When you write a review on Healthcare Delivery Reviews or otherwise use our Website, we collect and process personal data about you. This document helps you understand what personal data we collect about you, how we collect it, what we use it for, and what rights you have regarding your personal data.
Healthcare Delivery Reviews is the entity responsible for processing your personal data.
1. Personal data
What we collect and what we use it for.
1.1 Master data
When you write your first review on the Website, you will automatically generate a personal account for you on Healthcare Delivery Reviews (“Account”) and collect the following personal data about you (the “Master Data”):
Your title, Your full name (first names only will be publicly available), Your securely encrypted password, Your prescription product, Your email address, and Your location and country. This information is mandatory, which means that it will not be possible to write a review on the Website without it.
Additional data you can add is your telephone number. This additional information will not be part of your public profile but will be part of the Master Data.
Healthcare Delivery Reviews is an open review platform and when we display your review people can see the first name of who wrote the review and the date the review was first submitted.
1.2 Information in reviews and ratings
When you write a review about a company, we collect the information you put in your review. This includes:
Which company you review, The overall performance star rating comprised of the individual components of the service you are reviewing (1-5 stars).
The headline and content of your review The date of your review Confirmation that you have used the service provider you are reviewing within the last 2 years The information and content written regarding your experience Your customer recommendation score Please don’t share any sensitive personal documents or information with us, either concerning yourself or others.
If you notify us about a review that you believe violates our User Guidelines, then we collect the information you provide in your notification to us. This can include which review you notified us about, the reason for your notification, the date of your notification, etc.
Read more about which cookies the Website uses and for which purposes below.
1.5 Your IP address, browser settings and location
When you visit the Website, we register your computer’s IP address and browser settings. The IP address is the numerical address of the computer used to visit the Website. Browser settings can include the type of browser you use, browser language, and time zone. We collect this information so that we can trace the computer used in cases of misuse or unlawful actions in connection with visits to or use of the Website. We also use the IP address to approximate your location (at city level) and so that we know which sets of our Terms & Conditions apply to your use of our Website.
1.6 For what purposes do we use your personal data?
We will use the information you provide to us to:
Provide our services to you, including displaying your reviews, and providing you with access to your profile and our Website Identify you as a registered user when you log in to the Website and re-visit the Website Verify the legitimacy of your reviews Improve the Website and our services Invite you to leave more reviews Respond to your questions and provide related customer service Pass on a message from the company you reviewed or the company that has invited you to review a service via the Website.
Contact you if your review is flagged by other users or companies and, if necessary, ask you to provide documentation to verify your review or experience Engage in various internal business purposes, i.e data analysis, audits, fraud monitoring and prevention, developing new products and services, improving or modifying the Website, identifying usage trends, determining the effectiveness of our promotional campaigns and operating and expanding our business activities Comply with legal requirements and legal process, requests from public and governmental authorities, relevant industry standards and our internal policies Enforce our Terms & Conditions Protect our operations or those of any of our affiliates Protect our rights, privacy, safety or property and/or that of our affiliates, you or others Allow us to pursue available remedies or limit any damages that we sustain We will also use the information in other ways for which we provide specific notice at the time of collection.
Contact you to discuss any negative reviews you have left to ask if you would be interested in speaking with a different company who has a higher score on the Website and overall provides much more positive reviews from their current customers. We would not do this without your expressed consent. If you consent to us referring you to a different healthcare provider, we will provide your contact details (phone number and email address) to a new company which we would have discussed with you beforehand. We can pass your details onto more than one company if you wish/consent to it, to discuss your needs with multiple suppliers before you make a decision. You will consent to your details being passed to a different supplier before we send it (either through a form or email). We do not charge you for this service and you are in no contract or commitment to choose a new supplier if you do not want to. We provide this service because you have left a negative review and we believe someone else might be able to provide you with a better service
If you change your mind, you can opt out and we will cease all communications with the new company and they will not be in contact with you to discuss your needs.
1.7 On what legal basis do we process your personal data?
We need to process your personal data in order to:
Perform our contract with you (see Article 6.1.b of the GDPR) Comply with our legal obligations (see Article 6.1.c of the GDPR) and operate an online review platform in compliance with, for example, the Unfair Commercial Practices Directive, ICPEN’s guidelines on online reviews and endorsements, The Consumer Protection from Unfair Trading Regulations 2008, The Competition and Markets Authority’s guidance on online reviews and endorsements, the Danish Consumer Ombudsman’s Guidelines on publication of user reviews, the Danish Marketing Practices Act etc. Pursue legitimate business interests of our own related to operating the Website and providing our services to you, or to pursue the legitimate interests of third parties as long as your interests and fundamental rights do not override those interests (see Article 6.1.f of the GDPR). For the establishment, exercise or defence of legal claims, where necessary (see Article 9.2.f of the GDPR) Some of these grounds for processing your personal data overlap, so there may be several reasons which justify us processing your personal data.
In those limited circumstances where you have expressly given your consent to us to process your personal data (see Article 6.1.a of the GDPR), you are free to revoke your consent at any time. However, please be aware that we may have the right to continue to process your information if it can be justified on one of the other legal bases mentioned above.
You have the right to object to how we process your personal data, or ask us to restrict the processing. Please see below, at 13, for more details.
If you would like more information about our legal basis for processing your personal data, please contact our Data Protection Officer (DPO).
2. Disclosure of personal data
2.1 Disclosure of personal data on the Website
We are an open review platform and we share your review on our Website so that others can read about your experience with a specific company. When you write a review, we will disclose your review, your first name, the date of review.
We recommend that you exercise care in deciding which information to make available for disclosing on the Website and be aware that depending on the level of information provided, you may or may not be anonymous.
Master Data and other information
When you write a review on our Website and create an Account, your first name, review, and any responses you have written will be visible on the Website. The companies you review can also receive this information about your review.
When you write a review on the Website, we use your computer’s IP address to approximate your location to the nearest city. This information is made available to other users of the Website.
2.2 Disclosure to other services, websites and companies
One of Healthcare Delivery Reviews main goals is to increase the exposure and availability of reviews on the Website. We therefore permit other services to show reviews created on the Website. This increases the potential audience for your reviews.
The categories of third party services and companies who can show your review(s) together with your public user profile are:
Search engines, including Google and Bing Companies reviewed on Healthcare Delivery Reviews Companies that have invited you to review their service Consumer portals and business portals, including price comparison websites, shopping guides, etc. Other similar websites where, in Healthcare Delivery Reviews assessment, it will be relevant for users to search for reviews. Once you submit your review, it is published on the Website subject to approval from the Website administrator. This means that the following information is disclosed:
Your review(s), Your name and the additional data you choose to add to your profile.
If you write a review on Healthcare Delivery Reviews in response to an invitation sent by a company via our review invitation services, the company who sent you the invite will be able to link your review with the invitation.
If we need to verify your review, we will contact you and ask for documentation that shows that you have had a buying or service experience with the company you reviewed. We therefore recommend that you keep such documentation for 12 months from the date of your review. We explain the type of documentation you should send us here.
We do not share the documentation you send to us with the reviewed company. However, if you have a reference number or order ID, we may pass that on to the company, unless you ask us not to.
2.4 Other disclosures
In addition to the above, we disclose your personal data to the following parties and in the following circumstances:
To allow third party vendors, consultants and other service providers to perform services on our behalf To Healthcare Delivery Reviews subsidiaries and other companies within the Healthcare Delivery Reviews group of companies To comply with laws or to respond to claims, legal process (including but not limited to subpoenas and court orders) and requests from public and government authorities To cooperate with regulatory bodies and government authorities, including but not limited to Trading Standards, the Competition and Markets Authority, relevant data protection authorities and the Danish Consumer Ombudsman, in connection with investigations or case referrals To third parties in connection with enforcement of our Terms & Conditions and Guidelines To third parties in order for us to protect our operations or those of our affiliates To third parties in order for us to pursue available remedies, or limit damages that we may sustain To third parties in order for us to investigate, prevent or take action regarding suspected or actual prohibited activities, including but not limited to fraud and misuse of our Website To a third party in the event of any reorganisation, merger, acquisition, sale, joint venture, assignment, transfer or other disposition of all or any portion of our business or assets (including in connection with any bankruptcy or similar proceedings). 3. Data controller 3.1 Information for which we are the data controller.
We are the data controller of the Master Data you enter to create and maintain your profile, which includes but is not limited to your name, password, email address and location, as well as the registration of your IP address.
We are also the data controller of the information which is disclosed to other services (see 2.3). Denmark’s data protection laws govern our collection of your data.
3. Information for which you are the data controller.
You are the data controller for the content you choose to disclose on the Website.
4. Links to websites
Our Website contains links to other websites. Our inclusion of such links does not imply that we endorse those websites. We do not control the content of those third party websites, and assume no responsibility for the third party or their policies or practices.
We encourage you to review the privacy policies for these third party websites because their procedures for collecting, handling and processing personal data will be different from ours.
5. Data processors and transfer of personal data outside the EU
We use external companies to maintain the technical operation of the Website and our services. These companies are data processors for the personal data for which we are the data controller. By accepting this Policy, you agree that we may also allow the data for which you are the data controller to be processed by these data processors.
We have data processing agreements in place with the data processors and it follows from these agreements that they must act solely in accordance with our instructions. By accepting this Policy, you authorise us to instruct the data processors to process data in accordance with the Policy and for the purposes of using the Website.
The data processors have taken reasonable technical and organisational measures to protect against the information being accidentally or illegally destroyed, becoming lost or deteriorating, and to protect against the information being disclosed to unauthorised persons, being misused, or in other ways being processed in violation of data protection laws.
On your request – and possibly in return for remuneration at the data processors’ applicable hourly rates at any time for such work – the data processors must supply you with sufficient information to demonstrate that the above-mentioned technical and organisational safety measures have been taken.
Some of these data processors and third party services are located outside of the European Union, such as in the US. You consent to us using data processors in unsecure third countries provided that there is a legal framework governing the transfer of your personal data and ensuring adequate protection of it, for example if the data processor is part of the EU-US Privacy Shield framework.
6. Data retention
We keep the Master Data and other personal data you provide, including your reviews, for as long as you have an Account or as needed to provide you with our services. If you choose to delete your Account please note that all your reviews will also be deleted. We will delete this information upon your request and we will only save a log with the following information:
your name, email address and the date of the deletion of your Account. We will keep the log for 3 years. All other information will be deleted.
If you only use our Website for searching for reviewed companies, we will retain your information and keep your Account open until you decide to close your Account. In some cases, even if you close your account, we then choose to retain certain information (e.g. visits to our Website) in an anonymised or aggregated form.
7. Security measures
We use reasonable organisational, technical and administrative measures to protect your personal data within our organisation and we regularly audit our system for vulnerabilities. However, since the internet is not a 100% secure environment, we cannot ensure or warrant the security of the information you transmit to us. Emails sent via the Website may not be encrypted, and we therefore advise you not to include any confidential information in your emails to us.
To learn more about our current practices and policies regarding security and other information, please see our security practices. We are always working to improve our security practices and we will update this information as these practices evolve over time.
8.1 What types of Cookies do we use?
Cookies are small pieces of information that the Website places on your computer’s hard disk, on your tablet or on your smartphone. Note that HTML5 introduced Web Storage that has a similar nature to Cookies, and that we therefore consider that as a Cookie in the following.
Cookies contain information that the Website uses to make the communication between you and your web browser more efficient. Cookies identify your computer or device rather than you as an individual user.
We use session cookies, persistent cookies, HTML5 sessionStorage and HTML5 localStorage session cookies and HTML5 sessionStorage objects are temporary in nature and are deleted when you exit your web browser. Persistent cookies are permanent in nature and are stored and remain on your computer until they are deleted. Persistent cookies expire or auto delete after a certain period of time, which is set per cookie, but are renewed each time you visit the Website. HTML5 localStorage objects are permanent in nature and remain on your computer until they are deleted.
Measuring Website traffic such as the number of visits to the Website, which domains the visitors come from, which pages they visit on the Website and in which overall geographical areas the visitors are located.
Monitoring Website performance and your use of our Website.
Monitoring the performance of the Website and how you use our Website.
Authentication and improving the functionality of our Website.
Optimising your experience with the Website, which includes remembering your username and password when you return to the Website and remembering information about your browser and preferences (e.g. which language you prefer).
Ensuring the quality of reviews and to prevent misuse or irregularities in connection with writing reviews and using the Website.
8.3 Third party Cookies
Third party Cookies are set by third party websites – not our Website. When you visit our Website, the following third party Cookies may be set:
Google cookies, set when you log in to our Website with Google Google AdSense cookies, set when displaying relevant targeted advertisements on our Website. Some cookies may be set as DoubleClick, which is part of Google Hotjar localStorage, set for managing how and when surveys are displayed. Read more here. 8.4 Deletion of cookies
You can delete the cookies already on your device. You can typically delete cookies from the Privacy or History area, available from the Settings or Options menu in the browser. In most browsers, the same menu can be reached through the Ctrl+Shift+Del keyboard shortcut or Command+Shift+Del if you’re on a Mac.
If you do not accept Cookies from our Website, you may experience inconvenience in your use of the Website, and you may be prevented from accessing some of its features.
9 Access and insights into the personal data we have about you
If you have an Account on Healthcare Delivery Reviews, you can log in to your Account and see what information we have about you, including your reviews, and why we have that information.
If you don’t have an Account, you can email firstname.lastname@example.org and request information about your personal data. Upon receiving your request, we will let you know what personal data we have about you, how we collect the information, the purpose for which we process your personal data, and who we share your personal data with.
10 Correction and deletion of your personal data
f any of the Master Data or other personal data that we have about you in our capacity as a data controller is incorrect or misleading, you can ask us to correct your information by email email@example.com
You may at any time correct or delete any content and personal data on the Website for which you are the data controller (see 3.2). If your personal data changes, or if you no longer wish to appear on the Website, you can email us requesting to delete your account.
If your Account is deleted, all the data associated with your Account will be deleted, including your Master Data and reviews on the Website.
We reserve the right to block access to your Account and/or delete it if the Account or the content associated with your Account or your review(s) on the Website is, in our assessment, discriminating, racist, sexually oriented, unethical, threatening, offensive, harassing or otherwise violates applicable laws, third party rights or our User Guidelines, or is inconsistent with the purpose of the Website. If we block access to or delete your Account, we will inform you of the reason for blocking or deleting your Account by sending an email to the address you provided when you created your Account.
11. Other rights In addition to the rights set out above concerning your personal data, you also have the following rights:
You also have the right to object to the processing of your personal data and have the processing of your personal data restricted. In particular, you have an unconditional right to object to the processing of your personal data for direct marketing purposes. If our processing of your personal data is based on your consent, you have the right to withdraw your consent at any time. Your withdrawal will not affect the lawfulness of the processing of data carried out before you withdrew your consent. You may withdraw your consent by emailing us at firstname.lastname@example.org.
In some circumstances, these rights may be limited or conditional. For example, whether or not you have the right to data portability in a particular case depends on the specific circumstances of the processing activity.
12 Our Data Protection Officer
We have a Data Protection Officer (DPO). If you have any questions about the data processing activities performed by us, you are welcome to contact our DPO by email at: email@example.com
13 Changes to this Policy
We reserve the right to make changes to this Policy. The date shown at the start of this Policy indicates when it was last revised. If we make material changes to it, we will provide notice through our Website, or by other means, to give you the opportunity to review the changes before they come into effect. If you object to our changes, you can close your account. Your continued use of our Website after we publish or send a notice about the changes to the Policy will mean that you accept and agree to the updated Policy.
14 Contact information and where to send questions or complaints
If you have questions or concerns about our Policy, how we process your personal data, or would like us to correct your personal data, feel free to contact us at: firstname.lastname@example.org
You can also reach us by post.
If contacting us does not resolve your complaint, you have further options, for example you may always lodge a complaint with a data protection supervisory authority, e.g. The Danish Data Protection Agency. You can read more about it here.
Our contact details are:
Healthcare Delivery Reviews
8 Tavistock Street
Healthcare Delivery Reviews Registered Company 12890632