Last Revised July 2023
We at Polar Speed Distribution Limited (“us”, “we” or “our”), respect your concerns about privacy. Our address is 8 Chartmoor Road, Leighton Buzzard, Bedfordshire, LU7 4WG.
This Privacy Notice explains how we use any personal information we collect about you and your rights in relation to the information. “Personal information” means information that identifies you as an individual or is capable of identifying you as an individual.
Information We Obtain
We may collect personal information about you to enable us to provide our Distribution and Homecare Services to you. This personal information may include your name, email address, physical address, date of birth, telephone number, and certain health information.
We may collect this personal information:
- from you directly, such as when you fill in forms to register for our services, fill in forms provided by our delivery drivers, or communicate with us by telephone or in writing.
- from other sources, such as the hospital, community mental health team, care home, or healthcare professionals which may be involved in your care, or the company responsible for manufacturing the drugs being delivered to you.
- where relevant, from any nurses and phlebotomists who visit you to provide certain Homecare Services.
- technical information, including your IP address, browser type and version, device identifier, location and time zone setting, browser plug-in types and versions, operating system and platform, page response times, and download errors.
- information about your visit, including the websites you visit before and after our website and products you viewed or searched for.
- length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs) and methods used to browse away from the page.
How We Use the Information We Obtain
If you receive our Distribution Services, we use your personal information to provide these services to you, including:
- delivering your packages.
- creating and managing your delivery records.
- providing customer support.
- maintaining records and audit trails for the services we provide.
If you receive our Homecare Services, we use your personal information to provide these services to you, including:
- dispensing and delivering your medication.
- creating and managing your prescription and delivery records.
- facilitating a nurse or healthcare professional to visit you, where relevant.
- communicating with the hospital, community mental health team, care home, or healthcare professionals who may be involved in your care.
- providing customer support.
- recording and managing (where appropriate) any adverse events or side effects relating to your medication which you tell us about.
- maintaining records and audit trails for the services we provide.
We may use the personal information that we collect via our cookie and devices to:
- administer our website and customise your visits to our website.
- diagnose technical and service problems.
- analyse user traffic and usage patterns.
The legal bases for which we collect, use, transfer or disclose your personal information as part of our services include:
- performance of a task carried out in the public interest (this may apply where we are providing pharmaceutical services under contract with the NHS).
- our legitimate interests in providing services which have been commissioned by our customers or by the NHS.
- compliance with our legal obligations.
Where we process special categories of personal information, such as your health data, we will require an additional legal basis for processing. These additional legal bases include:
- the provision of health care or treatment.
- public interest in the area of public health.
If you experience an adverse event or side effect, we may pass on certain relevant personal information to the pharmaceutical company responsible for that medication. However, we will only do this if you consent to this.
- our legitimate interests of providing and improving our services, analysing our website user traffic so that we can improve our website and meet the needs of visitors to our website, to provide your with access to our website, and to monitor how our website is used to detect and prevent fraud, other crimes and the misuse of our website.
- compliance with a legal obligation, such as our obligation to ensure the security of our information systems.
The security of your data is extremely important to us. Access to your personal information is only provided to our staff and certain third parties, including:
- our service providers who help us to provide our services to you, such as delivery companies in our distribution network.
- our infrastructure and IT service providers.
- our regulators, or organisations to whom we are required to disclose your personal information by law.
- third parties connected with business transfers, such as in connection with a reorganisation, restructuring, merger, acquisition or transfer of assets, provided that the receiving party agrees to treat your personal information in a manner consistent with this Privacy Notice.
- if you receive our Homecare Services:
- the hospital, community mental health team, care home, or healthcare professionals which may be involved in your care.
- pharmaceutical companies in connection with adverse events or side effects, but only where you consent to this.
Your personal information will only be stored for as long as necessary for the purposes for which they were collected and only to the extent permitted by applicable laws. When we no longer need to use your information, we will remove it from our systems and records and / or take steps to promptly anonymise it so that you can no longer be identified from it (unless we need to keep your information to comply with legal or regulatory obligations to which we are subject).
International Data Transfers
The personal information that we collect from you may be transferred to, and stored at, a destination outside the European Economic Area (“EEA”). It may also be processed by staff operating outside the EEA and who work for us or for one of our service providers.
We will take all steps reasonably necessary to ensure that your personal information is treated securely and in accordance with this Privacy Notice and applicable data protection laws, including, where relevant, entering into EU standard contractual clauses (or equivalent measures) with the party outside the EEA receiving the personal information.
How We Protect Personal Information
We maintain administrative, technical and physical safeguards designed to protect the personal information you provide. Although we take steps to limit access to our facilities and vehicles to authorised individuals, information that is located on the outside of a package or letter may be visible to others.
Your Personal Information Rights
You have various rights in connection with our processing of your personal information:
- Access. You have the right to request a copy of the personal information we are processing about you, which we will provide back to you in electronic form.
- Rectification. You have the right to have incomplete or inaccurate personal information that we process about you rectified.
- Deletion. You have the right to request that we delete personal information that we process about you, except we are not obligated to do so if we need to retain such data in order to comply with a legal obligation or to establish, exercise or defend legal claims.
- Restriction. You have the right to restrict our processing of your personal information where you believe such data to be inaccurate, our processing is unlawful or that we no longer need to process such data for a particular purpose, but where we are not able to delete the data due to a legal or other obligation or because you do not wish for us to delete it. In such case, we would mark stored personal information with the aim of limiting particular processing for particular purposes in accordance with your request, or otherwise restrict its processing.
- Objection. Where the legal justification for our processing of your personal information is our legitimate interest, you have the right to object to such processing on grounds relating to your particular situation. We will abide by your request unless we have compelling legitimate grounds for the processing which override your interests and rights, or if we need to continue to process the data for the establishment, exercise or defence of a legal claim.
- Withdrawing Consent. Where we process certain personal information on the basis of your consent, you have the right to withdraw your consent.
In some situations, we may refuse to act or may impose limitations on your rights, as permitted by law. Before we can provide you with any information or correct any inaccuracies, we may ask you to verify your identity and/or provide other details to help us respond to your request. For the exercise of your rights, please contact us using the contact information provided below in the “How to Contact Us” section.
In all cases, you have a right to file a complaint with the local data protection authority if you believe that we have not complied with applicable data protection laws. If you are based in the UK, the Information Commissioner’s Office can be contacted as follows:
How to Contact Us
If you have any questions or comments about this Privacy Notice, please contact our Data Protection Officer (“DPO”), HewardMills Limited.
Our DPO can be contacted directly via email: email@example.com.
You may also write to our DPO at:
15 Old Bailey