PRIVACY POLICY
How we collect, use, store and protect your personal data
Registered Office: 167-169 Great Portland Street, London, England, W1W 5PF
1. Introduction
1.1 This Privacy Policy sets out in full how Freshstart Pharma UK Ltd (“Freshstart Pharma”, “we”, “us”, “our”) collects, uses, stores, shares and safeguards personal data in accordance with the UK General Data Protection Regulation (UK GDPR), the Data Protection Act 2018, the Privacy and Electronic Communications Regulations (PECR) and all applicable UK data protection laws.
1.2 Freshstart Pharma UK Ltd is a company registered in England and Wales. Registered office: 167-169 Great Portland Street, London, England, W1W 5PF.
1.3 This Privacy Policy applies to all customers, website users, account holders, business purchasers, enquirers and any person interacting with Freshstart Pharma.
1.4 By using our website or purchasing products, you acknowledge and agree to the practices described in this Policy.
2. Scope of this Policy
2.1 This Policy governs all personal data processed through:
2.1.1 our website (www.freshstartpharma.co.uk);
2.1.2 customer accounts;
2.1.3 email, telephone and electronic communications;
2.1.4 orders placed for Freshstart Pharma products;
2.1.5 compliance checks (where applicable).
2.2 This Policy does not apply to employees, contractors or external service providers who have separate agreements.
3. Definitions
3.1 “Personal Data” means information that identifies or relates to an identifiable person.
3.2 “Processing” means collecting, storing, using, sharing or handling personal data.
3.3 “Customer” includes consumers, healthcare professionals, pharmacies, clinics and business purchasers.
4. Categories of Personal Data We Collect
4.1 Identity Data may include full name, date of birth, age, title, business identity and professional registration details (for trade purchases).
4.2 Contact Data may include billing address, delivery address, email address and telephone numbers.
4.3 Technical Data includes IP address, device identifiers, browser data, session data, cookies and analytics information.
4.4 Transaction Data includes order history, payment confirmations, product categories purchased and invoicing information.
4.5 Compliance and Verification Data includes declarations confirming purchaser eligibility, professional accreditation (where applicable) and any supporting documentation voluntarily provided.
4.6 Communications Data includes emails, support queries and messages sent to Freshstart Pharma.
4.7 We do not store full card details; payment processing is handled securely by regulated third-party processors.
5. How We Collect Data
5.1 Direct interactions include placing orders, creating accounts, completing forms, contacting customer support and submitting compliance declarations.
5.2 Automated interactions include cookie and analytic tools that gather technical data as you browse the site.
5.3 Third-party sources include payment processors, courier systems and identity verification providers (where applicable).
6. Legal Basis for Processing
6.1 Contractual necessity applies when processing is required to fulfil your order or provide services.
6.2 Legal obligation applies for tax, accounting, fraud prevention and regulatory compliance.
6.3 Legitimate interest applies where processing is necessary for:
6.3.1 preventing misuse of restricted-access products;
6.3.2 maintaining product safety (including cold-chain products);
6.3.3 improving website functionality;
6.3.4 protecting our commercial interests.
6.4 Consent applies to marketing communications, which may be withdrawn at any time.
7. Age and Eligibility Verification
7.1 Only individuals aged 18 or above may purchase products from Freshstart Pharma, save where a higher age threshold applies to a specific product category.
7.2 Freshstart Pharma may request proof of age or professional accreditation where necessary to satisfy compliance obligations.
8. How We Use Personal Data
8.1 To process and deliver orders, including dispatch logistics and customer communications.
8.2 To maintain customer accounts and order history.
8.3 To perform safety, temperature-sensitive and regulatory notifications.
8.4 To prevent fraud, misuse of products and breach of usage restrictions.
8.5 To comply with accounting, tax, legal and regulatory requirements.
8.6 To improve website functionality and security.
9. Sharing Personal Data
9.1 We may share personal data with the following regulated or contractually bound entities:
9.1.1 payment processors for secure payment handling;
9.1.2 courier companies for delivery and dispatch updates;
9.1.3 IT, hosting and security service providers;
9.1.4 legal, tax and regulatory authorities when required by law;
9.1.5 professional advisers (lawyers, accountants).
9.1.6 To police or regulated authorities in case of investigation
9.2 Freshstart Pharma does not sell personal data under any circumstances.
10. International Transfers
10.1 Freshstart Pharma may transfer data outside the UK when required for hosting or service providers.
10.2 We ensure compliance using Standard Contractual Clauses, the UK Addendum or adequacy decisions.
11. Data Retention
11.1 Freshstart Pharma retains personal data only for as long as necessary for lawful purposes:
11.1.1 order data and tax records: minimum 6 years;
11.1.2 compliance declarations: minimum 7 years;
11.1.3 account data: until account closure;
11.1.4 marketing data: until consent withdrawn.
12. Data Security
12.1 Freshstart Pharma implements industry-standard technical and organisational measures including restricted access, encryption, anti-malware protocols and secure backups.
12.2 While we take robust precautions, no data transmission can be guaranteed entirely secure.
13. Customer Rights
13.1 Under UK GDPR you have the right to:
13.1.1 access your data;
13.1.2 request correction or deletion;
13.1.3 restrict processing;
13.1.4 object to certain processing;
13.1.5 request data portability;
13.1.6 withdraw marketing consent;
13.1.7 lodge a complaint with the Information Commissioner’s Office.
13.2 Requests may be submitted to privacy@freshstartpharma.co.uk.
14. Cookies
14.1 Our website uses essential and analytical cookies.
14.2 A full Cookies Policy is available as a separate document.
15. Links to Other Policies
15.1 This Privacy Policy should be read together with our Terms & Conditions, Refund Policy, Shipping Policy, Cookies Policy and Accessibility Policy.
16. Policy Updates
16.1 Freshstart Pharma may update this Policy at any time.
16.2 The latest version will always be published at www.freshstartpharma.co.uk/privacy-policy.
17. Contact Details
17.1 Freshstart Pharma UK Ltd, 167-169 Great Portland Street, London, England, W1W 5PF.
17.2 Email: privacy@freshstartpharma.co.uk