Dated: 11/03/19


Scope of Policy

This Privacy Policy applies to your participation in an online survey provided by Talking Medicines Limited on behalf of a third party (‘the Client’).

This policy sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us.

For the surveys we use third party services to create the questions and gather the survey data responses. Digital marketing platforms, such as mailchimp are used for engagement and videos from Vimeo are embedded in to the Typeform surveys to enable us to gain feedback on educational content.

Medsmart® Community service includes the use of all Medsmart® products (includes the App, Notifications, Website, Surveys, Newsletters, Social channels etc.).

For the purpose of the General Data Protection Regulation 2018, we, Talking Medicines, are the data controller.

We may need to change these Terms from time to time and reserve the right to do so. Any material changes to these Terms will be posted on our website.



Who we are

“Medsmart” is a brand product name used by Talking Medicines Limited, a limited liability company registered in Scotland with company number SC447227, whose registered office is at Top Floor, 25 Blythswood Square, Glasgow, G2 4BL (referred to in these Terms as “Talking Medicines”, “we” or “us”).


What personal information do we collect from you?

We may collect and process the following data about you:

  • Submitted Information – this is information you give us about yourself either prior to taking part in the survey, qualifying information which validates if you are eligible to take part, and / or information you may give us during the course of the survey. By providing your email address you are consenting to becoming a member of our Medsmart® Community service.
  • By consenting to take part in the survey, you are explicitly consenting to the combination of any data that you provide, with any Medsmart® data that we hold on you and that you have provided in the Survey. We will use this information in order to provide you with a better service and for our legitimate commercial purposes.



Our Survey uses cookies to distinguish you from other survey participants and users of our Medsmart® Community service.

This helps us to ensure that your data is handled appropriately within the survey, and also to provide you with a good experience when you use the Medsmart® Community service. We do not use cookies to collect any personally identifiable information. The cookies we use are “analytical” cookies (such as Mixpanel Mobile Analytics, Firebase, Apple Analytics & Google Analytics). You can change your device settings to reject cookies at any time, although this may impair your ability to take part in the survey.


What we do with the information we gather

We use any information held about you in the following ways:

  • To perform statistical analysis on anonymised survey data to identify patterns of behaviour, feedback on educational content and survey experience to improve our surveys.
  • To perform statistical analysis on anonymised data to identify patterns of medicine use behaviour (all anonymised data is owned by Talking Medicines and may be licensed to third parties commercially); and
  • To administer our surveys and for internal operations, including troubleshooting, data analysis, testing, statistical and survey purposes;
  • To maintain, protect and improve the surveys and to notify you about changes to either.
  • Offline communications between you and the Company to better engage with you as a user and provide a better experience
  • Provide appropriate customer service;
  • Validate and optimise your user experience;
  • Personalise your experience of the survey (for example, your information helps us to better respond to your individual needs, e.g., we may use your information to serve you more tailored and relevant content based on your interests or usage of the Medsmart® Community service);
  • Improve the Medsmart® Community service (we continually strive to improve the Medsmart® Community service based on the information we receive from you);
  • Send communication to you regarding the Medsmart® surveys, such as Terms and Conditions and other relevant surveys.
  • To comply with all regulatory obligations and legal requirements under GDPR and other statutory provisions.


Storing your information

We store data for a period of 80 years as it is necessary to provide services to you and others for the duration of your lifetime. Talking Medicines are committed to provide support throughout a variety of medicine related health changes over a person’s lifetime. Information associated with your email address will be held until deleted by Talking Medicines.


Disclosure of your information

We may disclose your personal data held by us to any member of our group, which means our subsidiaries, our ultimate holding company and its subsidiaries, as defined in section 1159 of the Companies Act 2006.

We may disclose your personal information to third parties:

  • in the event that we sell or buy any business or assets, in which case we may hand over your personal data to the prospective seller or buyer of such business or assets;
  • if Talking Medicines or substantially all of its assets are acquired by a third party, in which case personal data held by it about its customers will be one of the transferred assets;
  • if we are under a duty to disclose or share your personal data in order to comply with any legal or regulatory obligation or request;
  • in order to enforce or apply our Terms and/or other agreements or to investigate potential breaches; and in order to protect the rights, property or safety of Talking Medicines, our customers, or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction.



Where we store your personal data

The data that we collect from you may be transferred to, and stored at, a destination outside of the European Economic Area (“EEA”). It may also be processed by staff operating outside the EEA who work for us or for one of our suppliers. This may happen if any of our servers are from time to time located in a country outside the EEA, or if one of our service providers is located in a country outside the EEA. We may also need to share information between companies within our group which are located in other countries. If we transfer your information outside of the EEA, we will take steps to ensure that your rights continue to be protected.

By consenting, you agree to this transfer, storing or processing.

All information you provide us is stored on our secure servers. We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this Privacy Policy.


Your rights

Our surveys may, from time to time, contain links to and from the websites of our partner networks, advertisers and affiliates (including, but not limited to, websites on which the surveys are advertised). If you follow a link to any of these websites, please note that these websites and any services that may be accessible through them have their own privacy policies and that we do not accept any responsibility or liability for these policies or for any personal data that may be collected through these websites or services, such as contact and location data. Please check these policies before you submit any personal data to these websites or use these services.

If you would like a copy of the personal information that we store about you in our customer databases, the General Data Protection Regulation 2018 gives you the right to access information we hold about you. please contact us using the details given in the “Contact” below.

This is in addition to your legal rights, including the right to access a copy of your personal information, the right to request the deletion or updating of any inaccurate personal data and the right to object, in some cases, to our processing of your personal data. You can exercise these rights by contacting us using the details given in the “Contact” section of our Medsmart® website (www.gomedsmart.com).

Where we base processing on your consent, you have the right to withdraw consent at any time, without affecting the lawfulness of processing based on consent before its withdrawal.

You may also have, for some data processed by us, a right to data portability, i.e. the right to receive your personal information in a structured, commonly used machine-readable format and transmit your personal information to another data controller.

You can exercise these rights by contacting us using the details given in the “Contact” section. You may be asked to provide some proof of identification so that we can verify that it is you making the request.

If you are concerned that we have not complied with your legal rights or applicable privacy laws, you may contact the Information Commissioner’s Office (www.ico.gov.uk) (which is the regulator responsible for data protection in the United Kingdom, where Talking Medicines is located) or requests regarding how we handle your data you can get in contact with our Data Protection Officer by e-mail to [email protected]

Alternatively, if you are located outside of the United Kingdom, you may contact your local data protection authority.


Children’s Privacy

Talking Medicines considers a child to be anyone under the age of 16. We do not knowingly seek or collect personal information from or about children without the consent of a parent or guardian.

If Talking Medicines becomes aware that personal information that has been submitted to us relates to a child without the consent of a parent or guardian, Talking Medicines will use reasonable efforts to:

  • Delete that personal information from its files as soon as possible
  • Ensure, where deletion is not possible, that this personal information is not used further for any purpose, nor disclosed further to any third party
  • Any parent or guardian with queries regarding our processing of personal information relating to their child should contact us using the details provided in the “Contact” section section of our Medsmart® website (www.gomedsmart.com)