myLDN Privacy and Legal Notice

1. INTRODUCTION

1.1 This privacy notice provides you with details of how we collect and process your personal data through your use of myLDN.

By providing us with your data, you warrant to us that you are over 13 years of age.

LDN Research Trust is the data controller and we are responsible for your personal data (referred to as “we”, “us” or “our” in this privacy notice).

We have appointed a Data Protection Officer who oversees privacy related matters for us. If you have any questions about this privacy notice, please contact the Data Protection Officer using the details set out below.

1.2 Contact Details

Our full details are:

Full name of legal entity: LDN Research Trust

Name or title of Data Protection Officer: Laurie Phillips

Email address: privacy@ldnrt.org

Postal address: LDN Research Trust - PO Box 1083, Buxton, Norwich NR10 5WY

If you are not happy with any aspect of how we collect and use your data, you have the right to complain to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues ( www.ico.org.uk). We should be grateful if you would contact us first if you do have a complaint so that we can try to resolve it for you.

It is very important that the information we hold about you is accurate and up to date. Please let us know if at any time your personal information changes by emailing us at privacy@ldnrt.org OR by updating the information yourself in the ‘My Details’ section of myLDN.

2. WHAT DATA DO WE COLLECT ABOUT YOU

2.1 Personal data means any information capable of identifying an individual. It does not include anonymised data.

We may process certain types of personal data about you as follows:

2.2 Sensitive Data

We need to collect the following sensitive data about you for myLDN to function and to allow research studies to be carried out:

The purpose of myLDN is to enable research into the use of Low Dose Naltrexone, and we are citing Legitimate Interest as our lawful basis for the processing of your data.

We must have your explicit consent for processing sensitive data, so when you create an account, you will be asked to confirm that you consent to us processing your data. If you do not consent to us processing your data, you will be unable to create an account.

3. HOW WE COLLECT YOUR PERSONAL DATA

We collect data about you through a variety of different methods including:

4. HOW WE USE YOUR PERSONAL DATA

4.1 We will only use your personal data when legally permitted. The most common uses of your personal data are:

4.2 Purposes for processing your personal data

Set out below is a description of the ways we intend to use your personal data and the legal grounds on which we will process such data. We have also explained what our legitimate interests are where relevant.

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 email us at privacy@ldnrt.org 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.

Purpose/Activity

Type of data

Lawful basis for processing

To register you as a new user

(a) Identity

(b) Contact

Performance of a contract with you

To manage our relationship with you which will include:

(a) Notifying you about changes to our terms or privacy policy

(a) Identity

(b) Contact

(d) Marketing and Communications

(a) Performance of a contract with you

(b) Necessary to comply with a legal obligation

(c) Necessary for our legitimate interests to keep our records updated and to study how customers use our products/services

To administer our app (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data

(a) Identity

(b) Contact

(c) Technical

(a) Necessary for our legitimate interests for running our organisation, provision of administration and IT services, and research

(b) Necessary to comply with a legal obligation

To support LDN Research with anonymized health data

(a) Health

Necessary for our legitimate interests to provide otherwise unavailable data so that researchers may conduct research on LDN

To allow patients to share their data with their physicians

(a) Identity

(b) Health

(a) Necessary for our legitimate interests in enhancing patients’ health and lives by the use of LDN

(b) Consent

4.3 Marketing and communications

You will never receive marketing communications from us. We may, however, send you messages via:

These messages will be informational in nature and necessary for the performance of the app, or to keep you up-to-date with any changes to our terms and privacy policy.

4.4 Change of purpose

We will only use your personal data 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 you wish to find out more about how the processing for the new purpose is compatible with the original purpose, please email us at privacy@ldnrt.org.

If we need to use your personal data for a purpose unrelated to the purpose for which we collected the data, we will notify you and we will explain the legal ground of processing.

We may process your personal data without your knowledge or consent where this is required or permitted by law.

5. DISCLOSURES OF YOUR PERSONAL DATA

We may have to share your anonymized personal data with the parties set out below for the purposes set out in the table in paragraph 4 above:

Researchers, statisticians, students, pharmaceutical companies, insurance companies and other similar entities for the purpose of researching the efficacy of LDN.

We require all third parties to whom we transfer your data to respect the security of your personal data and to treat it in accordance with the law. We only allow such third parties to process your personal data for specified purposes and in accordance with our instructions.

6. INTERNATIONAL TRANSFERS

We do not transfer identifiable personal data outside the European Economic Area (EEA). Any transfers of data will be anonymized.

7. 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 such data.

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.

8. DATA RETENTION

We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal or reporting requirements.

To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.

In some circumstances you can ask us to delete your data: see below for further information.

In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.

9. YOUR LEGAL RIGHTS

Under certain circumstances, you have rights under data protection laws in relation to your personal data. These include the right to:

You can see more about these rights at: https://ico.org.uk/for-organisations/guide-to-the-general-data-protection-regulation-gdpr/individual-rights/

If you wish to exercise any of the rights set out above, please email us at privacy@ldnrt.org.

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 may refuse to comply with your request in these circumstances.

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.

We try to respond to all legitimate requests within one month. Occasionally it may 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.