Privacy Policy – App

Photo of Medsmart app on smartphone

Dated: 26th of April 2018


Scope of Policy

This Privacy Policy applies to your use of the App and the Service once you have downloaded or streamed a copy of the App onto your mobile device (“Device”).

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


Who we are

“Medsmart” is a brand 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, United Kingdom, 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 or (where you have registered on behalf of a person you care for) a person you care for, when you register for the Service and when you use the Service. The information you give us may include, but is not limited to, your, or a person you care for’s; name, address, e-mail address and phone number, the Device’s phone number, age, username, password, personal description, photograph and other registration information. It will also include information on your, or a person you care for’s, specific medicine routine and the feedback information you provide to us in relation to your, or the person you care for’s, use of the App and Service.


  • Device Information – this is the technical information we automatically collect from your Device when you use the App and the Service including the type of mobile device you use, a unique device identifier (for example, your Device’s IMEI number, the MAC address of the Device’s wireless network interface, or the mobile phone number used by the Device), mobile network information, your mobile operating system, the type of mobile browser you use, and time zone setting.


  • Account Information – this is information on the use of your Account which relates to your use of the Service.


The Medsmart App only captures data at the point of use, simply downloading the App and keeping it in your phone does not constitute usage.



Our App uses cookies to distinguish you from other users of our Service. This helps us to provide you with a good experience when you use the Service and also allows us to improve our App. We do not use cookies to collect any personally identifiable information. The cookies we use are “analytical” cookies (such as Mixpanel Mobile Analytics, Apple Analytics & Google Analytics). You can change your App settings to reject cookies at any time, although this may impair the functionality of our App.


What we do with the information we gather

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

  • To help provide the Service;


  • To send you push notifications with relevant information about the content of the App (you can change your settings to turn off such notifications at any time although this may impair the functionality of the App);


  • 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 App and for internal operations, including troubleshooting, data analysis, testing, statistical and survey purposes;


  • To maintain, protect and improve the App and/or the Service 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 the Service, including (but not limited to) customer service;


  • Optimise your user experience of the Platform and/or the Service;


  • Personalise your experience of the Platform and/or the Service (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 Platform and/or the Service);


  • Improve the Platform and/or the Service (we continually strive to improve the Platform and/or the Service based on the information we receive from you);


  • Administer Platform and/or Service features or respond to your enquiries or requests;


  • Send communication to you regarding the Medsmart Service, such as Terms and Conditions, notification of updates, information which we feel will be of use to you regarding your medicines and medicine-specific projects.


  • 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. Medsmart is designed to provide support throughout a variety of medicine related health changes and works best if used throughout a lifetime. Information associated with your account will be held until your account is deleted and Talking Medicines reserves the right to delete your account if it is inactive for a period of 80 years.


Uninstalling the Medsmart App

You can uninstall Medsmart from your phone at any time by using the native app removal technique on your phone. When uninstalling the app you will not be able to use the functionalities that Medsmart have to offer, for instance, the medicine log, the medicine cabinet and the notifications that come with it. All the medicine information you have inputted will be in the App waiting for you whenever you wish to re-install the App, all you have to do is type the same username and password combination previously used. By uninstalling the App you restrict your ability to use the App but this does not delete your account. Talking Medicines will hold the personal data you provide us with for a period of 80 years and reserves the right to delete any personal data if the account is inactive for 80 years.

If you wish to completely delete your account including all personal data, please follow the steps below.


Deleting your account

You can delete your account any time. When you delete your account, we delete things you have inputted into the Medsmart App such as your medicines information, personal profile data and your reminder notifications. Information kept within sub folders in the Medsmart App will also be deleted. No further information from your account will be used. Talking Medicines unequivocally reserves the right to use the aggregated data stored and gathered before this point as the act of anonymizing and aggregating data de-personalises it. We are unable to retrieve specific details about individuals after completing this process.

To delete your account please contact [email protected] stating you wish to delete your account and our Customer Service team will provide you with the link to this Delete Account Request Form. Please make sure you compete all the fields of the enclosed document and return it to [email protected] to delete your account.

Please find the account deletion form here Delete Account Request Form.

Upon receiving the completed deletion form, we will delete your data within 28 days of your request and will be unable to respond to you past this point. Talking Medicines reserves the right to keep a redacted document of your details to comply with legal regulations and potential legal disputes or proceedings.


Talking Medicines reserves the right to make suitable enquiries to ensure requests are not malicious in nature and are made by the intended user or appointed agent.


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.


In addition, if you use our Service while you are outside the EEA, your information may be transferred outside the EEA in order to provide you with the Service.

By submitting your personal data, you agree to this transfer, storing or processing.

Where you have chosen a password that enables you to access the Service, you are responsible for keeping this password confidential.

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 App 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 App or the Service 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.


Accessing your personal data

If you would like to access all the personal data we hold on you at any time, the General Data Protection Regulation 2018 gives you the right to access information we hold about you.


You can access the personal data we hold on you by sending Us a completed Personal Data Request Form which you can find here Personal Data Request Form. You must complete the form and send it to [email protected], please note that data extractions are done in a PDF format.


Talking Medicines reserves the right to make suitable enquiries to ensure requests are not malicious in nature and are made by the intended user or appointed agent.



We take data very seriously and take all steps reasonably to take care of your data. We hope that you never want to object to how we handle your data, if you have any questions or requests regarding how we handle your data you can get in contact with our Data Protection Officer by e-mail to [email protected].  If you wish to take your objection further, you can contact the Information Commissioner’s Office in Edinburgh at the following address:

The Information Commissioner’s Office – Scotland
45 Melville Street

Telephone: 0303 123 1115

Email: [email protected]

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