How we handle your data.

(1) Who are we?

We are Xen Health Clinics: we are dedicated to advancing medical cannabis treatments to support patients in effectively managing conditions such as chronic pain, anxiety, insomnia, and depression when conventional medications have proven unsuccessful.

Xen Health Clinics Limited is a company incorporated and registered in England and Wales (company number 16379556) with its registered office at Xen Health Clinics, 503 332 Ladbroke Grove, London, W10 5AD (the “Company” or “we” or “us”).

Protecting your data and respecting your privacy is fundamental to our operations. Transparency regarding how we handle any personal data you entrust to us is essential to building that trust. We will consistently comply with applicable data protection legislation and ensure that the collection and use of personal information is conducted in accordance with relevant data protection laws. The primary law governing data protection is the General Data Protection Regulation (Regulation (EU) 2016/679 of 27 April 2016) referred to as the “GDPR”.

This privacy notice explains the basis on which we will process any personal information about you — whether information we collect directly from you or other individuals on your behalf, or information provided to us from other sources. This policy outlines the rules on data protection and the legal conditions that must be met when we obtain, handle, process, transfer or store personal information.

(2) Data protection principles

We are accountable for demonstrating compliance with the GDPR’s six principles of processing personal information. These require that personal information we handle must be:

• processed lawfully, fairly and in a transparent manner;
• collected for specified, explicit and legitimate purposes and not further processed in a manner incompatible with those purposes;
• adequate, relevant and limited to what is necessary;
• accurate and, where necessary, kept up to date;
• not kept for longer than necessary; and
• processed securely, maintaining integrity and confidentiality.

(3) The kind of information we hold about you

In our interactions with you we will collect certain information about you. We may collect either directly or indirectly some or all of the following types of personal information about you:

• Personal details such as name and title
• Contact details such as addresses, telephone numbers and email addresses
• Date of birth
• NHS number
• If you are a doctor, your GMC registration details
• Gender
• Marital status and dependants
• Bank account or debit/credit card details
• Photographs
• Details of transactions you carry out through our website or by other means, the fulfilment of your instructions and any subsequent communications with you regarding any of these
• Details of your visits to our website including, but not limited to, traffic data, location data, weblogs and other communication data, whether required for our own administrative purposes or otherwise, and the resources that you access

We may also collect, store and use the following sensitive personal information:

• Information about your health, including any medical condition, health and sickness records.

(4) How is your personal information collected?

In the course of our business, we may collect personal information directly from you:

• when you provide information in relation to services we might provide to you;
• when you submit an enquiry about our services; and
• when you provide personal information directly to members of our team.

We may also collect personal information about you from other sources such as:

• Doctors and/or other medical professionals who refer you to us.
• Via email, telephone, social media, through our website and in-person interactions, from other health organisations (for example your GP), via the chat function or through cookies on our website and pixels in our emails, and through publicly accessible sources including your employer’s website or your social media profile.

We will only collect personal information to the extent required for the specific purpose notified — and we will retain it only as long as is necessary.

(5) How we will use your personal information

We will only use personal information when the law permits us to do so and relying on a relevant basis for lawful processing in each instance. We will use your personal information in the following circumstances:

• Where we need to perform a contract we are about to enter into or have entered into with you.
• To provide you with information, products or services that you request from us (contact details).
• To fulfil our obligations arising from any contracts entered into between you and us (contact details, medical information, payment information).
• Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
• To ensure that content from our website is presented in the most effective manner for you and your device (online identifiers, location data and other technical information).
• To provide you with information, products or services that we feel may interest you (where you have consented to be contacted for such purposes to the extent consent is required by law).
• Where you are a referring doctor, to contact you and verify any details relating to your practice and/or the patient in question (contact details, GMC registration).
• To allow you to participate in interactive features of our service, when you choose to do so.
• To notify you about changes to our service (contact details).
• To maintain essential information about you and your transaction history, in order to provide you with a service tailored to your preferences.
• Helping us develop, operate, deliver and improve the quality of care we provide or, more generally, the type of services that we offer.
• Where we need to comply with a legal or regulatory obligation.
• To retain basic transaction details for the purpose of tax reporting or updating medical records.
• For safeguarding reasons.
• Where you have consented to the processing.
• To use non-essential cookies on our website (see “Cookies” section below for further information). You have the right to withdraw consent to such use at any time by contacting us, but please note that some or all parts of our website may no longer be accessible to you.
• To send you direct marketing communications via email, text message, post or telephone call. You have the right to withdraw consent to any such use at any time by contacting us. Where you have consented we may also disclose your information to third parties (including our subsidiaries, our ultimate holding company and its subsidiaries) for the purpose of direct marketing.

We may process your personal information for more than one lawful basis depending on the specific purpose for which we are using your data.

We will only use your personal information 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.

Where we need to collect personal information 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 services). If this happens, we may have to cancel, or be unable to provide, any services you have requested.

We may process your personal information without your knowledge or consent where required or permitted by law.

We may collect, use and share aggregated data such as statistical or demographic data for any purpose. Aggregated data may be derived from your personal information but is not considered “personal data” in law as this data does not directly or indirectly reveal your identity.

Automated decision-making occurs when an electronic system uses personal information to make a decision relevant to you without human intervention. We do not envisage that any decisions will be taken about you using automated means; however we will notify you in writing if this position changes.

If you provide us with any personal information relating to relatives, partners or other individuals it is your responsibility to make such persons aware that their personal information may be shared with us and to provide them with appropriate information about how their personal information may be processed by us.

It is important that the personal information we hold about you is accurate and current. Please keep us informed if your personal information changes during your relationship with us.

(6) How we use sensitive personal information

Processing of sensitive personal information requires higher levels of protection. We may process sensitive personal information about you in the following circumstances:

Processing is necessary for the purposes of preventive or occupational medicine, for the assessment of medical diagnosis, the provision of health or social care or treatment pursuant to contract with a health professional and subject to appropriate confidentiality safeguards. Specifically:

• We may process information about your physical or mental health, or disability status, to ensure health and safety and to provide appropriate adjustments you might require to access our services.
• We may process information about your physical or mental health to assess and provide appropriate treatment services.

(7) Data sharing

We may transfer personal information we collect about you to countries within the European Economic Area (“EEA”). There are adequacy regulations in respect of these countries which means that these countries are deemed to provide an adequate level of protection for your personal information.

We may transfer personal information we collect about you to countries outside the EEA, in limited circumstances and where we do we ensure that your personal information is treated by those third parties in a way that is consistent with and respects UK law on data protection by putting in place data protection agreements, technical and organisational measures, standard contractual clauses and/or binding corporate rules as appropriate. If you require further information about this or these protective measures, you can request more information from our Data Protection Officer at hello@xenhealthclinics.co.uk.

We may share personal information we hold with:

• any member of our group, which means our subsidiaries, our ultimate holding company and its subsidiaries;
• in the event that we sell or buy any business or assets, or sell the Company, we will disclose your personal data to the prospective seller or buyer of such business or assets.

We may also disclose personal information we hold to third parties if we are under a duty to disclose or share an individual’s personal information in order to comply with any legal obligation, or in order to enforce or apply any contract with that individual or other agreements, or to protect our rights, property, or safety of our employees, patients or others. This includes exchanging personal information with other companies and organisations for the purposes of fraud protection and credit risk reduction.

We may share personal information with other members in the group as part of our regular reporting activities on company performance. When appropriate, we will anonymise personal information when used for performance reviewing and reporting activities.

We may also share personal information we hold with selected third parties for the purposes set out below. We do not allow our third-party service providers to use your personal data for their own purposes; we only permit them to process your personal data for specified purposes and in accordance with our instructions.

Third-party service providers

Google Analytics. Google Analytics is a web analytics service offered by Google that tracks and reports website traffic. Google uses the data collected to track and monitor the use of our Service. This data is shared with other Google services. You can opt-out of having made your activity on the Service available to Google Analytics by installing the Google Analytics opt-out browser add-on. For more information, please visit the Google Privacy & Terms web page.

Google Ads. Google Ads remarketing service is provided by Google Inc. You can opt-out of Google Analytics for Display Advertising and customise the Google Display Network ads by visiting the Google Ads Settings page.

Twitter / X. Twitter remarketing service is provided by Twitter Inc. You can opt-out from Twitter’s interest-based ads by following their instructions. You can learn more by reading the Twitter Privacy Policy.

Facebook. Facebook remarketing service is provided by Facebook Inc. You can learn more about interest-based advertising from Facebook by visiting their help page. To opt-out from Facebook’s interest-based ads follow these instructions.

Payment processors. We may provide paid products and/or services within the service. In that case, we use third-party services for payment processing. We will not store or collect your payment card details. That information is provided directly to our third-party payment processors, whose use of your personal information is governed by their privacy policy. These payment processors adhere to the standards set by PCI-DSS as managed by the PCI Security Standards Council.

(8) Data security

We will always take appropriate technical and organisational measures to protect personal information against accidental or unlawful destruction or accidental loss, alteration, unauthorised disclosure or access — in particular where the processing involves the transmission of data over a network — and against all other unlawful forms of processing. This includes taking reasonable steps to ensure the reliability of employees who have access to personal information. Our employees may only process personal information in accordance with this privacy notice, and any employee who is in breach may be subject to disciplinary action, up to and including dismissal.

We have put in place internal procedures to deal with any suspected data security breach and will notify you and any applicable regulator of a suspected breach where we are legally required to do so.

(9) Data retention

We will not keep personal information in a form which permits identification of individuals for longer than is necessary for the purpose or purposes for which it was collected. We will take all reasonable steps to destroy, or erase from our systems, all data which is no longer required. To determine the appropriate retention period for personal information, we consider the amount, nature, and sensitivity of the personal information, the potential risk of harm from unauthorised use or disclosure of personal information, the purposes for which we process information and whether we can achieve those purposes through other means, and the applicable legal requirements.

We may sometimes anonymise your personal information (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) Your rights

You have rights under data protection laws in relation to your personal information, as summarised below. You have the right to:

• Request access to your personal information (commonly known as a “data subject access request”). This enables you to receive a copy of the personal information we hold about you.
• Request correction of the personal information 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.
• Prevent processing for the purposes of direct marketing. This enables you to ask us to delete or remove you from any direct marketing activity.
• Object to processing of your personal information where it is likely to cause or is causing damage or distress.
• Request the transfer of your personal information to you or to a third party. To comply with data portability we will provide to you, or a third party you have chosen, your digital personal information in a structured, commonly used, machine-readable format.
• Withdraw consent at any time where we are relying on consent to process your personal information. Any withdrawal of consent 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.

If you wish to exercise any of the rights set out above, please contact us at hello@xenhealthclinics.co.uk or contact our Data Protection Officer as detailed below. We aim 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.

You will not have to pay a fee to access your personal information (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.

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal information (or to exercise any of your other rights). This is a security measure to ensure that personal information is not disclosed to any person who has no right to receive it. We may also contact you to ask for further information in relation to your request to speed up our response.

(11) Cookies

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 website. A cookie is a small file of letters and numbers that we store on your browser or the hard drive of your computer or device if you agree.

We use the following cookies:

• Strictly necessary cookies. These are required for the operation of our website. They include, for example, cookies that enable you to log into secure areas of our website.
• Analytical/performance cookies. They 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 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 any advertising displayed on it more relevant to your interests. We may also share this information with third parties for this purpose.

You can block cookies by activating the setting on your browser that allows you to refuse the setting of all or some cookies. However, if you block cookies you may not be able to access all or parts of our website. See our Cookie Policy for more detail.

(12) Data Protection Officer

Our Data Protection Officer is responsible for how the Company deals with personal information and for ensuring compliance with the GDPR and with this policy. Our Data Protection Officer can be contacted at hello@xenhealthclinics.co.uk. Any questions about the contents or operation of this privacy notice should be referred in the first instance to the Data Protection Officer.

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