Legal
Privacy Policy
Effective date: 3 October 2026
1. Who we are
This Privacy Policy explains how PharmMentor handles personal information when you visit our website, create a free sample account, purchase a subscription, use our learning resources or contact us. PharmMentor is operated by [full legal name], trading as PharmMentor. That business is the data controller: it decides why and how your personal information is used. Business address: [full postal address] Privacy contact: privacy@pharmmentor.co.uk You can contact us using these details or our Contact page. Our Terms and Conditions govern accounts and subscriptions; our Cookie Policy explains cookies and similar technologies. This policy explains our use of information; it does not obtain blanket consent. We request consent separately where required.
2. Information we collect and its sources
You can browse public pages without registering, but visits still generate technical information. IP addresses and device identifiers can be personal information even without your name. The information we handle depends on the features you use and includes the following categories. Account and profile information: your name, email address, username or account identifier, sign-in and verification information, account creation date, settings and preferences. Registration details may include your university, graduation year and how you heard about us. Learning activity: questions attempted, answers selected, correct and incorrect responses, topics studied, attempt dates, scores, mock-assessment results, flashcard activity and progress. Where supported by the features you use, this includes confidence ratings, bookmarks, revision notes, study streaks and time spent on questions or topics. Free sample activity is recorded in the same way as relevant paid activity. Subscription and transaction information: your plan, billing period, access and renewal dates, order and Stripe customer references, amounts, payment status, invoices, refunds, cancellations, discounts and relevant billing or tax details. Stripe provides transaction updates and limited payment-method information, such as card brand and last four digits, where applicable. Full card details are collected through Stripe; do not send card numbers or security codes in support messages. Feedback and communications: enquiries, complaints, bug reports, question feedback and any optional survey responses or testimonials you submit, together with replies and relevant account details. Question feedback can include the question identifier, answer selected, attempt details, technical information and attachments you choose to provide. Screenshots may reveal personal information, so remove unrelated details before sending them. Technical and security information: IP address, browser and device type, operating system, session identifiers, sign-in and access times, and security or error logs. Page views, links clicked, approximate location derived from IP address, referral sources and other analytics are handled only as explained in our Cookie Policy and subject to the applicable choices. Preferences and communication records: privacy and marketing choices, consent and withdrawal records, checkout acknowledgements, email delivery records and any permitted engagement information described in section 6. Misuse-related information: relevant account, payment and usage records, reports, correspondence and evidence needed to investigate suspected fraud, account sharing, unauthorised copying or distribution, or security incidents. Reports may include screenshots or copies of shared material. We assess allegations rather than treating a report as proof of misconduct. We obtain information directly from you, from activity on PharmMentor and from providers operating relevant services, including Stripe. We may also receive information from someone reporting suspected misuse or review relevant publicly available material, such as a post offering copies of our content. We provide any further source information required by law. Required fields are identified when information is collected. Without information needed for an account or purchase, we may be unable to provide the requested service. Optional profile details, feedback, surveys and marketing choices are not conditions of purchase. We explain the purpose of any survey when inviting you to take part. We do not require medical histories to provide revision access. Do not submit identifiable patient information, confidential workplace records or unnecessary sensitive information. Removing a name may not fully anonymise a clinical example; fictional examples are preferable for support enquiries. For accessibility requests, describe the assistance needed rather than sending medical records. If health or other specially protected information is necessary, we explain its purpose and use it only with both a lawful basis and an additional special-category condition, such as explicit consent where appropriate. Unnecessary sensitive material is restricted and may be deleted or redacted. Sending it to us does not, by itself, give explicit consent to other uses.
3. Why we use information and our lawful bases
We use personal information only where a lawful basis applies under UK data protection law. The table explains the purposes and bases for our current service. Section 4 describes the planned AI feature separately. Create and manage free and paid accounts; provide resources, mark answers, record progress and operate spaced repetition. Uses account and learning records. Lawful basis: Contract: providing the account and learning services you request. Process purchases, renewals, cancellations and refunds; provide subscription support and essential service messages. Uses account, transaction and correspondence records. Lawful basis: Contract, including steps you request before purchase. Meet accounting, tax and other legal duties; handle data-rights requests and privacy complaints. Uses records needed for the relevant duty. Lawful basis: Legal obligation. Maintain security, resolve technical problems, investigate fraud or content misuse, enforce lawful terms and establish or defend legal claims. Uses relevant account, transaction, usage and evidence records. Lawful basis: Legitimate interests in protecting users, operating a reliable service and protecting our rights. Improve resources, analyse question difficulty, investigate feedback and calculate cohort comparisons. Uses learning records and feedback, with identifying details minimised. Lawful basis: Legitimate interests in improving our revision resources and providing useful comparative statistics. Respond to general enquiries, feedback and optional surveys outside a contract. Uses contact details and relevant submissions. Lawful basis: Legitimate interests in responding to enquiries and understanding feedback about our service. Send promotional emails or publish an identifiable testimonial. Uses information explained when the choice is offered. Lawful basis: Consent. For qualifying emails about our own similar services, legitimate interests may apply under the limited exception in section 6. Testimonials require separate consent. Use optional analytics or tracking that requires permission. Uses the technical information described in our Cookie Policy. Lawful basis: Consent. Any applicable exception and associated lawful basis are explained in our Cookie Policy before use. Where we rely on legitimate interests, we assess necessity and balance those interests against your rights and reasonable expectations. You can object as explained in section 11. Records containing allegations of criminal offences are processed only where an applicable additional legal condition also permits this.
4. Learning records, statistics and planned AI
Account-linked answers and results are personal information about your learning. They are not automatically health data because a question concerns a medical condition. We use study records to support revision, not to infer your own health. Automated marking, progress summaries and spaced repetition use your answers and flashcard activity to organise revision. Tailoring revision using recorded performance is a form of learning-related profiling. It does not determine official assessment results or professional registration. We do not use learning scores to make solely automated decisions with legal or similarly significant effects. You can request human review of a recorded result or account restriction through our contact details. We use combined results to understand question difficulty, improve materials and display cohort comparisons without revealing individual learning histories. We limit or withhold comparisons where small groups could expose individual results. Replacing a name with an account code is pseudonymisation, not anonymisation: identifiable records remain protected. We treat information as anonymous only where people cannot reasonably be identified, including through combination with other available information. AI-assisted flashcards are in development and are not currently available. The planned feature would use questions you have answered incorrectly within a topic, including repeatedly missed questions, to generate targeted flashcards for you to choose to study in your dashboard. It is not a chatbot and does not provide a facility for entering AI prompts. Before using account information for this feature, we will explain the data used, lawful basis, generation process, user controls, any AI providers, retention and overseas processing. We will obtain consent where required. Generating revision flashcards is distinct from training or improving a general-purpose AI model. The planned feature does not give AI providers unrestricted permission to reuse your learning records for their own purposes.
5. Who receives your information
Authorised staff and contractors access information where needed for their work. Providers support hosting, databases, authentication, backups, payments, email delivery, support and security. Analytics or marketing providers receive information only for the purposes and under the choices described in this policy and our Cookie Policy. Processors act on our documented instructions under appropriate contracts, including confidentiality and security requirements. Independent controllers determine certain purposes themselves and have their own privacy responsibilities. Stripe processes payments and manages subscriptions. It receives information needed for checkout, billing, fraud prevention and related obligations, including payment-method and device information. We receive transaction, subscription and limited payment-method records. Stripe acts as a processor for some activities and an independent controller for others. Its own uses and international processing are explained at https://stripe.com/gb/privacy. Where necessary, we may share relevant information with professional advisers, accountants, insurers, payment-dispute parties, courts, law enforcement or regulators. A legal obligation supports a required disclosure; otherwise, we assess the applicable lawful basis, necessity, proportionality and safeguards before sharing. Serious misuse: where individually assessed as lawful, necessary and proportionate, relevant evidence may be shared with an appropriate professional regulator, such as the General Pharmaceutical Council (GPhC) or Pharmaceutical Society of Northern Ireland (PSNI), or an education or training provider, employer or supervisor with a legitimate role in the matter. Routine learning results are not shared with these organisations. An account-sharing alert, low score or allegation does not automatically result in a report. Any criminal-offence information requires an applicable additional legal condition. Relevant records may be shared with advisers and a prospective or new operator during a business sale or reorganisation, with confidentiality and data-protection safeguards. We will explain any material change to the controller. We do not sell personal information or provide mailing lists to other businesses for their own marketing. Private notes and support submissions are not public posts. We seek separate consent before publishing an identifiable testimonial.
6. Service messages and marketing
We send messages needed to operate your account and subscription, such as verification, password resets, security alerts, receipts, renewal notices and support replies. These are separate from promotional emails. Optional study reminders, where offered, follow the preferences explained when you enable them. Promotional emails are sent with consent, or under the limited existing-customer exception where all its conditions are met: we obtained your details directly during a sale or genuine negotiations, promote our own similar services, and offer an opt-out when collecting your details and in each message. A free account or acceptance of the terms is not, by itself, marketing consent. You can stop direct marketing at any time through the unsubscribe link or our privacy contact. We retain a minimal suppression record to honour your choice. Unsubscribing does not prevent necessary account or billing messages. [Specify whether emails use open or click tracking. Identify any provider, information collected, purpose and available controls, or state that this tracking is not used.] Any email tracking subject to consent is used only after that consent has been obtained. Permission to send a promotional email does not, by itself, authorise tracking technologies within it.
7. Cookies and external websites
Cookies and similar technologies support functions such as sign-in, security, billing and preferences. Our Cookie Policy identifies the technologies actually used, providers, purposes, durations and controls. Technologies requiring consent are not used until consent is obtained, and you can change your choice through the controls described there. Strictly necessary technologies may operate without consent. Any other exception must meet its conditions and be explained in our Cookie Policy, with an easy, free way to object where required. Browser settings may also block cookies, although this can affect essential functions. External reference links take you to independently operated websites with their own privacy arrangements. They may receive your IP address, browser information and the referring page address, depending on your browser and our link settings. We do not add your name, account identifier or answer history to reference links.
8. International processing
Our UK focus does not mean that all personal information stays in the UK. Providers may use overseas infrastructure, personnel or support. Stripe’s privacy information explains its own international arrangements. [Insert the actual overseas processing and access arrangements: relevant provider or recipient category, destination countries, and the applicable UK adequacy decision or safeguards. Include onward processing by providers acting on our instructions.] For restricted transfers, we use applicable UK adequacy arrangements or appropriate safeguards, such as the UK International Data Transfer Agreement or UK Addendum to the EU standard contractual clauses, with the required assessment and additional protections. Contact us for information or a copy of relevant safeguards, subject to necessary redactions protecting confidential information and other people.
9. Retention and account deletion
We keep personal information only for as long as needed for the relevant purpose. Retention depends on the record, account activity, legal duties, disputes and documented security needs. Account and learning records: kept while your account is active. Ending a paid subscription does not delete an account retained for free access. We review inactive accounts after [inactivity review period]. After account closure, records no longer needed are normally deleted or anonymised within [live-system deletion period], subject to the limited retention below. Payment and legal records: accounting and tax records are normally kept for [retention period and starting point applicable to the legal operator]. Records needed for a specific claim or dispute are kept for the relevant legal period. This does not justify keeping an entire learning history alongside financial records. Support correspondence: normally kept for [period after resolution]. Information needed for a continuing dispute or legal duty is retained for that purpose and reviewed afterwards. Security and technical logs: normally kept for [routine log-retention period]. Relevant evidence may be retained longer for a specific incident, documented abuse prevention or legal claim, and reviewed when that need ends. Preferences and consent records: kept while needed to act on or demonstrate your choices. A minimal suppression record may be kept while we carry out marketing to respect an opt-out. Backups: deleted information may remain in restricted backups until overwritten within [backup-retention period]. It is not used for ordinary operations; if restoration is necessary, applicable deletion instructions are reapplied. You can request account closure or deletion using our contact details. Closing an account stops future subscription renewals in accordance with our Terms and Conditions. Where deletion would affect paid access or saved progress, we explain the consequences. We explain any limited records retained and why. Genuinely anonymous statistics may be kept because they no longer identify anyone.
10. Protecting information
We use technical and organisational measures appropriate to the risks, including limiting access to people who need it, requiring confidentiality and assessing providers. Suspected incidents are investigated and handled through appropriate response procedures. We notify the relevant authority and affected people where the law requires it. Keep your login details secure, do not share passwords and report suspected unauthorised access promptly. Avoid including passwords or full payment-card details in support messages.
11. Your data-protection rights
Depending on the circumstances, you can request access, correction, deletion, restriction of processing and a portable copy of information you provided where the legal conditions apply. You can withdraw consent at any time without affecting the lawfulness of earlier processing. Update account details through available settings or contact us for help. Your right to object You can object to processing based on legitimate interests for reasons relating to your situation. We will stop unless we demonstrate compelling legitimate grounds overriding your interests, rights and freedoms, or the information is needed for legal claims. You have an unconditional right to stop the use of your information for direct marketing, including related profiling. Contact us using section 1; no particular form or legal wording is required. We may ask for proportionate information to verify identity or clarify a request. We normally respond without undue delay and within one calendar month. Where legally permitted for complex or multiple requests, we may extend this by up to two further months, explaining the reasons within the initial month. We explain any other lawful adjustment to the response period. Requests are normally free. Any fee, refusal, restriction or continued retention must be permitted by law, and we explain the reason and how to challenge it. You do not need a paid subscription to exercise privacy rights.
12. Privacy complaints
You can complain about our handling of personal information using our privacy contact, Contact page or postal address. We acknowledge privacy complaints within 30 days, investigate and respond without undue delay, keep you informed and explain the outcome. A complaint does not have to use a particular form. You can also complain to the Information Commissioner’s Office (ICO), the UK data-protection regulator. The ICO normally expects you to raise the concern with the organisation first. Its complaint guidance and contact routes are available at https://ico.org.uk/make-a-complaint/.
13. Children and future policy updates
PharmMentor is intended for adults aged 18 and over and is not designed for children. Free accounts and paid subscriptions are not offered to people under 18. Please contact us if you believe an under-18 account has been created, so that we can investigate and deal with the information appropriately. We may update this policy as our service or legal requirements develop. We show the effective date above and bring material changes to your attention where required. Before using information for a new purpose, we provide the relevant information and establish a lawful basis. Continued website use does not, by itself, give consent to a new use.