Last updated: September 2022
Our contact details
Name: Simple Pharma I Limited, trading as Androlabs
Address: Floor 4, Suite 3, 1 Duchess Street, London, England, W1W 6AN
Simple Pharma I Limited (“Androlabs”, “we”, “us”) collect personal information through our TRTED blog site (www.trted.org) and our TRTED community forum (https://community.trted.org/) . While we may use third parties to provide services to you, we are the data controller for personal information that we collect and process for our own purposes. This notice describes how we collect and use personal information, and explains your rights in relation to this data.
The type of personal information we collect and why we have it
Most of the personal information we process is provided directly by you to us to use or subscribe to our services, for example when you sign up to our blog mailing list or when you open an account on the TRTED forum. We currently collect and process the following information:
• Usage data for our services, which may include your device’s internet protocol address (IP address), browser type, browser version, the pages of our website that you visit, the time and date of your visit, the time spent on those pages, unique device identifiers and other diagnostic data. We collect this information so that we can better understand how users are interacting with our services and to improve the overall user experience, for example by debugging our services and to compile information on the most popular content for our users. This information is aggregated.
• Cookies information. Please view our cookies policy here.
• Contact information, such as your name and email address, and the contents of your message to us. If you opt to subscribe to updates from our blog or you reach out to us, we will process the information you provide to allow us to respond to your query or to sign you up to our newsletter.
• Account information, such as your name, email address, username, date of birth, occupation and location. When you create an account on our forum, we will process your account information to allow you to login and contribute to discussions.
• Account activity, including posts, likes and bookmarks you follow. This allows us to save your activity when using our forum.
• We may process sensitive personal data, including physical or mental health details if you include this in your posts or when you contact us. Androlabs is dedicated to improving awareness of men’s health conditions, which we believe are underdiagnosed and undertreated. If you write about your physical or mental health when posting in the TRTED forum or when contacting us, we will process this data to respond to you or to allow you to save and publish your post on the forum.
• Any other information you actively provide to us, for example in an email or through a contact form. We will process this information to allow us to respond to you.
Legal basis for processing
In order to process your personal data, we need to be able to rely on a lawful basis processing. Under the UK General Data Protection Regulation (UK GDPR) and the EU General Data Protection Regulation (EU GDPR), we rely on the following lawful bases to process this information:
Your consent. You may provide us with consent to process your data when you communicate with us. When you opt-in to our mailing updates, you provide us with your consent to add you to our subscription list, and when you email or contact us, you give us consent to process your data so that we can respond to you. To change your subscription, please email firstname.lastname@example.org.
We have a contractual obligation. We may need to use your personal data to be able to provide you with our services. Please see our terms and conditions here.
We have a legal obligation. For example, we may need to process your information if requested to do so by a court or tribunal.
We have a legitimate interest. When we use your data, we will consider whether it is fair, and whether you can reasonably expect that we would do so. We also consider how to limit the processing so that we can achieve our purpose with the least data possible. Our legitimate interests include: administration and operations, such as responding to requests and queries; web analytics to improve our services; and research into men’s health conditions.
You have made the data public. When you post personal information on our sites, such as by leaving a comment on a blog article or by posting in a thread on the forum, you choose to make this data publicly available.
Do we share your information?
We will not share any of your personal data to a third party except where:
• the transfer is to a secure data processor, which carries out data processing operations on our behalf, such as Discourse or Google Analytics
• we are required to do so by law, for example to law enforcement or regulatory bodies where this is required or allowed under the relevant legislation
• it is necessary to protect the vital interests of an individual
• we have obtained your consent
We may also share your information with other companies in our group.
Where we transfer your personal data outside of the European Economic Area, we will take reasonable steps to ensure that the recipient implements appropriate measures to protect your information, for example, by entering into a contract that includes prescribed clauses about the use of data such as the Standard Contractual Clauses.
How we store your personal information
We use third parties such as Microsoft, Google, FreshDesk and Discourse for our internal office use and to provide services to you. This means that our documents are securely stored in cloud services.
We will only store your information for a specified amount of time, as set out in our internal data retention policy. The length of time we will store your information for will depend on the reason why we are processing your data, and may be subject to certain legal requirements. If you unsubscribe from our mailing lists, we will keep some basic information about you to avoid sending you material in the future.
Once the retention period has expired, we will permanently destroy the data.
Your data protection rights
Under data protection law, you have rights including:
Your right of access. You have the right to ask us for copies of your personal information.
Your right to rectification. You have the right to ask us to rectify personal information you think is inaccurate. You also have the right to ask us to complete information you think is incomplete.
Your right to erasure. You have the right to ask us to erase your personal information in certain circumstances.
Your right to restriction of processing. You have the right to ask us to restrict the processing of your personal information in certain circumstances.
Your right to object to processing. You have the the right to object to the processing of your personal information in certain circumstances.
Your right to data portability. You have the right to ask that we transfer the personal information you gave us to another organisation, or to you, in certain circumstances.
The rights available to you will depend on the reason why we are processing your information.
You are not required to pay any charge for exercising your rights. If you make a request, we have one month to respond to you.
Please contact us at email@example.com if you wish to make a request.
How to complain
If you have any concerns about our use of your personal information, you can make a complaint to us at firstname.lastname@example.org.
You can also complain to the ICO if you are unhappy with how we have used your data.
The ICO’s address:
Information Commissioner’s Office
Helpline number: 0303 123 1113
ICO website: https://www.ico.org.uk