Privacy notice

Who we are

Pathlyn is a software platform that clinics and pharmacy groups use to run their online services: patient portals, health questionnaires, clinical review, prescriptions, payments and pharmacy orders. In this notice “Pathlyn”, “we” and “us” mean Pathlyn Ltd.

You can contact us about privacy at privacy@pathlyn.co.uk.

Our two roles

If you are a patient of a clinic that uses Pathlyn, the clinic is the controller of your personal data. It decides why and how your information is used, including your health information, and its own privacy notice explains this. Pathlyn is the clinic's processor: we hold and process your information on the clinic's behalf, under a written data processing agreement, and only on its instructions.

Requests about your patient record, such as asking for a copy of it, correcting it or asking for it to be deleted, should go to your clinic. If you send one to us, we will pass it to your clinic promptly and help them respond.

Pathlyn is the controller for a smaller set of information: the accounts of clinic staff, enquiries made to us, our customers' billing contacts, and visitors to this website. The rest of this notice is mainly about that information.

Our clinics instruct us to create anonymised, aggregated statistics from the data we hold for them, which we use to run, secure and improve the platform. Anonymised data cannot be used to identify anyone, so it is no longer personal data. We never try to re-identify anyone from it, and we never sell personal data.

Information we are responsible for

Whose information	What we hold	Why we use it	Lawful basis
Clinic staff (administrators, prescribers, operations staff)	Name, work email, role, sign-in records, two-factor authentication enrolment	To provide accounts, control access to patient records and keep the platform secure	Our contract with the clinic you work for, and our legitimate interest in keeping the platform secure
Prescribers	Professional register and registration number, the result of our register check, the signature used on prescriptions	To check that every prescriber is registered and entitled to prescribe before they can do so	Legitimate interests in patient safety, and compliance with the law on prescriptions
People who contact us or request a demo	Name, work email, organisation and your message	To reply to you and follow up your enquiry	Legitimate interests in responding to enquiries
Billing contacts of our customers	Name, email, invoices and payment records	To invoice for our service and keep accounting records	Contract, and legal obligation (tax and accounting records)
Website visitors	Server logs: IP address, browser type, pages requested, date and time	To keep the website running and protect it from attack	Legitimate interests in operating a secure website

Cookies

This website does not use advertising or analytics cookies. Clinic portals use strictly necessary cookies to keep you signed in and to protect sign-in forms. These do not need consent, and the portals do not work without them.

We use a small number of service providers, each under a written contract that requires them to protect the information and use it only to provide their service to us:

Hetzner Online GmbH, which hosts our servers and backups in Germany.
Resend, which delivers our emails. Our emails are notifications and never contain clinical information.

Patients pay for treatment through Stripe, using the clinic's own Stripe account. Stripe processes payment details under its own privacy notice, and we never see or store full card numbers. Medicines are dispensed by the clinic's chosen pharmacy, which receives the prescription and delivery details it needs under its own agreement with the clinic.

We may also share information with professional advisers, or where the law requires it, for example with a regulator or the police. We never sell personal data.

Where information is held

Our platform is hosted in Germany (European Economic Area), with Hetzner Online GmbH. UK law treats the European Economic Area as giving adequate protection to personal data. If a service provider handles personal data outside the UK and the European Economic Area, we only allow it where UK law permits the transfer, for example under UK adequacy regulations or the ICO's International Data Transfer Agreement.

How long we keep information

Patient records: for as long as the clinic instructs us, in line with its own records policy, and then deleted.
Staff accounts: while the account is active, then for six years after it closes, because records of who accessed and changed clinical records must remain available.
Enquiries: for two years after our last contact, unless they become a customer relationship.
Invoices and payment records: for six years, as tax law requires.
Website server logs: for 90 days.

How we protect information

Each clinic's patient records are kept in a separate store, and every request is checked against the clinic and the person's role before any record is shown. Staff must use two-factor authentication. Information is encrypted in transit, backups are encrypted, and clinical and administrative actions are recorded in audit logs. Pathlyn's own administrators cannot open patient records.

Your rights

You have the right to ask for a copy of your personal data, to have it corrected, to have it deleted, to restrict or object to how it is used, and to receive it in a portable format. Some rights apply only in certain circumstances.

For information we are responsible for, contact privacy@pathlyn.co.uk. For your patient record, contact your clinic. We will respond within one month.

Complaints

Please tell us first if you are unhappy with how we have handled your information, at privacy@pathlyn.co.uk. You can also complain to the Information Commissioner's Office at ico.org.uk or on 0303 123 1113.

Changes to this notice

We will update this notice when the way we handle personal data changes. The version and date at the top show which version you are reading.