Privacy Policy

SUMMARY OF KEY POINTS

This summary provides key points from our Privacy Notice, but you can find out more details about any of these topics by looking at the relevant section below.

What personal information do we process? When you visit, use or navigate our Services, we may process personal information depending on how you interact with us and the Services, the choices you make, and the products and features you use.

Do we process any sensitive personal information? We do not process sensitive personal information.

Do we receive any information from third parties? We do not receive information from third parties.

How do we process your information? We process your information to provide, improve and administer our Services, communicate with you, for security and fraud prevention, and to comply with the law. We may also process your information for other purposes with your consent. We process your information only when we have a valid legal reason to do so.

In what situations and with which types of parties do we share personal information? We may share information in specific situations and with specific categories of third parties.

How do we keep your information safe? We have organizational and technical processes and procedures in place to protect your personal information. However, no electronic transmission over the internet or information storage technology can be guaranteed to be 100% secure, so we cannot promise that hackers, cybercriminals or other unauthorized third parties will not be able to beat our security and improperly collect, access, steal or modify your information.

What are your rights? Depending on where you are located geographically, the applicable privacy law means that you may have certain rights regarding your personal information.

How do you exercise your rights? The easiest way to exercise your rights is by submitting a data subject access request, or by contacting us. We will consider and act upon any request in accordance with applicable data protection laws.

1. WHAT INFORMATION DO WE COLLECT?

Personal information you disclose to us.

In short: We collect personal information that you provide to us.

We collect personal information that you voluntarily provide to us when you express an interest in obtaining information about us or our products and Services, when you participate in activities on the Services, or otherwise when you contact us.

Personal Information Provided By You. The personal information that we collect depends on the context of your interactions with us and the Services, the choices you make, and the products and features you use. The personal information can include the following:

• Names
• Phone numbers
• Email addresses

Sensitive information. We do not process sensitive information.

All information that you provide us must be true, complete, and accurate and you must inform us of any changes to such personal information.

Information automatically collected.

In short: Some information – such as your Internet Protocol (IP) address and/ or browser and device characteristics – is collected automatically when you visit our Services.

We automatically collect certain information when you visit, use, or navigate the Services. This information does not reveal your specific identity (like your name or contact information) but may include device and usage information, such as your IP Address, browser and device characteristics, operating system, language preferences, referring URLs, device name, country location, information about how and when you use our Services, and other technical information. This information is primarily needed to maintain the security and operation of our Services, and for our internal analytics and reporting purposes.

Like many businesses, we also collect information through cookies and similar technologies.

The information we collect includes:

• Log and Usage Data. Log and usage data is service-related, diagnostic, usage and performance information our servers automatically collect when you access or use our Services and which we record in log files. Depending on how you interact with us, this log data may include your IP Address, device information, browser type, and settings and information about your activity in the Services (such as the date/ time stamps associated with your usage, pages and files viewed, searches and other actions you take such as which features you use), device event information (such as system activity, error reports (sometimes known as ‘crash dumps’) and hardware settings.)
• Device Data. We collect device data such as information about your computer, phone, tablet, or other device you use to access the Services. Depending on the device used, this device data may include information such as your IP address (or proxy server), device and application identification numbers, location, browser type, hardware model, Internet service provider and/ or mobile carrier, operating system and system configuration information.
• Location Data. We collect location data such as information about your device’s location, which can be either precise or imprecise. How much information we collect depends on the type and settings of the device you use to access the Services. For example, we may use GPS and other technologies to collect geolocation data that tells us your current location (based on your IP address). You can opt out of allowing us to collect this information by either refusing access to the information or by disabling your location settings on your device. However, if you opt out, you may not be able to use certain aspects of the Services.

2. HOW DO WE PROCESS YOUR INFORMATION?

In short: We process your information to provide, improve and administer our Services, communicate with you, for security and fraud prevention and to comply with law. We may also process your information for other purposes with your consent.

We process your personal information for a variety of reasons, depending on how you interact with our Services, including:

• To deliver and facilitate delivery of services to the user. We may process your information to provide you with the requested service.
• To respond to user enquiries/ offer support to users. We may process your information to respond to your enquiries and solve any potential issues you might have with the requested service.
• To send administrative information to you. We may process your information to send you details about our products and services, changes to our terms and policies, and other similar information.
• To save or protect an individual’s vital interest. We may process your information when necessary to save or protect an individual’s vital interest, such as to prevent harm.

3. WHAT LEGAL BASES DO WE RELY ON TO PROCESS YOUR INFORMATION?

In short: we only process your personal information when we believe it to be necessary and we have a valid legal reason (i.e. legal basis) to do so under applicable law, like with your consent, to comply with laws, to provide you with services to enter into or fulfill our contractual obligations, to protect your rights, or to fulfil our legitimate business interests.

The General Data Protection Regulation (GDPR) and UK GDPR require us to explain the valid legal bases we rely on in order to process your personal information. As such we may rely on the following legal bases to process your personal information:

• Consent. We may process your information if you have given us permission (i.e. consent) to use your personal information for a specified purpose. You can withdraw your consent at any time.
• Performance of a Contract. We may process your personal information when we believe it is necessary to fulfil our contractual obligations to you, including providing
• Legal Obligations. We may process your information where we believe it is necessary for compliance with our legal obligations, such as to cooperate with a law enforcement body or regulatory agency, exercise or defend our legal rights, or disclose your information as evidence in litigation in which we are involved.
• Vital interests. We may process your information where we believe it is necessary to protect your vital interests or the vital interests of a third party, such as situations involving potential threats to the safety of any person.

In legal terms, we are generally the ‘data controller’ under European data protection laws of the personal information described in this privacy notice since we determine the means and/ or purposes of the data processing we perform. This privacy notice does not apply to the personal information we process as a ‘data processor’ on behalf of our customers. In those situations, the customer that we provide services to and with whom we have entered into a data processing agreement is the ‘data controller’ responsible for your personal information, and we merely process your information on their behalf in accordance with your instructions.

4. WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?

In short: We may share information in specific situations described in this section and/or with the following categories of third parties.

Vendors, Consultants and Other Third-Party Service Providers. We may share your data with third-party vendors, service providers, contractors or agents (‘third parties’) who perform services for us or on our behalf and require access to such information to do that work. The categories of third parties that we may share personal information with are as follows:

• Data Analytics Services
• Performance Monitoring Tools

We may also need to share your personal information in the following situations:

9. WHAT ARE YOUR PRIVACY RIGHTS?

In short: In some regions, such as the European Economic Area (EEA), United Kingdom (UK) or Switzerland, you have rights that allow you greater access to and control over your personal information. You may review, change or terminate you account at any time.

In some regions (EEA, UK, Switzerland) you have certain rights under applicable data protection laws. These may include the right (i) to request and obtain a copy of your personal information, (ii) to request rectification or erasure, (iii) to restrict the processing of your personal information, (iv) if applicable, to data portability, and (v) not be subject to automated decision making. In certain circumstances, you may have the right to object to the processing of your personal information.

We will consider and act upon any request in accordance with applicable data protection laws.

If you are in the UK and believe that we are unlawfully processing your personal information, you have the right to complain to the UK Data Protection Authority.

Withdrawing your consent: if we are relying on your consent to process your personal information, you have the right to withdraw your consent at any time.

However, please note that this will not affect the lawfulness of the processing before its withdrawal, nor will it affect the processing of your personal information conducted in reliance on lawful processing grounds, other than consent.

Opting out of marketing and promotional communications: you can unsubscribe from our marketing and promotional communications at any time by clicking on the Unsubscribe link at the bottom of the emails that we send, or by contacting us via email, post or telephone. You will then be removed from the marketing lists. However, we may still communicate with you, for example, to send you service-related messages that are necessary for the administration of your treatment, to respond to service requests or for other non-marketing purposes.

Cookies and similar technologies: most web browsers are set to accept cookies by default. If you prefer, you can usually choose to set your browser to remove and/ or reject cookies. If you choose to remove or reject cookies, this could affect certain features or services of our Services.