Privacy Policy
Introduction
Welcome to the Pathway Software (UK) Limited’s (the Company) privacy policy.
The Company is committed to protecting and respecting the privacy of all our customers,
partners and the end users of our Services and Software.
This privacy policy will inform you as to how we look after your Personal Data and tells you
about your privacy rights and how the law protects you.
Important information and who we are
Purpose of this privacy policy
This policy together with:
●our Terms of Service applicable to your use of the Services where you are our
Customer (our Terms of Service); and
●our Acceptable Use Policy applicable to your use of the Software (our Acceptable
Use Policy)
- and any other documents referred to in the Terms of Service and/or the Acceptable Use
Policy sets out the basis on which any Personal Data the Company collects from you, or that
you provide to the Company, whether through this Site or when you use our Services and/or
Software will be processed by us.
The Site is not intended for children and we do not knowingly collect data relating to
children.
It is important that you read this privacy policy together with any other privacy policy or fair
processing policy we may provide on specific occasions when we are collecting or
processing Personal Data about you so that you are fully aware of how and why we are
using your data. This privacy policy supplements other notices and privacy policies and is
not intended to override them.
Changes to the privacy policy and your duty to inform us of changes
We keep our privacy policy under regular review. We may change this policy from time to
time to take account of:
●changes to Data Protection Legislationand other laws which may affect this policy;
●guidance issued by the ICO and others;
●issues raised by our Customers, partners and end users
Accordingly we suggest that you regularly check this page to ensure that you continue to be
comfortable with the measures that we are taking to protect your privacy. This policy was last
updated on 29 January 2021.
It is important that the Personal Data we hold about you is accurate and current. Please
keep us informed if your personal data changes during your relationship with us.
Definitions
In this policy the following words have the following meanings:
Customer includes the following (a) customers who have entered into a contract with us for
the supply of the Services and WriteUpp (b) customers who have subscribed for a trial of our
Services and WriteUpp, in both cases in accordance with our Terms of Service.
Controller, Processor, Data Subject, Personal Data, Personal Data Breach, processing
and appropriate technical and organisational measures: as defined in the Data
Protection Legislation.
Data Protection Legislation: the UK Data Protection Legislation and any other European
Union legislation relating to Personal Data and all other legislation and regulatory
requirements in force from time to time which apply to a party relating to the use of Personal
Data (including, without limitation, the privacy of electronic communications)..
UK Data Protection Legislation: all applicable data protection and privacy legislation in
force from time to time in the UK including the General Data Protection Regulation ((EU)
2016/679) (UK GDPR); the Data Protection Act 2018; the Privacy and Electronic
Communications Directive 2002/58/EC (as updated by Directive 2009/136/EC) and the
Privacy and Electronic Communications Regulations 2003 (SI 2003/2426) as amended.
Patients means the Customer’s patients.
Patients Data means Personal Data of Patients, including clinical notes and assessments.
Personal Data means any information relating to an identified natural person that is
processed by the Company as a result of, or in connection with the provision of the Services;
an identifiable natural person is one who can be identified, directly or indirectly, in particular
by reference to an identifier such as a name, identification number, location data, an online
identifier or to one or more factors specific to the physical, physiological, genetic, mental,
economic, cultural or social identity of that natural person.
ICO means the Information Commissioner’s Office and any successor to it as data
protection authority.
Us, Our, We or Company means Pathway Software (UK) Limited and our Staff.
You, Your, or Customer means your organisation and its Staff.
Software, Services or WriteUpp means the software and associated services provided and
developed by the Company which may be supplied to you.
Standard Contractual Clauses (SCC) the European Commission’s Standard Contractual
Clauses for the transfer of Personal Data from the European Union to processors
established in third countries (controller-to-processor transfers) as set out in the Annex to
Commission Decision 2010/87/EU.
Staff means your and our employees, workers, agents and sub-contractors.
Site means the Company’s website at https://www.writeupp.com.
The Company – as Data Controller
Where you are a Customer of the Company, we will be the Data Controller in respect of
certain Personal Data which you and your Staff may supply to us or which we collect from
you which relates to you and your Staff (Customer Data).
Pathway Software (UK) Limited of Watergate House, 85 Watergate Street, England, CH1
2LF (registered in England and Wales with company number 06844098) is the Controller in
respect of Customer Data.
As Data Controller, we determine the purposes for which and the manner in which Customer
Data is, or is to be, processed. In this policy we describe the types of processing we may
undertake with respect to Customer Data.
The Customer– as Data Controller, the Company as Data Processor
Where you or your Staff are responsible for the input of Patient Data which may be
collected, stored and processed as a result of your use of the Services and WriteUpp, you
will be the Data Controller. The Company will be a Data Processor only.
In cases where you are collecting, storing and processing Patient Data you will determine
the purposes for which and the manner in which that Personal Data is, or is to be processed.
You will also be responsible for:
●informing your Staff and Patients of your own privacy policy and practices, including
the lawful grounds upon which you are processing any Personal Data;
●compliance with Data Protection Legislation including all data protection and privacy
laws relevant to the territory in which you operate and/or which are applicable to your
Patients;
●drawing the Patient’s attention to this privacy policy;
●informing us if any Patient objects to either your or our processing.
Patient Data is to be distinguished from Customer Data which the Company has collected
from you (our Customer). For example, you may have agreed to our collection, use, transfer
and storage of Customer Data (including data of your Staff) for the Company’s own business
purposes including credit checks, administration of contractual arrangements, sales and
marketing.
Conditions for Processing
The Customer will ensure that it has all necessary appropriate consents and notices in place
to enable lawful transfer of the Patient Data to the Company and/or lawful collection of the
Patient Data by the Company on behalf of the Customer for the duration and purposes of the
Services. The Customer acknowledges that for the purposes of the Data Protection
Legislation, the Customer is the Controller and that the Company is the Data Processor. The
Company shall, in relation to any Patient Data processed in connection with the performance
by the Company of the Services:
●process that Patient Data only on your written instructions;
●ensure that it has in place appropriate technical and organisational measures, to
protect against unauthorised or unlawful processing of Patient Data and against
accidental loss or destruction of, or damage to, Patient Data, as are appropriate;
●ensure that all the Company’s Staff who have access to and/or process Patient Data
are obliged to keep the Patient Data confidential;
●not transfer or otherwise process Patient Data outside of the European Economic
Area (EEA) without obtaining the Customer’s prior written consent. Where such
consent is granted, the Company may only process, or permit the processing, of
Patient Data outside the EEA under the following conditions:
othe Company is processing Patient Data in a territory which is subject to a
current finding by the European Commission under the Data Protection
Legislation that the territory provides adequate protection for the privacy
rights of individuals; or
othe Company participates in a valid cross-border transfer mechanism under
the Data Protection Legislation, so that the Company (and, where
appropriate, the Customer) can ensure that appropriate safeguards are in
place to ensure an adequate level of protection with respect to the privacy
rights of individuals as required by Article 46 of the General data Protection
Regulation ((EU) 2016/679); or
othe transfer otherwise complies with the Data Protection Legislation
(collectively “Appropriate Safeguards”)
●assist the Customer, at the Customer's cost, in responding to any request from a
Data Subject and in ensuring compliance with its obligations under the Data
Protection Legislation with respect to security, breach notifications, impact
assessments and consultations with supervisory authorities or regulators;
●notify the Customer without undue delay on becoming aware of a Personal Data
Breach;
●within 45 days of the date of termination or cancellation of your Contract delete
Patient’s Data and copies thereof unless required by Data Protection Legislation to
store the Personal Data; and
●maintain complete and accurate records and information to demonstrate its
compliance with these obligations.
The Customer authorises the Company to transfer the Patient Data outside the EEA
provided all transfers by the Company of the Patient Data shall be (to the extent required
under Data Protection Legislation) effected by way of Appropriate Safeguards.
The Company (and any sub-processors) may only transfer the Patient Data to (or process
Patient Data) in the following countries: United Kingdom, United States of America, Republic
of Ireland and the Netherlands
If any Patient Data transfer between the Customer and the Company requires execution of
Standard Contractual Clauses in order to comply with Data Protection Legislation (where the
Customer is the entity exporting Patient Data to the Company outside the EEA), the
following shall apply in order to provide an appropriate safeguard:
●the parties shall enter the Standard Contractual Clauses agreement;
●the agreement referred to above will be effective upon it being signed by both
parties; and
●a copy of the executed agreement shall be delivered to each of the parties.
You acknowledge that the Company uses various third-party suppliers to provide
functionality within WriteUpp for the Customer’s optional use to deliver and send text and
email messages. The Customer accepts that such use will be in accordance with the third-
party suppliers’ terms and conditions and their respective privacy policies. The Customer will
ensure that it has Patients consent or other authority to share Patients Data via these
communications.
Where the Company engages another Data Processor for carrying our processing activities
on behalf of the Customer, the same data protection obligations as set out in this Contract
shall be imposed on that other Data Processor by way of a contract or other binding legal
means, in particular providing sufficient guarantees to implement appropriate technical and
organisational measures in such a manner that the processing will meet the requirements of
Data Protection Legislation. Before the commencement of any sub-processing the
Company shall make sufficient enquiries to ensure that the sub processor is capable of
carrying out its data processing obligations.
At any time on not less than 30 days’ notice, the Company may revise this part of the privacy
policy by replacing it with any applicable controller to processor standard clauses or similar
terms forming part of an applicable certification scheme (which shall apply when this policy
is updated).
The Company is not liable in respect of any Patient Data which is controlled by the
Customer in breach of Data Protection Legislation or outside the scope of the permissions
granted to you by the Patient.
The Kind of Information we hold
We may process the following types of Personal Data:
1. Customer Data:
This is information you give us about you and your Staff and may include:
●Identity Data including name, username;
●Contact Data including address, email address and telephone number
●Transaction Data includes details about payments to and from you and other details
of products and services you have purchased from us.
●Technical Data includes internet protocol (IP) address, your login data, browser type
and version, time zone setting and location, browser plug-in types and versions,
operating system and platform, and other technology on the devices you use to
access this website.
●Profile Data includes your username and password, purchases or orders made by
you, your interests, preferences, feedback and survey responses.
●Usage Data includes information about how you use our website, products and
services.
●Marketing and Communications Data includes your preferences in receiving
marketing from us and our third parties and your communication preferences.
We use different methods to collect data from and about you including through:
Direct interactions. You may give us your Identity and Contact by filling in forms or by
corresponding with us by post, phone, email or otherwise. This includes Personal Data you
provide when you:
●Visit our Site;
●Use our Services;
●Use WriteUpp;
●Correspond with us by filling in forms, post, phone, e-mail or otherwise;
●Request marketing to be sent to you;
●Participate in any discussion boards or other social media functions on our Site;
●submit an enquiry to us regarding our products and/or Services whether by
telephone, email, via our website or other channel;
●register a profile, complete surveys, or tell us about any problems with our Site;
●submit material for publication on our website (whether in discussion boards, chat
rooms or other social media platforms our website;
●subscribe for any newsletter or publication we may supply.
Automated technologies or interactions. As you interact with our website, we will
automatically collect Technical Data about your equipment, browsing actions and patterns.
We collect this Personal Data by using cookies, server logs and other similar technologies.
We may also receive Technical Data about you if you visit other websites employing our
cookies. Please see our cookie policy for further details.
Third parties or publicly available sources. We will receive Personal Data about you from
various third parties as set out below:
Usage Data. Personal Data is collected by Raygun – error and performance monitoring for
WriteUpp.
2. Patient Data:
This is information you enter into WriteUpp about your Patients when using WriteUpp and
our Services which may include, but is not limited to:
●Name
●Address
●Email address
●Landline & Mobile Number
●Insurer details
●GP details
●Medical records
●Treatment plans
●Letters & documentation
●Communications with other healthcare professionals; and
●Other information necessary for the operation of the Services and/or WriteUpp.
This Patient Data may be supplied by you when you:
●Use our Services in the course of your business;
●Use WriteUpp in the course of your business; or
●when you report a problem with our Site.
This Patient Data may be processed by us for the purposes of:
●storing Patient Data on WriteUpp;
●storing Patient Data on our servers;
●supplying you with our products and Services;
●enabling and assisting us to comply with all legal, regulatory and compliance
obligations to which we are subject; and
●ensuring the security of our Services, maintaining back-ups of our databases and
sending communications to you.
How we will use personal data
Lawful Basis for the Company’s processing activities.
In this privacy policy, the following terms have the following meanings:
Legitimate Interest means the interest of our business in conducting and managing our
business to enable us to give you the best service/product and the best and most secure
experience. We make sure we consider and balance any potential impact on you (both
positive and negative) and your rights before we process your Personal Data for our
legitimate interests. We do not use your Personal Data for activities where our interests are
overridden by the impact on you (unless we have your consent or are otherwise required or
permitted to by law). You can obtain further information about how we assess our legitimate
interests against any potential impact on you in respect of specific activities by contacting us.
Performance of Contract means processing your Personal Data where it is necessary for
the performance of a contract to which you are a party or to take steps at your request
before entering into such a contract.
Comply with a legal obligation means processing your Personal Data where it is
necessary for compliance with a legal obligation that we are subject to.
When the Company processes Personal Data, whether as Data Controller or as Data
Processor, we will rely on the following lawful grounds for processing of each of the
categories of data identified above.
The Company will use personal information in the following ways:
1. Customer Data
We have set out below, in a table format, a description of all the ways we plan to use
Customer Data, and which of the legal bases we rely on to do so. We have also identified
what our legitimate interests are where appropriate.
Note that we may process your Personal Data for more than one lawful ground depending
on the specific purpose for which we are using your data. Please contact us if you need
details about the specific legal ground we are relying on to process your personal data
where more than one ground has been set out in the table below.
Generally, we do not rely on consent as a legal basis for processing your Personal Data
although we will get your consent before sending third party direct marketing
communications to you via email or text message. You have the right to withdraw consent to
marketing at any time by following the opt-out links on any marketing message sent to you..
Purpose/Activity
Type of data
To register you as a new
customer
(a) Identity
(b) Contact
To process and deliver your
order including:
(a) Manage payments, fees and
charges
(b) Collect and recover money
owed to us
(a) Identity
(b) Contact
(c) Transaction
(d) Marketing and
Communications
To manage our relationship with
you which will include:
(a) Notifying you about changes
to our terms or privacy policy
(b) Asking you to leave a review
or take a survey
(a) Identity
(b) Contact
(c) Profile
(d) Marketing and
Communications
To enable you to partake in a
prize draw, competition or
complete a survey
(a) Identity
(b) Contact
(c) Profile
(d) Usage
(e) Marketing and
Communications
To administer and protect our
business and this website
(including troubleshooting, data
analysis, testing, system
maintenance, support, reporting
and hosting of data)
(a) Identity
(b) Contact
(c) Technical
2. Patient Data:
The legal basis for this processing is:
●you have obtained all necessary and appropriate consent from the Patient/data
subject in accordance with Data Protection Legislation;
●because this is necessary for your use of WriteUpp and the supply of our Services to
you, and performance of our contract; and/or
●your legitimate interests, namely the supply of your services to your Patients.
Patient Data may be processed by the Company for the purposes of:
●storing Patient Data on WriteUpp;
●storing Patient Data on our servers;
●supplying you with our products and Services;
●enabling and assisting us to comply with all legal, regulatory and compliance
obligations to which we are subject; and
●ensuring the security of our Services, maintaining back-ups of our databases.
If you fail to provide personal information
To deliver relevant website
content and advertisements to
you and measure or
understand the effectiveness of
the advertising we serve to you
(a) Identity
(b) Contact
(c) Profile
(d) Usage
(e) Marketing and
Communications
(f) Technical
To use data analytics to
improve our website, products/
services, marketing, customer
relationships and experiences
(a) Technical
(b) Usage
To make suggestions and
recommendations to you about
goods or services that may be
of interest to you
(a) Identity
(b) Contact
(c) Technical
(d) Usage
(e) Profile
(f) Marketing and
Communications
If you, the Customer, fail to provide certain information when requested, the Company may
not be able to perform the Services and any contract we have entered into with you or we
may be prevented from complying with our legal obligations.
Change of purpose
Where we are Data Controller (in respect of Customer Data only): the Company will only use
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. If we need to use your personal information for an unrelated purpose, we
will notify you and we will explain the legal basis which allows us to do so.
Please note that we may process your personal information without your knowledge or
consent, in compliance with the above rules, where this is required or permitted by law.
Where we are Data Processor: the Company will only process Patient Data in accordance
with the conditions for processing set out in this policy. We shall only process Patient Data
relevant to a particular Customer’s Patients, while our contract with the Customer is
continuing and shall cease such processing (a) when requested by the Customer (b) on
termination of the contract (c) on cancellation of the contract; or (d) at the request of the data
subject.
Marketing
We strive to provide you with choices regarding certain Personal Data uses, particularly
around marketing and advertising.
Promotional offers from us
We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on
what we think you may want or need, or what may be of interest to you. This is how we
decide which products, services and offers may be relevant for you (we call this marketing).
You will receive marketing communications from us if you have requested information from
us or purchased services from us and you have not opted out of receiving that marketing.
Third-party marketing
We will get your express opt-in consent before we share your Personal Data with any third
party for marketing purposes.
Opting out
You can ask us or third parties to stop sending you marketing messages at any time by
following the opt-out links on any marketing message sent to you.
Where you opt out of receiving these marketing messages, this will not apply to personal
data provided to us as a result of service purchase, service experience or other transactions.
Disclosure of your personal data
You agree that the Company has the right to share Customer Data (but not Patient Data)
with:
●Any member of our group, which means our subsidiaries, our ultimate holding
company and its subsidiaries, as defined in section 1159 of the UK Companies Act
2006.
●Selected external third parties including:
obusiness partners, suppliers and sub-contractors for the performance of any
contract we enter into with them or you (including third party IT providers,
hosting and back-up service providers);
oProfessional advisers including lawyers, bankers, auditors and insurers who
provide consultancy, banking, legal, insurance and accounting services; and
othird party service providers who assist us with our activities, such as hosting
providers, and other IT or payment service providers, may also have access
to Personal Data held by us and may use this information on our behalf
●Third parties to whom we may choose to sell, transfer or merge parts of our business
or our assets. Alternatively, we may seek to acquire other businesses or merge with
them. If a change happens to our business, then the new owners may use your
personal data in the same way as set out in this privacy policy.
●Other third parties:
oif we are under a duty to disclose or share your personal data in order to
comply with any legal obligation, or in order to enforce or apply the Terms of
Service or the Acceptable Use Policy and other agreements; or
oto protect the rights, property, or safety of the Company, our customers, or
others. This includes exchanging information with other companies and
organisations for the purposes of fraud protection and credit risk reduction;
oto assist us in improving our products and Services. We monitor aggregated
data that is collected by our Service and may share this with third parties
collectively and in an anonymous way. This data will not reveal personal
information.
We will not sell, rent or share Customer Data or Patient Data with third parties in other ways
without your consent unless we are entitled by law to do so.
We require all third parties to respect the security of your Personal Data and to treat it in
accordance with the law. We do not allow our third-party service providers to use your
personal data for their own purposes and only permit them to process your personal data for
specified purposes and in accordance with our instructions.
Where the Company will store personal data
We may hold Personal Data in electronic databases, such as our customer relationship
management system. We take all reasonable steps to keep any Personal Data we hold
about you (and your Patients) secure.
All information which is provided to, or collected by, the Company is:
●Stored on the Company’s secure servers within the United Kingdom and the
European Union (EU), namely Dublin and Amsterdam.
●Hosted on secure data centre managed by our hosting partner with 24/7 manned
security, CCTV, biometric access to the facility and restrictive access to the internals
of the building based on authorisation levels.
International transfers
European Union (“EU”) data protection rules apply to the European Economic Area (“EEA”),
which includes all EU countries and the non-EU countries of Iceland, Liechtenstein and
Norway.
The UK and the EU agreed a Trade and Cooperation Agreement effective from the 1st
January 2021. This agreement provides for an interim period of up to six months where
Personal Data can be transferred from the EEA to the UK and not be seen as a transfer to a
third country. Essentially, the same position on transfers that applied during the Brexit
transition period which is being preserved on an interim basis whilst a UK adequacy decision
is considered.
In relation to UK to EEA transfers, the UK has already announced that it will initially treat the
EEA countries as adequate for the purpose of UK to EEA transfers, but that this will be kept
under review.
Many of our external third parties are based outside the UK so their processing of your
Personal Data will involve a transfer of data outside the UK.
Whenever we transfer your Personal Data out of the UK, we ensure a similar degree of
protection is afforded to it by ensuring safeguards are implemented.
We will only transfer your Personal Data to countries that have been deemed to provide an
adequate level of protection for Personal Data.
Please contact us if you want further information on the specific mechanism used by us
when transferring your Personal Data out of the UK.
Data Security
We have put in place appropriate security measures to prevent your personal data from
being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In
addition, we limit access to your personal data to those employees, agents, contractors and
other third parties who have a business need to know. They will only process your personal
data on our instructions and they are subject to a duty of confidentiality.
We have put in place procedures to deal with any suspected personal data breach and will
notify you and any applicable regulator of a breach where we are legally required to do so.
Passwords and Security
Where the Company has given you (or where you have chosen) a password which enables
you to access your account, you are responsible for keeping this password confidential. The
Company asks you not to share a password with anyone.
Unfortunately, the transmission of information via the internet is not completely secure.
Although the Company will do its best to protect your Personal Data, the Company cannot
guarantee the security of your data transmitted via the Site; any transmission is at your own
risk. Once the Company has received your information, the Company will use strict
procedures and security features to try to prevent unauthorised access.
Data Retention
How long the Company will use personal data
The Company will retain Customer Data for:
●such time as this is required in connection with the Services we are supplying to you;
●following completion of the Services for a period of not less than 6 years from the
date the Services end.
We may retain Customer Data where such retention is necessary for compliance with a legal
obligation to which we are subject, or in order to protect your vital interests or the vital
interests of another natural person.
The Company will retain Patient Data for:
●such time as this is required in connection with the Services we are supplying to you;
●following completion of the Services for a maximum period of 45 days from the date
the Services end.
Your rights as a data subject (where the Company is
the Data Controller)
Under certain circumstances, if you are an individual in respect of whom the Company
processes Personal Data, you have the following rights. Please note that this is a summary
of your rights. If you wish to understand your rights in detail you should read the relevant
laws, guidance and regulations for a fuller explanation.
You have the right to:
Request access to your Personal Data (commonly known as a "data subject access
request"). This enables you to receive a copy of the Personal Data we hold about you and to
check that we are lawfully processing it. We will supply the data free of charge but we
reserve the right to charge a reasonable fee (or refuse to act on the request) if you request
additional copies of the information, if access requests are unfounded or excessive.
There are circumstances where we may withhold the supply of your Personal Data – for
instance where the rights and freedoms of others may be affected or where we are permitted
by law.
Request correction of the Personal Data 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.
Erasure of your Personal Data. This enables you to ask us to delete or remove Personal
Data where there is no good reason for us continuing to process it. You also have the right to
ask us to delete or remove your Personal Data where you have successfully exercised your
right to object to processing (see below), where we may have processed your information
unlawfully or where we are required to erase your Personal Data to comply with local law.
Note, however, that we may not always be able to comply with your request of erasure for
specific legal reasons which will be notified to you, if applicable, at the time of your request.
Object to processing of your Personal Data where we are relying on a legitimate interest
(or those of a third party) and there is something about your particular situation which makes
you want to object to processing on this ground as you feel it impacts on your fundamental
rights and freedoms. You also have the right to object where we are processing your
personal data for direct marketing purposes. In some cases, we may demonstrate that we
have compelling legitimate grounds to process your information which override your rights
and freedoms.
Request restriction of processing of your Personal Data. This enables you to ask us to
suspend the processing of your Personal Data in the following scenarios:
●If you want us to establish the data's accuracy.
●Where our use of the data is unlawful but you do not want us to erase it.
●Where you need us to hold the data even if we no longer require it as you
need it to establish, exercise or defend legal claims.
●You have objected to our use of your data but we need to verify whether we
have overriding legitimate grounds to use it.
Request the transfer of your Personal Data to you or to a third party. We will provide to you,
or a third party you have chosen, your Personal Data in a structured, commonly used,
machine-readable format. Note that this right only applies to automated information which
you initially provided consent for us to use or where we used the information to perform a
contract with you.
Withdraw consent at any time where we are relying on consent to process your Personal
Data. However, this 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. We will advise you if this is the case at the time you withdraw
your consent.
No fee usually required
You will not have to pay a fee to access your Personal Data (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 could refuse to comply with your request in these
circumstances.
What we may need from you
We may need to request specific information from you to help us confirm your identity and
ensure your right to access your Personal Data (or to exercise any of your other rights). This
is a security measure to ensure that Personal Data is not disclosed to any person who has
no right to receive it. We may also contact you to ask you for further information in relation to
your request to speed up our response.
Time limit to respond
We try to respond to all legitimate requests within one month. Occasionally it could 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.
Withdrawal of consent
In any cases where the legal basis for our processing of your Personal Data is consent, you
have the right to withdraw that consent at any time. Such withdrawal will not affect the
lawfulness of any processing before you withdraw consent.
Cookies
Like most applications, WriteUpp uses cookies to help provide you with the best experience
we can. Cookies are small text files that are placed on your computer or mobile phone when
you browse websites
Our cookies help us:
●Make WriteUpp work as you'd expect
●Enables WriteUpp to remember your details so you don't have to enter them each
time you log in (if you so choose)
●Remember your settings in WriteUpp
●Improve the speed/security of WriteUpp
We do not use cookies to:
●Collect any personally identifiable information (without your express permission)
●Pass data to advertising networks
●Pass personally identifiable data to third parties
You can learn more about all the cookies we use below.
Granting us permission to use cookies
If the settings on your software that you are using to view this Site (your browser) are
adjusted to accept cookies we take this, and your continued use of our Site, to mean that
you are fine with this. Should you wish to remove or not use cookies from our Site you can
learn how to do this below, however doing so will prevent the service from working.
Website Function Cookies
Our own cookies
We use cookies to make our Site work, including:
●Determining if you are logged in or not
●Remembering your search settings
●Showing which patients you have recently viewed
●Tailoring content to your needs
●Remembering your preferences
There is no way to prevent these cookies being set other than to not use our Site.
Third party functions
Our Site, like most websites, includes functionality provided by third parties. Disabling these
cookies will likely break the functions offered by these third parties.
Turning cookies off
WriteUpp will not function if cookies are turned off or disabled.
Links
The Site may, from time to time, contain links to and from the websites of our partner
networks, advertisers and affiliates. Clicking on those links or enabling those connections
may allow third parties to collect or share data about you. Please note that we do not control
these third-party websites, which may have their own privacy policies, and that we are not
responsible for their privacy statements. When you leave our Site, we encourage you to read
the policy statement of every website you visit.
Contact
Questions, comments and requests regarding this privacy policy are welcomed and should
be addressed to support@writeupp.com.
If you have any questions or have a complaint about this privacy policy please let us know
us immediately.
To individuals situated in the EU, please contact us directly in regards to requesting your
individual rights, alternatively we have instructed Verasafe Ireland Limited as our EU
Representative in accordance with Article 27 of the GDPR for EU supervisory authorities and
EU citizens (contact details below).
Post: Verasafe Ireland Limited, Unit 3D North Point House, North Point House, North Point
Business Park, New Mallow Road, Cork, T23 ATZP.
You have the right to make a complaint at any time to the Information Commissioner's Office
(ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would,
however, appreciate the chance to deal with your concerns before you approach the ICO so
please contact us in the first instance.
Company Information
Pathway Software
Watergate House,
85 Watergate Street,
England,
CH1 2LF
Web: www.writeupp.com
Email: support@writeupp.com
Company Number: 06844098
VAT Number: 948 3831 85