Privacy policy

Healthxchange Ireland Limited
Last updated: June 2026

Healthxchange Ireland Limited (“We”, “Us”, “Our”) Privacy Policy. This is Our Privacy Policy which details how We use your personal data (“Personal Data”) when you use Our Website https://healthxchange.ie. We take Our data protection responsibilities seriously.

1. Privacy Policy

1.1 This Website is owned and operated by Healthxchange Ireland Limited, a company registered in Ireland (company number [insert], registered office [insert Irish address]), which is the data controller responsible for personal data collected through this Website. Healthxchange Ireland Limited is part of the Healthxchange Group and is a subsidiary of Pharma-e Limited (Guernsey). Healthxchange Ireland Limited is registered with the Irish Data Protection Commission under reference 15669/A.

1.2 We process your personal data in accordance with the EU General Data Protection Regulation (GDPR) and the Irish Data Protection Acts 1988–2018. Where data is shared within the Healthxchange Group, it may also be subject to the Data Protection (Bailiwick of Guernsey) Law 2017 and UK data protection law.

1.3 This Privacy Policy sets out the way We will obtain and hold your Personal Data. This is known as “Processing”. When read together with Our Terms and Conditions of Use and Cookie Policy, this Privacy Policy covers Our relationship with you in relation to this Website. By continuing to browse and use this Website, you agree to this Privacy Policy. If you disagree with any part of it, please do not use Our Website.

1.4 Any questions, comments and requests you may have regarding this Privacy Policy are welcomed and should be addressed to our Data Protection Officer at dpo@healthxchange.com, or by writing to the Data Protection Officer, Healthxchange Group, Albert House, South Esplanade, St Peter Port, Guernsey, GY1 1AJ.

2. Data Protection Regulations

2.1 For the purposes of this Privacy Policy:

  1. We determine the purposes for which and the manner in which your personal data is, or is to be, processed, and we are known as the data controller (“Data Controller”);
  2. in submitting your data and information to us to collect, handle and process, you will be the individual who is the subject of the data (the “Data Subject”); and
  3. in processing your data and information, any other parties contracted to process data by the Data Controller will be known as (“Data Processors”).

3. What information do We collect from you?

3.1 We may collect and process the following information that you give us when you set up a trade account, complete our customer verification checks, place an order, or otherwise correspond with us by phone, email or otherwise:

  1. business contact details, including your name, job title, business address, email address and telephone number;
  2. business identifiers, including VAT number and company registration number;
  3. verification information for the individual responsible for the account, including a copy of photographic identification, professional registration number and regulatory body details;
  4. recordings of phone calls to our offices or Customer Service Centre, as well as other communications such as email and electronic messaging, which may be used for staff training and audit purposes.

3.2 The information we collect at clause 3.1 is personal data. We do not collect or process special category health data, or any patient or prescription data, through this Website, which is for wholesale business-to-business trade customers only.

3.3 We will collect and process the following data automatically from your visit to Our Website:

  1. technical information, including the internet protocol (IP) address used to connect your device to the Internet, your login information, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform;
  2. information about your visit, including the full uniform resource locator (URL), clickstream to, through and from Our Website, products you viewed or searched for, page response times, download errors, length of visits to certain pages, page interaction information, methods used to browse away from the page, and any phone number used to call Our customer service number.

3.4 This Website is intended for business and trade customers only. It is not directed at consumers or children, and we do not knowingly collect personal data relating to children.

4. Cookies

4.1 Cookies are small files placed on your device when you visit Our Website. We use them to operate the Website, remember your preferences and, where you allow us to, measure how the Website is used.

4.2 Strictly necessary cookies are essential for the Website to function and are always active. Non-essential cookies are only set after you have given your prior opt-in consent through the cookie banner that appears when you first visit the Website.

4.3 You are not obliged to accept non-essential cookies, and you can still use the Website if you decline.

4.4 You can change or withdraw your consent at any time, free of charge, by selecting Cookie settings [insert link] to reopen the cookie preferences panel. You may also control cookies through your browser settings.

4.5 Our use of cookies complies with the European Communities (Electronic Communications Networks and Services) (Privacy and Electronic Communications) Regulations 2011 and the GDPR. Further detail on the specific cookies We use, including their purpose and duration, is set out in Our Cookie Policy [insert link].

5. How do We use the information?

5.1 We shall use the data and information you give to Us:

  1. to set up and manage your trade account and verify your eligibility to purchase from us;
  2. to process, fulfil and dispatch your orders;
  3. to keep and maintain Our internal business records;
  4. for our internal training purposes;
  5. where you have consented, to provide you with Our own marketing information that We think may suit your interests and needs;
  6. where you have consented, to provide you with marketing and promotional information from carefully restricted third-party suppliers and manufacturers that We think may suit your interests and needs.

5.2 We reserve the right to add to the list of uses in clause 5.1. We shall not use pre-collected data and information for any new uses of your data without consulting you and obtaining your express consent where required under the Regulations.

5.3 Where you provide us with information for the purposes of setting up your trade account and placing orders, We may use such information in order to verify the information provided, carry out our customer verification checks, and process your account and order.

5.4 We reserve the right to anonymise your data to obtain analysis while retaining your privacy.

5.5 Our lawful bases. We only process your personal data where we have a lawful basis to do so under Article 6 of the GDPR. We do not process special category data through this Website, so no Article 9 condition is required.

Purpose Lawful basis
Setting up and managing your trade account Performance of a contract, or steps prior to entering a contract
Processing, fulfilling and dispatching your orders Performance of a contract
Verifying your eligibility to purchase from us Legal obligation and legitimate interests
Keeping and maintaining our business records Legal obligation and legitimate interests
Internal training Legitimate interests
Sending you our own marketing Consent
Sharing your data with third parties for their marketing Consent

6. How do We handle your information?

6.1 The data and information We collect from you will be transferred to and securely stored by our hosting third party: Clarity Limited, PO Box 176, Cirrus House, Garenne Park, Rue de la Gache, St Sampson, Guernsey GY1 3LQ.

6.2 We are committed to ensuring that your data and information is secure. We have put in place suitable physical, electronic and managerial procedures to safeguard and secure the information We collect online.

6.3 We store customer verification information, including any copy of photographic identification, securely, and use it only to verify your account and your eligibility to purchase from us.

6.4 Your personal data may be transferred to and stored by other members of the Healthxchange Group and their service providers in Guernsey and the United Kingdom. Where we use service providers located elsewhere outside the European Economic Area, we ensure an appropriate safeguard is in place, such as Standard Contractual Clauses approved by the European Commission.

6.5 We keep your personal data only for as long as necessary for the purposes for which it was collected. Customer verification records are retained for 6 years, and order processing records are retained for 16 years. When your personal data is no longer required, it is securely deleted or anonymised.

7. To whom may We disclose your information?

7.1 In providing us with data and information, you agree that We may disclose such information, where necessary for the purposes and uses listed in clause 5, to:

  1. Our employees, agents, representatives and Data Processors officially contracted to process the data on Our behalf;
  2. business partners, suppliers and sub-contractors for the performance of any contract We enter into with you;
  3. analytic and search engine providers that assist us in the improvement and optimisation of Our Website;
  4. any other third parties We are legally obliged to disclose your information to.

7.2 Where you have given your consent, We may disclose your data to carefully restricted third parties for their marketing and promotional purposes.

7.3 We will only disclose your Personal Data to parties who bear sufficient legal responsibility for its protection and who have sufficient privacy and security measures in place.

7.4 We may disclose your Personal Data to third parties in the event of a business sale, acquisition, legal obligation, enforcement of Our terms, or to protect Our rights, property or safety.

8. How can I control use of my information?

8.1 Marketing

8.1.1 We will only send you marketing, and will only share your details with carefully restricted third parties for their own marketing, if you have given your consent by ticking the marketing opt-in box on the Account Registration Form. The box is not pre-ticked.

8.1.2 By ticking the box, you consent both to receiving marketing from us and to us sharing your data with carefully restricted third parties for their own marketing purposes.

8.1.3 You can withdraw your consent at any time, free of charge, by clicking “unsubscribe” in any marketing message or by contacting our Data Protection Officer.

8.2 Your rights

8.2.1 Under the GDPR you have the right to:

  • access the personal data we hold about you;
  • request rectification of inaccurate or incomplete data;
  • request erasure of your data where there is no lawful reason for us to continue holding it;
  • request restriction of our processing in certain circumstances;
  • object to processing based on our legitimate interests, and to object at any time to processing for direct marketing;
  • request the portability of data you provided to us;
  • withdraw consent at any time where we rely on consent;
  • not be subject to a decision based solely on automated processing that produces legal or similarly significant effects.

We do not currently make decisions about you by automated means.

8.3 How to exercise your rights

8.3.1 You can exercise any of these rights by contacting our Data Protection Officer at dpo@healthxchange.com, or by writing to the Data Protection Officer, Healthxchange Group, Albert House, South Esplanade, St Peter Port, Guernsey, GY1 1AJ.

8.3.2 There is normally no charge, and we will respond within one month. We may ask you to verify your identity before we act on a request.

8.3.3 If you are not satisfied, you have the right to complain to the supervisory authority.

9. Changes to Privacy Policy

9.1 We reserve the right to make changes to this Policy from time to time by updating this page. Every time you wish to use Our Website, please check the Policy to ensure you understand the terms that apply at that time.

9.2 This version is effective as of [insert date].

10. Your right to complain

10.1 If you believe your personal data is not being handled properly, you have the right to lodge a complaint with the Irish Data Protection Commission (DPC), 6 Pembroke Row, Dublin 2, D02 X963, Ireland — www.dataprotection.ie.

Placeholders to complete before publishing

  • 1.1 — Healthxchange Ireland Limited company number and Irish registered office; confirm 15669/A is the correct DPC registration for the website.
  • 4.4 / 4.5 — link to the Shopify cookie-settings control, and link to the live Cookie Policy page.
  • 9.2 — effective date.

Points for the DPO to confirm

  • Lawful bases in clause 5.5, especially the legal-obligation basis for bona fide / eligibility checks.
  • No special category data is processed through the Website.
  • No solely automated decision-making with legal or similarly significant effect.
  • Healthxchange Ireland Limited is the sole controller for personal data of EU customers collected through this Website.