Privacy and Cookies Policy

This is the Privacy and Cookies Policy for the Oncodemia Platform at www.oncodemia.com (the "Platform") and the separate Community Cancer Champion web application and charter at apply.unifyhealth.app (the "Application Site"). The Platform and Application Site are operated by or on behalf of Accord Healthcare Limited ('we', 'us' or 'our').

This policy sets out how we collect and use your personal data in connection with operation of the Platform.

This policy covers:

We are committed to protecting and respecting your privacy. Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it.

By accepting our services and using the Platform and Application Site you acknowledge you have read and understood this privacy policy.

For the purposes of United Kingdom and European Economic Area data protection laws, (the "Data Protection Law"), the data controller is: Accord Healthcare Limited of Sage House, 319 Pinner Road, North Harrow, Middlesex, HA1 4HF.

Information we collect about you and how we use it

We will collect and process the following personal data from you:

Information you give us

This is information about you that you give us directly when you interact with us by filling in forms on the Platform or Application Site or by corresponding with us by phone, e-mail or otherwise. It includes information to:

  • Register to use the Platform.
  • Complete the Application and sign the Charter Commitments in order to be designated a Community Cancer Champion (the "Application") for presentation within the pharmacy locator in the separate Unify Health App.
  • Participate in a Platform promotion or survey, submit a query, or if you report a problem with the Platform or Application Site.
Find out more
The information you give us may include:
  • Identity information your name, username and chosen password;
  • Contact information your e-mail address, city/town and country of residence
This is so we can create your account and identify you when you log in to the Platform or verify your Application against your existing Oncodemia account.

  • Professional Profile information: information relevant to your Application when you complete this and which includes:

    Your country of employment, job role, professional registration number(s), whether you are a locum pharmacist or not, other qualifications, work location, pharmacy name, address, website, a profile picture, (if you choose to share one) and a short statement on areas of expertise for you or your pharmacy to help cancer patients on the separate Unify Health App to refine their search.

    Your completed profile from your Application helps cancer patients using the separate Unify Health Application to more easily locate you.

Information we collect about you from your use the Platform

We will automatically collect information from you each time you visit the Platform or Application Site. This includes:
  • Technical information - associated with your device and browser.
  • Session information - from your interaction with the platform.
  • Certification information - about your engagement with the Oncodemia Platform course content and Application certification status.
  • Location data
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  • Technical information will include the Internet protocol (IP) address used to connect your computer to the Internet, your login information, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform;
  • Session information about your visit may include the full Uniform Resource Locators (URL), clickstream to, through and from our Platform (including date and time), items that you viewed or searched for, page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), methods used to browse away from the page, and any phone number used or social media handle used to connect with our support team.
  • Certification information including the modules taken and completed, the answers you give to "knowledge check" tests case studies and / or exams within the Platform, Platform learning resources consulted, any notes you make on the training and information relating to Common Professional Development (CPD) you may have undertaken.
  • Location information: relevant to identifying the location from which you are accessing the Platform in order that we can take steps to reflect Platform content relevant to applicable local regulatory requirements and to understand at an aggregate level the locations of users accessing our services.

Information we receive from other sources.

This is information we receive about you or your pharmacy, in particular:
  • Professional profile information – about your pharmacy to supplement your Application profile.
  • If you or your pharmacy uses any of the other websites or apps we operate or the other services we provide.
  • From third parties we work closely with.
Find out more
  • Professional profile information your Application will be supplemented with further information from your Pharmacy's Google profile, such as opening times, exterior photos, number of pharmacists in the pharmacy. You should check this information is up to date at https://business.google.com/create.
  • If you use any other of our sites and services, the strength of your relationship with us may reflect in how your profile is ranked within the pharmacy locator available to users of the separate Unify Health App.
  • We are working closely with third parties (including, for example, business partners, sub-contractors in technical, services, analytics providers, and search information providers). We will notify you when we receive information about you from them and the purposes for which we intend to use that information.
You can see a full list of the types of data we process, the purpose for which we process it and the lawful basis on which it is processed at the end of this policy.

Cookies and other technologies

The Platform uses cookies and/or other similar technologies to collect and store certain information. These typically involve pieces of information or code that a website transfers to or accesses from your computer hard drive or mobile device to store and sometimes track information about you. Cookies and similar technologies enable you to be remembered when using that computer or device to interact with websites and online services and can be used to manage a range of features and content as well as storing searches and presenting personalised content.

The Platform uses cookies and similar technologies to distinguish you from other users of the Platform. This helps us to provide you with a good experience when you browse our site and also allows us to improve the Platform.

Most web browsers automatically accept cookies and similar technologies, but if you prefer, you can change your browser to prevent that and your help screen or manual will tell you how to do this. We also give you information about how to disable cookies. However, you may not be able to take full advantage of our website if you do so.

A number of cookies and similar technologies we use last only for the duration of your web session and expire when you close your browser. Others are used to remember you when you return to the Platform and will last for longer.

We use these cookies and other technologies on the basis that they are necessary for the performance of a contract with you, or because using them is in our legitimate interests (where we have considered that these are not overridden by your rights), and, in some cases, where required by law, where you have consented to their use.

Find out more
We use the following types of cookies:
  • Strictly necessary cookies. These are cookies that are required for the operation of our platform session and under our terms with you. They include, for example, cookies that enable you to navigate and log into secure areas of our Platform.
  • Functional cookies – you can choose to enable a cookie so that the platform remembers your username when you next sign in.
  • Analytical/performance cookies. They allow us to recognize and count the number of visitors and to see how visitors move around our website when they are using it. This helps us improve the way our website works, for example, by ensuring that users are finding what they are looking for easily.

Disabling cookies

The effect of disabling cookies depends on which cookies you disable but, in general, the Platform may not operate properly if all cookies are switched off.

If you want to disable cookies on our site, you need to change your website browser settings to reject cookies. How you can do this will depend on the browser you use.

Further details on how to disable cookies for the most popular browsers are set out below: -

For Microsoft Internet Explorer:

  1. Choose the menu “tools” then “Internet Options”
  2. Click on the “privacy” tab
  3. Select the setting the appropriate setting

For Google Chrome:

  1. Choose Settings then Advanced
  2. Under "Privacy and security," click “Content settings”.
  3. Click “Cookies”

For Safari:

  1. Choose Preferences then Privacy
  2. Click on “Remove all Website Data”

For Mozilla firefox:

  1. Choose the menu “tools” then “Options”
  2. Click on the icon “privacy”
  3. Find the menu “cookie” and select the relevant options

For Opera 6.0 and further:

  1. Choose the menu Files then “Preferences”
  2. Privacy
Where you have not set your permissions, we may also separately prompt you regarding our use of cookies on the Platform.

You can find more information about the individual cookies we use and the purposes for which we use them below.

Cookie Name Purpose and lawful basis More information
Session cookie TotaraSession MoodleSessionXXX This cookie is essential in our legitimate interests for the operation of our Platform. It remembers you as the same user as you navigate the platform.
User id cookie Totara MOODLEID1_XXX If selected by the user and on the basis of their consent, this cookie enables the user's username to be remembered at sign-in.
Universal Analytics Google _ga _ gali _ gat _gid These cookies collect, with your consent, information about how visitors use our platform. We use information to compile reports to understand how users interact with the platform and so we can make improvements. The cookies collect information in a way that does not directly identify anyone, including the number of visitors to the platform, where visitors have come to the platform from and the pages that are visited. See Google's Safeguarding your data overview https://support.google.com/analytics/answer/6004245 opt-out https://support.google.com/analytics/answer/181881?

Our promotional updates and communications

Where permitted in our legitimate interest or with your prior consent where required by law, we will use your personal information for marketing analysis and to provide you with promotional update communications by email. Please refer to the 'Your rights' section of this policy if you wish to change your direct marketing and contact preferences.

Who we give your information to

The aim of the Platform is to provide training and resources related to helping patients with cancer care in the community. The Application Site enables pharmacists who have completed an appropriate training programme such as on the Platform or other appropriate post-graduate training, to apply through the Application Site to make themselves available to cancer patients in their community by sharing professional and pharmacy details. The patients will access Google maps information for the location of the pharmacy that successful applicants work at and associated information shared through the Application.

We may share your information with:
  • Any member of our group, which means our subsidiaries, our ultimate parent company and its subsidiaries, who support our processing of personal data under this privacy policy. To see a full list of such companies please click here. If any of these parties are using your information for direct marketing purposes, we will only transfer the information to them for that purpose with your prior consent.
  • Selected third parties such as suppliers who provide us services for the proper rendering of the services we provide.
  • Public bodies and authorities (administrative or judicial) in cases where a legal obligation applies.
Find out more

Our selected third parties may include:

  • Organizations who process your personal data on our behalf and in accordance with our instructions and the Data Protection Law. This includes in supporting the services we offer through the Platform and Application Site in particular those providing website and data hosting services, providing fulfilment services, distributing any communications we send, supporting or updating marketing lists, facilitating feedback on our services and providing IT support services from time to time. These organizations (which may include third party suppliers, agents, sub-contractors and/or other companies in our group) will only use your information to the extent necessary to perform their support functions.
  • Advertisers . We do not disclose information about identifiable individuals to our advertisers, but we may provide them with aggregate information about our users to explain our platform to potential partners.
  • Analytics and search engine providers that assist us in the improvement and optimization of our Platform and subject to the cookie section of this policy (this will not directly identify you as an individual).
We may disclose your personal information to third parties:
  • In the event that we sell or buy any business or assets, in which case we will disclose your personal data to the prospective seller or buyer of such business or assets subject to the terms of this privacy policy.
  • If Accord Healthcare Limited or substantially all of its assets are acquired by a third party, in which case personal data held by it about Platform and Application Site users will be one of the transferred assets.
  • If we are under a duty to disclose or share your personal data in order to comply with any legal obligation, or in order to enforce or apply our terms of supply terms and other agreements with you; or to protect the rights, property, or safety of Accord Healthcare Limited our users, or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection and to prevent cybercrime.

Where we store your information

The Platform, Application Site and associated data collected from you is hosted on servers in Europe. We may on occasion, also use service providers or collaborate with our group companies to whom personal data may be transferred to, and stored at, a destination outside the European Economic Area ("EEA") and that may not be subject to equivalent Data Protection Law.

Where your information is transferred outside the EEA, we will take steps to ensure that your data is subject to appropriate safeguards, such as relying on a recognised legal adequacy mechanism, and that it is processed securely and in accordance with this privacy policy.

Find out more

We may transfer your personal information outside the EEA:

  • In order to support the operation of the services provided through the Platform and the Application Site
  • Where we are legally required to do so.
  • In order to facilitate the operation of our group of businesses, where it is in our legitimate interests and we have concluded these are not overridden by your rights.
Where we transfer your personal information to a jurisdiction not subject to a legal adequacy finding, we will take steps to ensure an appropriate legal adequacy safeguard is in place which usually means, use of specific approved contracts that rely upon standard contractual clauses (scc)s for the protection of personal data.

For further information on transfers outside of the EEA and/or specific safeguard methods adopted, please contact [email protected].

Child Safety

Protecting the safety of children when they use the Internet and online services is important to us. The Platform and Application Site are intended for use only by persons who are at least 18 years of age. By using either, you confirm to us that you meet this requirement. If we establish by way of a notification to [email protected] that any information we collect has been provided by a child under 18 we will take steps to close that account.

How we protect your information

All information you provide to us is stored on secure servers. Where you have chosen a password, which enables you to access certain parts of the Platform, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.

Unfortunately, the transmission of information via the internet is not completely secure. We will do our best to protect your personal data including encryption of data in transit and encryption at rest for non-live systems (including backups). Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access.

Our Platform and the Application Site may, from time to time, contain links to third party external sites. We are not responsible for the privacy policies or the content of such sites and do not accept any responsibility or liability for those policies or your use of those sites.

The Platform and Application Site do not process personal data for the purpose of automated decision making that has any legal effect or significantly affects you.

How long we keep your information

We retain personal data for as long as you use the Platform and have an account with us or as necessary to administer your Application or for the term of your valid Community Cancer Champion designation and in each case, for period after this to anticipate and resolve any legal issues or claims.

We may also retain aggregate information beyond this time for research purposes and to help us develop and improve our services. You cannot be identified from aggregate information retained or used for these purposes.

Your rights

You have the right under certain circumstances:
  • to be provided with a copy of your personal data held by us;
  • to request the rectification or erasure of your personal data held by us;
  • to request that we restrict the processing of your personal data (while we verify or investigate your concerns with this information, for example);
  • to object to the further processing of your personal data, or to object to marketing and any profiling relating to such marketing (as mentioned in 'Our promotional updates and communications' section by selecting the "unsubscribe" link at the end of all our marketing and promotional update communications to you, or by sending us an email

    In respect of the Platform to [email protected] or
    In respect of the Aplication Site to [email protected]

  • to request that your provided personal data be moved to a third party
  • not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning you or that similarly significantly affect you (note, as stated above, the Platform and Application Site do not use personal data to make such automated decisions).

Your right to withdraw consent:

Where the processing of your personal information by us is based on consent, you have the right to withdraw that consent without detriment at any time. You can also change your marketing preferences at any time as described in 'Our promotional updates and communications' section;

Where we receive a request to exercise one of the above rights, we will normally respond within one month. This may be extended by up to two further months in cases where requests are complex or numerous and where such an extension is permitted by Data Protection Law. Where that is the case we will inform you within one month of any extension and the reason for this.

You can also exercise the rights listed above at any time by contacting us at
Platform - [email protected]
Application Site - [email protected]

If your request or concern is not satisfactorily resolved by us, you may approach your local data protection authority competent in your country. You will find the contact details by entering the following link: Data Protection Authorities - European Commission (europa.eu)

Changes to this policy

Any changes we make to our privacy policy in future will be posted on this page and, in relation to substantive changes, will be notified to you by e-mail. This policy was last reviewed and updated in August 2021.

Contact Us

Questions, comments and requests regarding this privacy policy are welcomed and should be addressed for the attention of our European Representative to:

Oncodemia Platform Email: [email protected]
Application Site - Email: [email protected]

Post: Accord Healthcare Limited Sage House 319 Pinner Road North Harrow, Middlesex HA1 4HF

Purpose and lawful basis for processing of personal data

This table sets out:
  • What personal data we process
  • What we use that data for
  • The lawful basis for the processing
It forms part of our privacy policy which you should also read.
Purpose/Activity Type of data Lawful basis for processing including basis of legitimate interest
To register you as a new user of the Platform and to administer your Application profile. (a) Identity (b) Contact (c) Professional profile 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 (b) Asking you to leave a review or take a survey (a) Identity (b) Contact (c) Professional profile (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 pharmacists use our services)
To provide you with training and resources and issue CPD points (where applicable) and certificate upon completion of the Platform training (a) Identity (b) Certification (c) Professional profile (a) Performance of a contract with you (b) Necessary for our legitimate interests (to keep our records updated)
To administer your Application to make yourself available to cancer patients in your area (a) Identity (b) Contact (c) Professional profile Necessary for our legitimate interests (being the aim of equipping community pharmacists to provide additional, informed support and resources to cancer patients
To enable you to partake in a promotion or complete a survey (a) Identity (b) Contact (c) Professional profile (d) Usage (e) Marketing and Communications (a) Performance of a contract with you (b) Necessary for our legitimate interests (to study how customers use our products/services, to develop the
To administer and protect our business and the Platform and Application Site (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 business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise) (b) Necessary to comply with a legal obligation
To allow you to participate in interactive features of our service, when you choose to do so. a) Identity (b) Contact (c) Profile (d) Usage Necessary for our legitimate interests (to provide interactive features)
To deliver relevant Platform online content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you (a) Identity (b) Contact (c) Profile (d) Usage (e) Marketing and Communications (f) Technical Necessary for our legitimate interests (to study how pharmacists use our products/services, to develop them, to grow our business and to inform our marketing strategy)
To use data analytics to improve our Platform products/services, marketing, customer relationships and experiences (a) Technical (b) Usage Necessary for our legitimate interests (to define types of users for our products and services, to keep our Platform updated and relevant, to develop our business and to inform our marketing strategy)
To make suggestions and recommendations to you about goods or services that may be of interest to you (a) Identity (b) Contact (c) Technical (d) Usage (e) Professional profile Necessary for our legitimate interests (to develop our products/services and grow our business)