1. Important introductory information

1.1 This Privacy Policy describes how EIDO Healthcare Limited and EIDO Systems International Limited (together referred to as EIDO) will process your personal data.

1.2 EIDO respects your privacy and is committed to protecting your personal data.

1.3 If you are a medical professional who has provided us with personal data in connection with your use of any of our services please see the privacy notice that applies to users of EIDO products and services. You can find this at https://docs.eidohealthcare.com/privacy-policy-users-of-eido-services.

1.4 All personal data that we process relating to you, will be handled in line with all applicable data protection laws.

1.5 Our products, services, publications and websites are not intended for children and we do not knowingly process personal data relating to children.

1.6 It is important that you read this privacy notice together with any other privacy notice we may provide to you from time to time so that you are fully aware of how and why we will use your personal data.

1.8 If you have any questions or concerns about the information set out in this privacy notice or how EIDO processes your personal data please contact our Data Protection Officer using the contact details set out in paragraph 1.9 below. You also have the right to make a complaint at any time to the Information Commissioner’s Office (ICO). You can do this by visiting the ICO website at www.ico.org.uk or by phone to 03031231113.

1.9 The table below provides various information about EIDO, including details of how you can contact us, and our Data Protection Officer (DPO)

Company name	EIDO Healthcare Ltd	EIDO Systems International Ltd
Registration number	4030383	09485836
Address	Bridgford Business Centre, 29 Bridgford Road, West Bridgford, NG2 6AU	Bridgford Business Centre, 29 Bridgford Road, West Bridgford, NG2 6 AU
Telephone	0115 8781000	01158781000
Website	www.eidohealthcare.com	www.eidohealthcare.com
Data Protection Officer contact details	[email protected]	[email protected]

2. What personal data will we process about you?

2.1 We may collect, use, store and transfer different kinds of personal data about you depending on how we interact with you and the purposes we hold your personal data for. The types of personal data we might hold about you can be grouped together as follows:

2.1.1 Identity Data including first name, last name, job title or similar identifiers such as the organisation you work for or the area of your specialism

2.1.2 Contact Data including postal address, email address and telephone numbers.

2.1.3 Technical Data including internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access our websites.

2.1.4 Usage Data including information about how you use our website, publications, products and services.

2.1.5 Marketing and Communications Data including your preferences in receiving marketing from us, your communication preferences, and information regarding your use of, and responses to, our marketing.

2.1.6 Transaction Data including details of our relationship with you, about your enquiry, request or complaint or any other information relating to the purpose you have contacted us for.

3. How do we collect your personal data?

3.1 We may collect your personal data in a number of ways including:

Direct interactions

3.2 You may give us your Identity Data, Contact Data, Transaction Data, and/or Marketing and Communications Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:

3.2.1 submit an enquiry about our products/services;

3.2.2 subscribe to our newsletter or publications;

3.2.3 request a copy of our Annual Consent Review or another publication;

3.2.4 request marketing materials to be sent to you;

3.2.5 take part in a competition, survey or promotion;

3.2.6 give us your personal data at any event, meeting, exhibition we attend;

3.2.7 give us feedback or contact us regarding our products/services or request support when using our website products or services;

3.2.8 communicate with us whether by phone, email, social media or otherwise.

Automated technologies or interactions

3.3 As you interact with our websites, we may automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies and other similar technologies. We may also receive Technical Data about you if you visit other websites employing our cookies. Please see our cookie policy at https://www.eidohealthcare.com for further details.

Third parties and publicly available sources

3.4 We may receive personal data about you from various third parties as set out below:

3.4.1 Technical Data from analytics providers, such as Google;

3.4.2 Identity Data and Contact Data from data brokers or aggregators such as Binley’s Medical Database

3.4.3 Identity Data and Contact Data from publicly available sources, such as Linkedin, Companies House and the Electoral Register.

4. How we use your personal data and what lawful basis do we rely on?

4.1 We will only use your personal data for purposes and in ways that are fair and lawful. We will use your personal data in the following circumstances:

4.1.1 Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.

4.1.2 Where we need to comply with a legal obligation.

4.1.3 Where you have given your consent.

4.1.4 Where it is necessary to perform a contract or to take steps with a view to entering a contract with you.

5. What purposes will we use your personal data for?

5.1 We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

Purpose/Activity	Type of personal data	Lawful basis for processing (including where applicable basis of legitimate interest)
To process your request for a copy of our Annual Consent Review or other publications	Identity Data Contact Data	Necessary for our legitimate interests (to provide you with materials you have requested in order to promote our business)
To process and respond to your general enquiry or to provide support to you	Identity Data Contact Data	Necessary for our legitimate interests (to respond to your enquiry and promote our business)
To send you marketing material in relation to our products/services which may be of interest to you	Identity Data Contact Data Usage Data Marketing and Communications Data	Necessary for our legitimate interests (to develop our products/services and promote our business) Consent
To manage our relationship with you which will include: Notifying you about changes to our terms or privacy notice or reminding you when your service is due to expire Asking you to send us feedback or take a survey Taking payments from you.	Identity Data Contact Data Usage Data Marketing and Communications Data	Necessary to comply with a legal obligation Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services) Necessary for perform our contractual obligations to you
To use data analytics to improve our website, products/services, marketing, customer relationships and experiences	Identity Data Contact Data Usage Data Marketing and Communications Data	Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website 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	Identity Data Contact Data Usage Data Marketing and Communications Data	Necessary for our legitimate interests (to develop our products/services and promote our business)
To register you on one of our events and to manage and run the event	Identity Data, Contact Data	Necessary for our legitimate interests (to run and manage events)

6. Marketing

6.1 We strive to provide you with choices and will only use your personal data when we have your consent. You can also ask us to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you or by contacting us at any time at [email protected].

7. Third party marketing

7.1 We do not share your personal data with any third parties for their own marketing purposes.

8. Change of purpose

8.1 We will only use your personal data for the purposes for which we collected it and which we have notified to you, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose.

8.2 If we need to use your personal data for an unrelated purpose, we will notify you and either ask for your consent or notify you (depending which is most appropriate) we will explain the legal basis which allows us to do so.

8.3 Please note however that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

9. Disclosure

9.1 We may share your personal data with the parties set out below for the purposes set out in the table (Purposes for which we will use your personal data) above.

9.1.1 Other members of staff in the same group of companies as EIDO from time to time to ensure the efficient operation of each member of the group;

9.1.2 External third parties such as:

9.1.2.1 service providers acting as processors who provide IT, system administration and support services, developers cloud service providers and payment service providers;

9.1.2.2 professional advisers including lawyers, bankers, auditors and insurers who provide consultancy, banking, legal, insurance and accounting services;

9.1.2.3 HM Revenue & Customs, regulators and other authorities who require reporting of processing activities in certain circumstances.

9.1.3 Third parties to whom we may choose to sell, transfer or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy notice.

9.2 We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

9.3 Our websites may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy notice of every website you visit.

10. Where in the world do we transfer your personal data to?

10.1 Some of the third parties we share your personal data with are based outside the UK and the EEA. As a result, your personal data will be transferred to, or accessed from, outside the UK and EEA

10.2 Whenever we transfer your personal data out of the EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

10.2.1 We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission.

10.2.2 Where we use certain service providers, we may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe.

10.3 Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.

11. How do we keep your personal data secure?

11.1 We have put in place appropriate security measures to prevent your personal data from being accidentally and inadvertently lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know it.

11.2 We have put in place procedures to detect and respond to any suspected or known personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

12. How long do we keep your personal data for?

12.1 We will only keep your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements.

12.2 To determine the appropriate retention period for personal data, we consider the purpose(s) for which your personal data was collected, the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data and whether we can achieve those purposes without handling your personal data at all. We also consider where applicable legal, regulatory, tax, accounting or other requirements.

12.3 Details of the specific periods for that we keep your personal data are available in our retention policy. If you have any specific questions about how long we keep your personal data for, you can ask for more information by emailing [email protected].

12.4 In some circumstances we will anonymise your personal data (so that it can no longer be associated with you) so that we then use it for research and/or statistical purposes, in which case we may use this information indefinitely without further notice to you.

13. Your legal rights as a data subject

13.1 At any point while we are in possession of your personal data, you, data protection laws give you a number of rights. You can exercise these rights at any time by contacting us at [email protected]. You should be aware that all of these rights apply in all circumstances but we will consider each request individually and if any right does not apply, we will explain why.

13.1.1 Right to access your personal data (commonly known as a “data subject access request). This enables you to request a copy of the personal data that we hold about you and check that we are lawfully processing it.

13.1.2 Right to rectification your personal data. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.

13.1.3 Right to be forgotten. This enables you, in certain circumstances, to ask us to delete or remove personal data where there is no good reason for us to continue processing it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to restriction to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, we may not always be able to comply with your request for erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.

13.1.4 Right to restrict processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios:

13.1.4.1 If you want to establish the data’s accuracy.

13.1.4.2 Where our use of the data is unlawful but you do not want us to erase it.

13.1.4.3 Where you need us to hold the data even if we no longer require it as you need to establish, exercise or defend legal claims.

13.1.4.4 You have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to us it.

13.1.5 Right of portability. Where this right applies we will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format

13.1.6 Right to object to your personal data being processed. Where we are relying on a legitimate interest (or those of a third party) and you want to object to processing. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms. However where you object to us processing your personal data for direct marketing purposes we will always comply.

13.1.7 Right to withdraw consent. Where we are relying on consent to process your personal data you can withdraw your consent at any time. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.

13.2 Where your personal data has been disclosed to a third party (as stated in paragraph 9.1.2 above), any request received from you in connection with your rights set out above will also be shared with such relevant third party if required.

Document Control

Reference: Privacy Notice (website)

Issue No: 1.2

Issue Date: 30 November 2020