Protein Supplies Ltd (t/a/ PronoKal) is a registered company in England and Wales with registration number 07168388 and with its registered office at 2nd Floor, 15 Harley Street, London, W1G 9QQ, respects the personal information of people that it collects and complies with the General Data Protection Regulation (EU 679/2016) (GDPR).
We ask that you read this privacy notice carefully as it contains important information on:
- who we are;
- how and why we collect, store, use and share personal information;
- your rights;
- on how to contact us and supervisory authorities in the event you have a complaint.
1. WHO WE ARE
1.1. PronoKal (UK) (hereinafter, “PronoKal”, “we” or “us”) collects, uses and is responsible for certain personal information about you.
When we do so we are regulated under the GDPR which applies across the European Union (including in the United Kingdom) and we are responsible as “controller” of that personal information for the purposes of those laws.
- Our address: Protein Supplies Ltd t/a/ PronoKal
- Postal Address: 2nd Floor, 15 Harley Street, London, W1G 9QQ
- Tel: 0207 183 2391
- Email: firstname.lastname@example.org
1.2. If you are a prescribing doctor or a nutritionist, please read and review this Policy, as it contains specific sections that inform about the processing of personal data that PronoKal conducts with respect to doctors and nutritionists.
2. GENERAL ASPECTS OF PROCESSING PERSONAL DATA AND INFORMATION COLLECTED FROM WEBSITES AND SOCIAL MEDIA
2.2. PronoKal collects information whenever users visit any of PronoKal’s websites:
(hereinafter, “Site or Sites”)
2.3. We also collect information when you request the services and/or products offered through the Website and where applicable, we collect Personal Information when you access the corporate profiles of our social media accounts where PronoKal has or may have a presence including the following: https://www.facebook.com/PronoKalWeightLoss/
3. OTHER INFORMATION COLLECTED BY US:
3.1. We also collect the following information from;
3.1.1. Users who make enquiries: when you make electronic or telephone enquiries from us in respect of our products and services through our website, we will collect your name address, email address and telephone number (Users);
3.1.2. Patients in receipt of treatment: in respect of those patients who are in receipt of treatment and who have already provided us with the method prescription sheet, duly stamped by the prescribing doctor, we collect health data as set out in clause 4.1.3 below; some of these patients may be registered with the PronoKal Club (Patients);
3.1.3. Doctors: Information about the doctors prescribing the method and browsing our Websites and accessing the medical area of our website (hereinafter, “Doctors”) as set out in clause 5.2 below.
3.1.4. Nutritionists: We collect information about the nutritionists who work with the PronoKal products.
3.2. In addition to the Personal Data that PronoKal collects through this Site, PronoKal may also process Personal Data of Users, Patients, Doctors and/or nutritionists when they contact PronoKal through any means other than this Site.
In such cases we will always specifically inform all categories of data subjects about the processing of their personal data and, if necessary, we will request their explicit consent.
4. HOW WE COLLECT PERSONAL INFORMATION OF USERS AND PATIENTS
4.1. PronoKal will process the personal data as follows:
- through online application forms on the PronoKal Website;
- connection data collected through cookies and similar technologies;
- data provided by the data subject through telephone conversations;
- data provided by the data subject in person at our offices.
4.2. We may also collect Personal Data about Patients provided to us by third parties namely:
- from the prescribing Doctor of the PronoKal method, which is the PronoKal diet programme designed for each individual based upon their specific needs, when the Doctor sends us the prescription form, and
- during the course of the treatment, when Patients undergo follow-up consultations, we will obtain further health data about the Patient.
4.3. We may collect the following information:
- Contact information, such as name and surname(s), postal address, gender, date of birth, email address and telephone number.
- health data, such as weight, possible pathologies or illnesses, prescribed medication, emotional state, potential allergies and intolerances and any other personal health information that the Patient brings to the attention of PronoKal and/or their Doctor and Nutritionists and which are strictly necessary for the correct monitoring and control of the treatment.
5. DATA COLLECTED ABOUT PRESCRIBING DOCTORS AND NUTRITIONISTS
5.1. PronoKal will process Personal Data provided directly by all Doctors and nutritionists;
- through the corresponding registration form of the participating Doctor and
- to PronoKal staff; or
- through public access sources.
5.2. The type of data collected includes but is not limited to:
- the Doctors and/ or nutritionists identity and contact information including name and surname(s), email address, telephone number.
- financial data, when we are provided with the bank details. We collect bank details to be able to pay Doctors and nutritionists.
6. PURPOSES OF PROCESSING PERSONAL DATA, APPLICABLE LEGAL BASIS AND STORAGE TIME
6.1. The Personal Data of the User and/or Patient will be processed for the following purposes:
- To deal with requests for information and/or consultations made by each User, including the appointment request with the prescribing doctor. The data processed for this purpose will be stored until the request for information and/or the query has been answered. The legal basis of such processing will be the User’s implicit consent at the time of request and/or consultation, so that PronoKal can reply to it.
- To manage the relationship with each Patient during the course of the treatment. The data processed for this purpose will be stored during the validity of the contract that the Patient has with PronoKal and, once this has concluded, for such time as is necessary for PronoKal to comply with its legal obligations. The legal basis of the processing will be the performance of the contractual obligations between PronoKal and the Patient.
- To manage the registration of each Patient with the PronoKal Club (Club). The data processed for this purpose will be stored until the Patient cancels their registration with the Club, and for such time as necessary to comply with legal obligations that may apply to Pronokal. The legal basis of the processing is the Patient’s consent at the time of registration.
- To keep Patients informed, by sending commercial communications, including by electronic means, about the products, services and news of PronoKal. The data processed for this purpose will be stored until such time the Patient unsubscribes and opts out of receiving email communications. The legal basis of the processing will be that of explicit consent for all those users who commence treatment for the first time and register as new Patients of PronoKal.
- With respect to Patients who are receiving treatment services from PronoKal, PronoKal relies upon its legitimate interests and the soft opt in in the Privacy and Electronic Communications Regulations in sending information about new products and services to existing Patients.
- To communicate the Personal Data to other Group companies, for internal administrative purposes. Some of these companies may be located outside the European Economic Area (“EEA”), but such transfers will be made in compliance with the applicable data protection laws and guaranteeing a level of data protection equivalent to that of the EEA. The Personal Data processed for this purpose will be stored for as long as the relationship between the Patient and PronoKal exists and, once this has concluded, for such time as is necessary to enable PronoKal to comply with legal obligations. The legal basis of such processing will be the legitimate interests that PronoKal has in transmitting the data for internal administration purposes.
6.2. The Personal Data of the prescribing Doctor and collaborating nutritionists will be processed for the following purposes:
- To manage the contractual relationship between PronoKal and each prescribing Doctor/nutritionist, including paying the Doctors /nutritionists for their services and for their participation in studies, travel and trips related to the PronoKal Products including clinical studies.
- PronoKal relies upon the contract with each Doctor for the processing of such data. The Personal Data processed for this purpose will be stored for as long as the contract for the provision of services between each Doctor and PronoKal remains in place. Following termination of the contract for services PronoKal will retain data for as long as is necessary for PronoKal to comply with its legal obligations.
- To keep the Doctors and nutritionists informed, by sending commercial communications, including by electronic means, about the PronoKal products, services and news. The legal basis for PronoKal to process such data is the consent of the Doctors and nutritionists to the receiving of communications. The data processed for this purpose will be stored until such time as the Doctor notifies PronoKal he /she no longer wishes to receive any such communications.
- Scientific update on the methodology of the method through training sessions, participation in meetings and/or scientific conferences, response to requests for information and/or medical advice/ opinions. PronoKal relies upon the legitimate interests basis when updating the method. The data processed for this purpose will be stored for the duration of the contract between the Doctor and PronoKal. Upon contract termination the data will be retained for such time as is necessary for PronoKal to comply with its legal obligations.
- To communicate the Personal Data to other group companies, for internal administrative purposes. Some of these companies may be located outside the European Economic Area (“EEA”), but such transfers will be made in compliance with the applicable data protection laws and guaranteeing a level of data protection equivalent to that of the EEA. PronoKal relies upon the legitimate interests basis to transmit data for its internal administration purposes. The data processed for this purpose will be stored for the duration of the contract between the Doctor and PronoKal. Upon contract termination the data will be retained for such time as is necessary for PronoKal to comply with its legal obligations.
7. WITH WHOM WE MAY SHARE YOUR PERSONAL DATA
7.1 Your Personal Data may be accessed by third parties under a contract with and acting on behalf of PronoKal, where such access and data processing is essential for the provision of a specific service to PronoKal.
7.2 Your Personal Data may also be communicated to other Group companies, some of them located in countries outside the EEA, for internal administrative purposes, in accordance with the provisions of the previous section.
8. KEEPING YOUR PERSONAL INFORMATION SECURE
8.1 We have appropriate security measures in place to prevent personal information from being accidentally lost or used or accessed in an unauthorised way. We limit access to your personal information to those who have a genuine business need to know it. Those processing your information will do so only in an authorised manner and are subject to a duty of confidentiality.
8.2 We also have procedures in place to deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected data security breach within 72 hours where we are legally required to do so.
8.3 You should also note that whilst we will use all our efforts to protect your privacy and data, we cannot ensure or warrant the security of any information you transmit to us over the internet because no method of transmission over the internet or method of electronic storage can be guaranteed to be absolutely secure.
9. YOUR RIGHTS
9.1 Under the GDPR you have a number of important rights. In summary, those include rights to:
- Fair processing of information and transparency over how we use your personal information.
- Access to your personal information. Please provide enough information to identify yourself correctly; you may make such a request by emailing us at email@example.com.
- Require us to correct any mistakes in your information which we hold. You can request us to rectify and correct any personal data that we are processing about you which is incorrect by contacting us at firstname.lastname@example.org. We will update your personal details and keep your data accurate.
- Require the erasure of personal information concerning you in certain situations. You can request us to erase any personal data that we process about you by contacting us at email@example.com.
- Receive the personal information concerning you which you have provided to us, in a structured, commonly used and machine-readable format and have the right to transmit that data to a third party in certain situations. You can request us to do this by contacting us at firstname.lastname@example.org.
- Object at any time to processing of personal information concerning you for direct marketing. Again, you can object by contacting us at email@example.com.
- Object in certain other situations to our continued processing of your personal information by contacting us at firstname.lastname@example.org.
- Otherwise restrict our processing of your personal information in certain circumstances by contacting us at email@example.com.
9.2 Please note that some of these rights apply in specific circumstances and are qualified by exemptions in data protection legislation. We will advise you if we are relying on any such exemptions when we respond to you.
If you would like to exercise any of those rights, please email, call or write to us or email us as below:
- Protein Supplies Ltd t/a PronoKal, 2nd Floor, 15 Harley Street, London, W1G 9QQ;
- or by sending an email to: firstname.lastname@example.org
10. HOW TO COMPLAIN
We hope that we can resolve any query or concern you raise about our use of your information.
The General Data Protection Regulation also gives you right to lodge a complaint with a supervisory authority, in particular in the European Union (or European Economic Area) state where you work, normally live or where any alleged infringement of data protection laws occurred. The supervisory authority in the United Kingdom is the Information Commissioner, who may be contacted at https://ico.org.uk/concerns/ or telephone: 0303 123 1113.