WEBSITE & DIGITAL USER PRIVACY POLICY
“User Data” refers to information that you upload, input, or furnish to Optifema. This includes
data that may either directly identify an individual or have the potential to do so. Such
information is submitted to and/or collected by Optifema Web Sites or Software in the
course of your interactions with our platform.

Personally Identifiable Information collected:
We will collect and use the following personal data about you:
• your name, address and contact information;
• your contact history and purchase history;
• any home address specified;
• your gender;
• your billing information, transaction and payment card or other payment method
information;
• bank account and payment details;
• details of any information, feedback or other matters you give to us by phone, email,
post or via social media;
• your account details such as username and login details;
Information about the services we provide to you.
User Data encompasses information such as names, postal addresses, email addresses, and
telephone numbers, collectively referred to as Personally Identifiable Information (PII), which
is protected by stringent privacy laws. When Optifema collects, utilizes, and assumes
responsibility for specific PII in delivering our services, we ensure strict compliance with Data
Protection Legislation outlined in our Terms and Conditions.
In instances where User Data lacks PII and cannot be utilised to directly or indirectly identify
an individual, it falls under the category of Aggregated Data, exempt from UK GDPR
regulations. This anonymised and generalised data may be leveraged for statistical analysis,
exclusively aimed at enhancing public health and diagnostics. Optifema reserves the right to
commercialise Aggregated Data.
Optifema may derive New Data from your User Data, provided it does not involve PII or fall
under intellectual property provisions within a related services contract. This newly
generated data is distinct from User Data and is exclusively owned by Optifema, granting us
intellectual property rights. Optifema is authorised to process this New Data on the same
Aggregated Data basis as mentioned earlier.
Regarding online information collection, Optifema serves as the controller for User Data
obtained through Optifema Web Sites and certain software platforms. As the legal entity
responsible for determining the purpose and means of usage, Optifema prioritises the secure
handling of your information.

Ways we collect User Data:
1. User Data Submission:
Optifema gathers User Data entered into data fields on its Web Sites and software. This
includes details like your name, postal address, email address, and other information
submitted for purposes such as receiving information, opting into marketing, contacting
customer service, or participating in surveys. To ensure privacy, refrain from providing
information not explicitly requested, and ensure legal entitlement to submit User Data
according to local data protection laws.
2. Passive Unidentifiable Information Collection:
Optifema Web Sites may collect information about your visits without active submission.
Technologies like cookies and web beacons facilitate this passive collection. Cookies, small
text files transferred to your computer, and web beacons help customise and enhance user
experience. Your browser automatically transmits some unidentifiable information,
contributing to service improvement. Some site features may require passive information
collection technologies. Collected information cannot identify you without additional
identifiable data, and Optifema ensures the separation of this information.
3. Google Analytics:
The Optifema website may employ Google Analytics, a web analytics service by Google, Inc.
Google Analytics uses cookies to assess website usage and generate activity reports on
www.Optifema.com. Google may share this information with third parties as required by law
or for processing on Google’s behalf. Your IP address will not be associated with other data
held by Google.

Managing Cookies:
Persistent Cookies: These cookies remain on your computer until they expire, or you delete
them. They capture user information, like preferences, for enhanced and quicker access
during subsequent visits.
Disabling Cookies: To prevent the use of cookies in your browser:
– Remove cookies from your computer’s hard drive.
– Adjust your browser settings to block cookies or receive a warning before storage.
Please be aware that without cookies, you may be unable to access numerous services on our
website or other websites effectively.

User Data Collection:
Under data protection law, we can use your User Data if we have a proper reason e.g.
• where you have given consent;
• to comply with our legal and regulatory obligations;
• for the performance of a contract with you or to take steps at your request before
entering into a contract; or
• for our legitimate interests or those of a third party.
• Scientific Research, Statistical analysis and on a Public Interest basis.
A legitimate interest is when we have a business or commercial reason to use your User Data,
so long as this is not overridden by your own rights and interests. The table below explains
what we use your User Data for and why.
What we use your User Data for Our reasons
Creating and managing your account with us To perform our contract with you or to take
steps at your request before entering into a
contract
Conducting checks to identify you and verify
your identity or to help prevent and detect
fraud against you or us
To comply with our legal and regulatory
obligations
Enforcing legal rights or defend or
undertake legal proceedings
Depending on the circumstances: -to comply
with our legal and regulatory obligations -in
other cases, for our legitimate interests, e.g.
to protect our business, interests and rights
Customising our website and its content to
your preferences based on a record of your
selected preferences or on your use of our
website
Depending on the circumstances: -your
consent as gathered -where we are not
required to obtain your consent and do not
do so, for our legitimate interests, e.g., to be
as efficient as we can so we can deliver the
best service to you at the best price
Retaining and evaluating information on
your recent visits to our website and how
you move around different sections of our
Depending on the circumstances: your
consent as gathered -where we are not
required to obtain your consent and do not
website for analytics purposes to
understand how people use our website so
that we can make it more intuitive or to
check our website is working as intended
do so, for our legitimate interests, e.g. to be
as efficient as we can so we can deliver the
best service to you at the best price
Communications with you not related to
marketing, including about changes to our
terms or policies or changes to the products
and/or services or other important notices
Depending on the circumstances: -to comply
with our legal and regulatory obligations -in
other cases, for our legitimate interests, e.g.
to be as efficient as we can so we can deliver
the best service to you at the best price
Protecting the security of systems and data
used to provide the services
To comply with our legal and regulatory
obligations We may also use your User Data
to ensure the security of systems and data to
a standard that goes beyond our legal
obligations, and in those cases our reasons
are for our legitimate interests, e.g. to protect
systems and data and to prevent and detect
criminal activity that could be damaging for
you and/or us
Statistical analysis to help us understand our
customer base
For our legitimate interests, e.g. to be as
efficient as we can so we can deliver the best
service to you at the best price
Updating and enhancing customer records Depending on the circumstances: -to perform
our contract with you or to take steps at your
request before entering into a contract -to
comply with our legal and regulatory
obligations -where neither of the above apply,
for our legitimate interests, e.g. making sure
that we can keep in touch with our customers
about existing orders and new products
Disclosures and other activities necessary to
comply with legal and regulatory obligations
that apply to our business
To comply with our legal and regulatory
obligations
Marketing our services to existing and
former customers
For our legitimate interests, e.g. to promote
our business to existing and former customers
For any audits carried out on Optifema For our legitimate interests, e.g. maintain our
accreditations so we can demonstrate we
operate at the highest standards
To share your User Data with members of
our group and third parties that will or may
take control or ownership of some or all of
our business (and professional advisors
acting on our or their behalf) in connection
with a significant corporate transaction or
restructuring, including a merger,
acquisition, asset sale, initial public offering
or in the event of our insolvency In such
cases information will be anonymised where
possible and only shared where necessary
Depending on the circumstances: -to comply
with our legal and regulatory obligations -in
other cases, for our legitimate interests, e.g.
to protect, realise or grow the value in our
business and assets
Using identifying technologies to allow the
Optifema Web Site to track your personal
preferences
Addressing and sending communications to
you about opportunities to receive notices
regarding Optifema’s products or services
invitations to surveys or notifying you about
special promotions
Certain User Data we may collect is treated as a special category to which additional
protections apply under data protection law including:
• data concerning health;
• data concerning sex life;
• genetic data
Access to Special Category Data will be restricted to individuals with a legitimate interest and
a demonstrable need to access it for specific purposes outlined in compliance with GDPR
regulations. This may include Optifema employees and our partners involved in patient
management software.Where we process such special category User Data, we will ensure we
are permitted to do so under data protection laws.
User Data: User Data-Marketing
We may use your User Data to send you updates (by email, text message, telephone or post)
about our product and/or services, including exclusive offers, promotions or new products
and/or services.
We have a legitimate interest in using your User Data for marketing purposes.
You have the right to opt out of receiving marketing communications at any time by:
• contacting us; support@optifema.com
• using the ‘unsubscribe’ link in any emails we send you
• updating your marketing preferences.
We may ask you to confirm or update your marketing preferences if you ask us to provide
further products and/or services in the future, or if there are changes in the law, regulation,
or the structure of our business.
We will always treat your User Data with the utmost respect and never sell or share it with
other organisations outside Optifema for marketing purposes.
Consolidating User Data:

Optifema may consolidate the User Data of customers who use Optifema Web Sites. In
addition, we may consolidate information in a non-identifiable form (aggregate/anonymous
data) to help us better design Optifema Web Sites and Optifema products, to enhance our
research activities, and to facilitate other business functions. This may result in
commercialisation of aggregate data. For the avoidance of doubt, you are not entitled to any
compensation in such circumstances. The aggregate data shall be used solely on a statistical
basis for the purposes of improving public health.

Your user rights and options:
You may always limit the amount and type of User Data that Optifema receives about you by
choosing not to enter any User Data into forms or data fields on Optifema Web Sites. Some
of our online services can only be provided to you if you provide us with appropriate User
Data. Other parts of Optifema Web Sites may ask whether you wish to opt into our contact
lists for offers, promotions and additional services that may be of interest to you.
You may also be provided with preference questions or preference boxes allowing you to
indicate that you do not want Optifema Web Sites to use tracking technologies, such as
cookies, to “remember” your User Data, such as user IDs or mailing addresses (If such
tracking technologies are in use at the time of visiting the website), on return visits. However,
Optifema Web Sites that use tracking technologies to collect unidentifiable information do
not generally provide you with the ability to opt out of the tracking technologies. Some
Internet browsers allow you to limit or disable the use of tracking technologies that collect
unidentifiable information.

How your Data may be accessed:
User Data can be accessed by a restricted number of Optifema employees, by certain
companies with which Optifema may conduct joint programs, and by third parties with whom
Optifema contracts to carry out business activities for Optifema. We train our employees
about the importance of privacy and how to handle and manage customer data appropriately
and securely. Also, it is Optifema’s practice to seek your consent where required by
applicable law if you are registering for a program which is conducted in conjunction with
another company that may require access to your User Data. In addition, Optifema’s practice
is to require its contractors to keep your User Data confidential and to use your User Data
only to perform functions for Optifema.
We routinely share User Data with:
• third parties we use to help deliver our products and/or services to you, e.g. payment
service providers, Laboratories & Testing Facilities.
• other third parties we use to help us run our business, e.g. marketing agencies or
website hosts, website analytics providers, Client Management software companies
and Accountancy Software companies;
• our banks;
• to the buyer subject to your consent in the event Optifema sells one of its product
lines or divisions, when required by applicable law so that the buyer can continue to
provide you with information and services.
Except as otherwise stated in this Section, Optifema will not transfer your personal
information to third parties unless you have been provided with an opportunity to opt
into this disclosure. Optifema may disclose your personal information without your
opt-in to third party service providers which assist us with our business activities with
specific regard to our contracted service. It is Optifema’s practice to require such
third-party service providers to keep your personal information confidential and to
use your personal information only to perform functions for Optifema and in
accordance with Optifema’s instructions. Optifema further reserves the right to
disclose your personal information to respond to authorised information requests
from government authorities or when otherwise required by law.
• Research Partners on a de-identified Aggregated Data basis, solely for the purpose of
improving and creating diagnostic products with a view to improving public health.
• Regulatory bodies, on a de-identified Aggregated Data basis, solely for the purpose of
improving and creating diagnostic products with a view to improving public health.
We do our upmost to only allow those organisations to handle your User Data if we are
satisfied, they take appropriate measures to protect your User Data.

We or the third parties mentioned above may occasionally also share User Data with:
• our and their external auditors, e.g. in relation to the audit of our or their accounts, in
which case the recipient of the information will be bound by confidentiality
obligations;
• Our and their professional advisors (such as lawyers and other advisors), in which case
the recipient of the information will be bound by confidentiality obligations;
• Law enforcement agencies, courts, tribunals and regulatory bodies to comply with our
legal and regulatory obligations;
• Other parties that have or may acquire control or ownership of our business (and our
or their professional advisers) in connection with a significant corporate transaction
or restructuring, including a merger, acquisition, asset sale, initial public offering or in
the event of our insolvency—usually, information will be anonymised, but this may
not always be possible. The recipient of any of your User Data will be bound by
confidentiality obligations.
How does Optifema secure User Data?
• We seek to limit access to your User Data to those who have a genuine need to access
it. We also have procedures in place to deal with any suspected data security breach
where we are legally required to do so.
• It is Optifema’s practice to secure Optifema Web Sites that collects User Data;
however, the confidentiality of User Data transmitted over the Internet cannot be
guaranteed. We urge you to exercise caution when transmitting User Data over the
Internet. Optifema cannot guarantee that unauthorised third parties will not gain
access to your User Data; therefore, when submitting User Data to Optifema Web
Sites, you must weigh both the benefits and the risks. In addition, Optifema Web Sites
covered by this Privacy Policy we may have backlinks that take you to other thirdparty Web sites that are not controlled by Optifema; you should check the privacy
policies of such third-party web sites before submitting User Data. If you require more
information on this, it can be obtained from, Get Safe Online where you will find
information on how to protect your User Data and other information, and how to
protect your computers and devices against fraud, identity theft, viruses and many
other online problems, please visit www.getsafeonline.org Get safe online is
supported by HM Government and leading businesses.
Transferring your User Data out of the country of origin, or where it was originally provided.
The EEA, UK and other countries outside the EEA and the UK have differing data protection
laws, some of which may provide lower levels of protection of privacy.
It may be sometimes necessary for us to transfer your User Data to countries outside of
where it was provided. In those cases, we will comply with applicable data protection
legislation designed to ensure the privacy of User Data.
Under data protection laws, we can only transfer your User Data to a country outside of
where it was originally provided:
• If the subject government of country of origin has decided the particular country
ensures an adequate level of protection of User Data (known as an ‘adequacy
regulation’) further to Article 45 of the UK GDPR
• in the case of transfers subject to EEA data protection laws, the European
Commission has decided that the particular country ensures an adequate level of
protection of User Data (known as an ‘adequacy decision’) further to Article 45 of the
EU GDPR;
• There are appropriate safeguards in place, together with enforceable rights and
effective legal remedies for you, or;
• a specific exception applies under relevant data protection law.
• You have consented to the transfer, and that country is considered to satisfy the
appropriate requirements.
• Sufficient contractual provision is in place to ensure compliance with Schemes and
associated Standard Contractual Clauses
Where we transfer your User Data outside the country of origin, we do so based on an
adequacy regulation e.g. legally approved standard data protection clauses recognised or
issued further to Article 46(2) of the UK GDPR. In the event we cannot or choose not to
continue to rely on this mechanism at any time we will not transfer your User Data outside
the Country of origin unless we can do so based on an alternative mechanism or exception
provided by UK data protection law and reflected in an update to this policy.
Where we transfer your User Data outside the EEA, we do so on the basis of an adequacy
decision e.g. legally approved standard data protection clauses issued further to Article 46(2)
of the EU GDPR. In the event we cannot or choose not to continue to rely on this mechanism
at any time we will not transfer your User Data outside the EEA unless we can do so based on
an alternative mechanism or exception provided by applicable data protection law and
reflected in an update to this policy.
Any changes to the destinations to which we send User Data or in the transfer mechanisms
we rely on to transfer User Data internationally will be notified to you in accordance with the
section on ‘How will I know whether Optifema has updated its privacy policy’ below.
The following types of cookies may be used when you visit this site:

Advertising Cookies
Advertising cookies are placed on your computer by advertisers and ad servers to display
advertisements that are most likely to be of interest to you. These cookies allow advertisers
and ad servers to gather information about your visits to the Site and other websites,
alternate the ads sent to a specific computer, and track how often an ad has been viewed
and by whom. These cookies are linked to a computer and do not gather any User Data about
you.
Analytics Cookies
Analytics cookies monitor how users reached the Site, and how they interact with and move
around once on the Site. These cookies let us know what features on the Site are working the
best and what features on the Site can be improved.
Our Cookies
Our cookies are “first-party cookies” and can be either permanent or temporary. These are
necessary cookies, without which the Site will not work properly or be able to provide certain
features and functionalities. Some of these may be manually disabled in your browser but
may affect the functionality of the Site.

Personalisation Cookies
Personalisation cookies are used to recognize repeat visitors to the Site. We use these
cookies to record your browsing history, the pages you have visited, and your settings and
preferences each time you visit the Site.

Site Management Cookies
Site management cookies are used to maintain your identity or session on the Site so that
you are not logged off unexpectedly, and any information you enter is retained from page to
page. These cookies cannot be turned off individually, but you can disable all cookies in your
browser.

Third-Party Cookies
Third-party cookies may be place on your computer when you visit the Site by companies
that run certain services we offer. These cookies allow the third parties to gather and track
certain information about you. These cookies can be manually disabled in your browser.

Performance and Functionality Cookies
These cookies are used to enhance the performance and functionality of our websites but are
non-essential to their use. However, without these cookies, certain functionality (like videos)
may become unavailable.

Analytics and customisation cookies
These cookies collect information that is used either in aggregate form to help us understand
how our websites are being used or how effective our marketing campaigns are, or to help us
customise our websites for you.

Media cookies
These are cookies that have not yet been categorized. We are in the process of classifying
these cookies with the help of their providers.

What control do I have over cookies?
Most browsers are set to accept cookies by default. However, you can remove or reject
cookies in your browser’s settings. Please be aware that such action could affect the
availability and functionality of the Site. For more information on how to control cookies,
check your browser or device’s settings for how you can control or reject cookies.
What other tracking technologies are there?
In addition to cookies, we may use web beacons, pixel tags, and other tracking technologies
on the Site to help customise the Site and improve your experience. A “web beacon” or “pixel
tag” is tiny object or image embedded in a web page or email. They are used to track the
number of users who have visited pages and viewed emails and acquire other statistical data.
They collect only a limited set of data, such as a cookie number, time and date of page or
email view, and a description of the page or email on which they reside. Web beacons and
pixel tags cannot be declined. However, you can limit their use by controlling the cookies that
interact with them.

What are your rights?
Optifema is subject to global data protection laws. Generally, GDPR is considered to be a gold
standard of Data Protection. Under GDPR, you generally have the following rights, which you
can usually exercise free of charge:
• the right to be informed of the type of PII held relating to you, and how it is
processed;
• the right to require us to correct any mistakes in your User Data (Correction);
• the right to require us to delete your User Data—in certain situations (Erasure);
• the right to require us to restrict use of your User Data in certain circumstances e.g. if
you contest the accuracy of the data (Restriction of use);
• the right to receive the User Data you provided to us, in a structured, commonly used
and machine-readable format and/or transmit that data to a third party—in certain
situations (Data portability);
• the right to object at any time to your User Data being used for direct marketing
(including profiling) or in certain other situations to our continued use of your User
Data, e.g. where we use your User Data for our legitimate interests unless there are
compelling legitimate grounds for the processing to continue or the processing is
required for the establishment, exercise or defence of legal claims (To object to use);
• if you have provided us with a consent to use your User Data you have a right to
withdraw that consent easily at any time. Withdrawing a consent will not affect the
lawfulness of our use of your User Data in reliance on that consent before it was
withdrawn (The right to withdraw consents).

How do I contact and/or make complaints?
With your support Optifema will keep User Data accurate and up-to-date. You may request to
remove, amend or correct your User Data. Please notify us of your wishes to do so, using the
following steps:
Please contact support@optifema.com (or send any post; Optifema Private Medical Limited,
169a Upper Newtownards Road, Belfast, Northern Ireland BT4 3HZ for the attention of the
Data Protection Officer) in for the first instance, if you wish to:
• withdraw your consent;
• ask any questions about this privacy policy or the information that we hold about you;
see your User Data or to exercise any of the rights mentioned previously;
• make a compliant about how we have handled your User Data.
We will do our best to respond to all requests in a timely manner.
If you are not satisfied with our response to any query you raise with us, or you believe we
are processing your User Data in a way which is inconsistent with the law, you can complain
to the ICO office helpline: 0303 123 1113
How long will Optifema store User Data?
In general, Optifema will only store your User Data for as long as it is needed to fulfil the
purposes for which it was collected, subject to applicable data retention periods imposed
upon Optifema by applicable law.
Optifema will not use your Personally Identifiable Information for anything other than that
which you have consented to. We may use what is known as aggregated data, which has
been de-identified for statistical analysis purposes, and such statistics may result in
commercialisation. You are not entitled to any recompense in such circumstances, but rest
assured, any such anonymised statistical use, shall be for the sole purpose of improving
public health.
How will I know whether Optifema has updated its privacy policy?
If Optifema changes its privacy practices, an updated version of this Privacy Policy will reflect
those changes and we will notify you of such changes by updating the effective date at the
top of this Privacy Policy. Without prejudice to your rights under applicable law, Optifema
reserves the right to amend this Privacy Policy from time to time to reflect technological
advancements, legal and regulatory changes and good business practices. Optifema may
email you with notification of any material changes.
Last updated – 31/08/2026