Certain User Data we may collect is treated as a special category to which additional protections apply under data protection law including:

• data concerning health;

• data concerning sex life;

• genetic data

Where we process such special category User Data, we will ensure we are permitted to do so under data protection laws.

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User Data: User Data-Marketing

We may use your User Data to send you updates (by email, text message, telephone or post) about our product and/or services, including exclusive offers, promotions or new products and/or services.

We have a legitimate interest in using your User Data for marketing purposes.

You have the right to opt out of receiving marketing communications at any time by:

• contacting us ;support@optifema.com

• using the ‘unsubscribe’ link in any emails we send you

• updating your marketing preferences.

We may ask you to confirm or update your marketing preferences if you ask us to provide further products and/or services in the future, or if there are changes in the law, regulation, or the structure of our business.

We will always treat your User Data with the utmost respect and never sell or share it with other organisations outside Optifema for marketing purposes.

Consolidating User Data:

Optifema may consolidate the User Data of customers who use Optifema Web Sites. In addition, we may consolidate information in a non-identifiable form (aggregate/anonymous data) to help us better design Optifema Web Sites and Optifema products, to enhance our research activities, and to facilitate other business functions. This may result in commercialisation of aggregate data. For the avoidance of doubt, you are not entitled to any compensation in such circumstances. The aggregate data shall be used solely on a statistical basis for the purposes of improving public health.

Your user rights and options:

You may always limit the amount and type of User Data that Optifema receives about you by choosing not to enter any User Data into forms or data fields on Optifema Web Sites. Some of our online services can only be provided to you if you provide us with appropriate User Data. Other parts of Optifema Web Sites may ask whether you wish to opt into our contact lists for offers, promotions and additional services that may be of interest to you.

You may also be provided with preference questions or preference boxes allowing you to indicate that you do not want Optifema Web Sites to use tracking technologies, such as cookies, to “remember” your User Data, such as user IDs or mailing addresses (If such tracking technologies are in use at the time of visiting the website), on return visits. However, Optifema Web Sites that use tracking technologies to collect unidentifiable information do not generally provide you with the ability to opt out of the tracking technologies. Some Internet browsers allow you to limit or disable the use of tracking technologies that collect unidentifiable information.

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How your Data may be accessed:

User Data can be accessed by a restricted number of Optifema employees, by certain companies with which Optifema may conduct joint programs, and by third parties with whom Optifema contracts to carry out business activities for Optifema. We train our employees about the importance of privacy and how to handle and manage customer data appropriately and securely. Also, it is Optifema’s practice to seek your consent where required by applicable law if you are registering for a program which is conducted in conjunction with another company that may require access to your User Data. In addition, Optifema’s practice is to require its contractors to keep your User Data confidential and to use your User Data only to perform functions for Optifema.

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We routinely share User Data with:

• third parties we use to help deliver our products and/or services to you, e.g. payment service providers, Laboratories & Testing Facilities.

• other third parties we use to help us run our business, e.g. marketing agencies or website hosts, website analytics providers, Client Management software companies and Accountancy Software companies;

• our banks;

• to the buyer subject to your consent in the event Optifema sells one of its product lines or divisions, when required by applicable law so that the buyer can continue to provide you with information and services.
  Except as otherwise stated in this Section, Optifema will not transfer your personal information to third parties unless you have been provided with an opportunity to opt into this disclosure. Optifema may disclose your personal information without your opt-in to third party service providers which assist us with our business activities with specific regard to our contracted service. It is Optifema’s practice to require such third-party service providers to keep your personal information confidential and to use your personal information only to perform functions for Optifema and in accordance with Optifema’s instructions. Optifema further reserves the right to disclose your personal information to respond to authorised information requests from government authorities or when otherwise required by law.

• Research Partners on a de-identified Aggregated Data basis, solely for the purpose of improving and creating diagnostic products with a view to improving public health.

• Regulatory bodies, on a de-identified Aggregated Data basis, solely for the purpose of improving and creating diagnostic products with a view to improving public health.

We do our upmost to only allow those organisations to handle your User Data if we are satisfied, they take appropriate measures to protect your User Data.

We or the third parties mentioned above may occasionally also share User Data with:

• our and their external auditors, e.g. in relation to the audit of our or their accounts, in which case the recipient of the information will be bound by confidentiality obligations;

• Our and their professional advisors (such as lawyers and other advisors), in which case the recipient of the information will be bound by confidentiality obligations;

• Law enforcement agencies, courts, tribunals and regulatory bodies to comply with our legal and regulatory obligations;

• Other parties that have or may acquire control or ownership of our business (and our or their professional advisers) in connection with a significant corporate transaction or restructuring, including a merger, acquisition, asset sale, initial public offering or in the event of our insolvency—usually, information will be anonymised, but this may not always be possible. The recipient of any of your User Data will be bound by confidentiality obligations.

How does Optifema secure User Data?

• We seek to limit access to your User Data to those who have a genuine need to access it. We also have procedures in place to deal with any suspected data security breach where we are legally required to do so.

• It is Optifema’s practice to secure Optifema Web Sites that collects User Data; however, the confidentiality of User Data transmitted over the Internet cannot be guaranteed. We urge you to exercise caution when transmitting User Data over the Internet. Optifema cannot guarantee that unauthorised third parties will not gain access to your User Data; therefore, when submitting User Data to Optifema Web Sites, you must weigh both the benefits and the risks. In addition, Optifema Web Sites covered by this Privacy Policy we may have backlinks that take you to other third-party Web sites that are not controlled by Optifema; you should check the privacy policies of such third-party web sites before submitting User Data. If you require more information on this, it can be obtained from,Get Safe Onlinewhere you will find information on how to protect your User Data and other information, and how to protect your computers and devices against fraud, identity theft, viruses and many other online problems, pleasevisitwww.getsafeonline.org.Get safe online is supported by HM Government and leading businesses.

Transferring your User Data out of the country of origin, or where it was originally provided.

The EEA, UK and other countries outside the EEA and the UK have differing data protection laws, some of which may provide lower levels of protection of privacy.

It may be sometimes necessary for us to transfer your User Data to countries outside of where it was provided. In those cases, we will comply with applicable data protection legislation designed to ensure the privacy of User Data.

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Under data protection laws, we can only transfer your User Data to a country outside of where it was originally provided:

• If the subject government of country of origin has decided the particular country ensures an adequate level of protection of User Data (known as an ‘adequacy regulation’) further to Article 45 of the UK GDPR

• in the case of transfers subject to EEA data protection laws, the European Commission has decided that the particular country ensures an adequate level of protection of User Data (known as an ‘adequacy decision’) further to Article 45 of the EU GDPR;

• There are appropriate safeguards in place, together with enforceable rights and effective legal remedies for you, or;

• a specific exception applies under relevant data protection law.

• You have consented to the transfer, and that country is considered to satisfy the appropriate requirements.

• Sufficient contractual provision is in place to ensure compliance with Schemes and associated Standard Contractual Clauses

Where we transfer your User Data outside the country of origin, we do so based on an adequacy regulation e.g. legally approved standard data protection clauses recognised or issued further to Article 46(2) of the UK GDPR. In the event we cannot or choose not to continue to rely on this mechanism at any time we will not transfer your User Data outside the Country of origin unless we can do so based on an alternative mechanism or exception provided by UK data protection law and reflected in an update to this policy.

Where we transfer your User Data outside the EEA, we do so on the basis of an adequacy decision e.g. legally approved standard data protection clauses issued further to Article 46(2) of the EU GDPR. In the event we cannot or choose not to continue to rely on this mechanism at any time we will not transfer your User Data outside the EEA unless we can do so based on an alternative mechanism or exception provided by applicable data protection law and reflected in an update to this policy.

Any changes to the destinations to which we send User Data or in the transfer mechanisms we rely on to transfer User Data internationally will be notified to you in accordance with the section on ‘How will I know whether Optifema has updated its privacy policy’ below.

The following types of cookies may be used when you visit this site:

Advertising Cookies

Advertising cookies are placed on your computer by advertisers and ad servers to display advertisements that are most likely to be of interest to you. These cookies allow advertisers and ad servers to gather information about your visits to the Site and other websites, alternate the ads sent to a specific computer, and track how often an ad has been viewed and by whom. These cookies are linked to a computer and do not gather any User Data about you.

Analytics Cookies

Analytics cookies monitor how users reached the Site, and how they interact with and move around once on the Site. These cookies let us know what features on the Site are working the best and what features on the Site can be improved.

Our Cookies

Our cookies are “first-party cookies” and can be either permanent or temporary. These are necessary cookies, without which the Site will not work properly or be able to provide certain features and functionalities. Some of these may be manually disabled in your browser but may affect the functionality of the Site.

Personalisation Cookies

Personalisation cookies are used to recognize repeat visitors to the Site. We use these cookies to record your browsing history, the pages you have visited, and your settings and preferences each time you visit the Site.

Site Management Cookies

Site management cookies are used to maintain your identity or session on the Site so that you are not logged off unexpectedly, and any information you enter is retained from page to page. These cookies cannot be turned off individually, but you can disable all cookies in your browser.

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Third-Party Cookies

Third-party cookies may be place on your computer when you visit the Site by companies that run certain services we offer. These cookies allow the third parties to gather and track certain information about you. These cookies can be manually disabled in your browser.

Performance and Functionality Cookies

These cookies are used to enhance the performance and functionality of our websites but are non-essential to their use. However, without these cookies, certain functionality (like videos) may become unavailable.

Analytics and customisation cookies

These cookies collect information that is used either in aggregate form to help us understand how our websites are being used or how effective our marketing campaigns are, or to help us customise our websites for you.

Media cookies

These are cookies that have not yet been categorized. We are in the process of classifying these cookies with the help of their providers.

What control do I have over cookies?

Most browsers are set to accept cookies by default. However, you can remove or reject cookies in your browser’s settings. Please be aware that such action could affect the availability and functionality of the Site. For more information on how to control cookies, check your browser or device’s settings for how you can control or reject cookies.

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What other tracking technologies are there?

In addition to cookies, we may use web beacons, pixel tags, and other tracking technologies on the Site to help customise the Site and improve your experience. A “web beacon” or “pixel tag” is tiny object or image embedded in a web page or email. They are used to track the number of users who have visited pages and viewed emails and acquire other statistical data. They collect only a limited set of data, such as a cookie number, time and date of page or email view, and a description of the page or email on which they reside. Web beacons and pixel tags cannot be declined. However, you can limit their use by controlling the cookies that interact with them.

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What are your rights?

Optifema is subject to global data protection laws. Generally, GDPR is considered to be a gold standard of Data Protection. Under GDPR, you generally have the following rights, which you can usually exercise free of charge:

• the right to be informed of the type of PII held relating to you, and how it is processed;

• the right to require us to correct any mistakes in your User Data (Correction);

• the right to require us to delete your User Data—in certain situations (Erasure);

• the right to require us to restrict use of your User Data in certain circumstances e.g. if you contest the accuracy of the data (Restriction of use);

• the right to receive the User Data you provided to us, in a structured, commonly used and machine-readable format and/or transmit that data to a third party—in certain situations (Data portability);

• the right to object at any time to your User Data being used for direct marketing (including profiling) or in certain other situations to our continued use of your User Data, e.g. where we use your User Data for our legitimate interests unless there are compelling legitimate grounds for the processing to continue or the processing is required for the establishment, exercise or defence of legal claims (To object to use);

• if you have provided us with a consent to use your User Data you have a right to withdraw that consent easily at any time. Withdrawing a consent will not affect the lawfulness of our use of your User Data in reliance on that consent before it was withdrawn (The right to withdraw consents).

How do I contact and/or make complaints?

With your support Optifema will keep User Data accurate and up-to-date. You may request to remove, amend or correct your User Data. Please notify us of your wishes to do so, using the following steps:

Please contactsupport@optifema.com(or send any post;

Optifema Private Medical Limited, 169a Upper Newtownards Road, Belfast, Northern Ireland BT4 3HZ for the attention of the Data Protection Officer) in for the first instance, if you wish to:

• withdraw your consent;

• ask any questions about this privacy policy or the information that we hold about you; see your User Data or to exercise any of the rights mentioned previously;

• make a complaint about how we have handled your User Data.

We will do our best to respond to all requests in a timely manner.If you are not satisfied with our response to any query you raise with us, or you believe we are processing your User Data in a way which is inconsistent with the law, you can complain to the ICO office helpline: 0303 123 1113

How long will Optifema store User Data?

In general, Optifema will only store your User Data for as long as it is needed to fulfil the purposes for which it was collected, subject to applicable data retention periods imposed upon Optifema by applicable law.Optifema will not use your Personally Identifiable Information for anything other than that which you have consented to. We may use what is known as aggregated data, which has been de-identified for statistical analysis purposes, and such statistics may result in commercialisation. You are not entitled to any recompense in such circumstances, but rest assured, any such anonymised statistical use, shall be for the sole purpose of improving public health.

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How will I know whether Optifema has updated its privacy policy?

If Optifema changes its privacy practices, an updated version of this Privacy Policy will reflect those changes and we will notify you of such changes by updating the effective date at the top of this Privacy Policy. Without prejudice to your rights under applicable law, Optifema reserves the right to amend this Privacy Policy from time to time to reflect technological advancements, legal and regulatory changes and good business practices. Optifema may email you with notification of any material changes.