact us in writing at the address set out on the Site with sufficient information to identify yourself and the information you require. We will respond to your request within 40 days. We reserve the right to charge £10 for complying with a subject access request.

7 – Disclosure to third parties
We will not pass your personal information to anyone outside of PHN, without your prior consent, except the following:

Third party service providers for the purpose of fulfilling your order; in the event that PHN sells or buys any business or assets, in which case we may disclose your personal information to the prospective buyer or seller any agents or subcontractors that process data on our behalf.

8 – Updating our Privacy Statement

As we have done this month May 2018 we may update this Privacy Statement from time to time in our sole discretion and, in such event; we will post a clear message on our Website. By continuing to use the Website after we post notification of any such changes, you accept and agree to this Privacy Statement as modified.

9 – Security

Except if provided to others in the circumstances set out in this Policy, the data supplied by you will be kept on the Site’s secured servers and computer systems, protected from outside intrusions.

10 – Contacting us

Please email questions, concerns or comments you have about this Privacy Statement and the way we process personal information to PHN Company Secretary or write to the Registered Office. Alternatively, you can contact our customer service at: 0208 090 1467

Registered address
Primary Health Net Ltd
Hall Barn, The Street,
Preston St Mary
Sudbury, Suffolk
CO10 9NG

January 2021