Privacy and cookie policy

Introduction

Theramex HQ UK Limited together with its international subsidiaries (“Theramex”, “us” or “our”) are committed to protecting and respecting your privacy.

This Privacy Policy sets out how we collect and process personal data through our Theramex websites (collectively the “Site”) and the basis on which the personal data we are collecting from you will be processed by us.  Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it.

Controllers of Personal Data

The Site is operated by Theramex HQ Limited a corporation established in the United Kingdom with registered office at Sloane Square House, 1 Holbein Place, Belgravia, London SW1W 8NS who, together with the Theramex subsidiary responsible for the relevant Theramex Site you engage with, are data controllers of personal data collected through the Site.

What does this Policy cover?

This Privacy Policy applies only to your use of our Site. Our Site may contain links to other websites. Please note that we have no control over how your data is collected, stored, or used by other websites and we advise you to check the privacy policies of any such websites before providing any data to them.

What is Personal Data?

Personal data is treated under this Privacy Policy as ‘any information relating to an identifiable person who can be directly or indirectly identified in particular by reference to an identifier’.

Put more simply, Personal data is any information about you that enables you to be identified. Personal data covers obvious information such as your name and contact details, but it also covers less obvious information such as identification numbers, electronic location data, and other online identifiers.

What Personal Data do we collect and use?

We may 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 or use contact details provided on the Site to correspond with us by phone, e-mail or otherwise. It may include:

• Identity information – your name, username and password to validate access to any secure area of the Site made available to healthcare professionals.
• Contact information – If you send us an email, we may collect your name, your email or postal address, and any other information which you choose to give us.
• Professional information: Your profession and specialization should you choose to provide this.
• Adverse Event Reports: Please see our separate privacy notice explaining how any enquiries, complaints or adverse event reports we are handled by us.

Information we collect about you from your use of the Site

We may gather information about you automatically through your use of the Site. This includes:

• Technical information – associated with your device and browser. This includes the Internet protocol (IP) address used to connect your computing device to the Internet, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform.
• Session information – from your interaction with the Site. This may include the full Uniform Resource Locators (URL), clickstream to, through and from our Site (including date and time), content you viewed, page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs).
• Country information: relevant to identifying the country from which you are accessing the Site to understand at an aggregate level, the locations of users accessing our Sites.

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 in the table below.  [ link to table.]

Promotional updates and communications

We may either through the Site or separately and with your prior consent collect or receive requests from you for the purpose of providing you with promotional update communications by email, SMS, phone or post (subject to your stated preferences). Please refer to the ‘Your rights’ section [link to section] of this policy if you wish to change your promotional communication and contact preferences.

Purpose and lawful basis of processing

We have summarised below:

• What personal data we process
• What we use that data for
• The lawful basis for the processing

Who is my data shared with?

We may share information with:

• Another subsidiary in the Theramex group
• Organisations who process your personal data on our behalf and, our instructions and subject to contractual safeguards in supporting our Site.
• Analytics providers that assist us to better understand the engagement with the Site and to help us make improvements

We may also disclose your personal data

• 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 Theramex or substantially all of its assets are acquired by a third party, in which case personal data held by it about 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,

How and where do you store my data?

We store your personal data on servers in Europe. We may on occasion also use the services of service providers or collaborate with subsidiaries in our group to whom personal data may be transferred.

Where we transfer personal data we will take steps to ensure your data is subject to legal safeguards appropriate to the transfer and the data, including by relying upon a recognised legal adequacy mechanism such as use of specific approved contracts relying upon approved standard contractual clauses for the protection of personal data.

Security of personal data

Personal data security is essential to us and to protect personal data, we take the following measures:

• Ensuring that we have adequate Site security including relevant SSL Certificates for the Site.
• Mandatory Cookie acceptance choice for visitors to the Site
• If you email us, we will store your details in a secure server environment.

How long we keep personal data

We retain information for the term necessary for the fulfilment of the purposes set out above and for a period after this where necessary to anticipate, resolve any legal issues, obligations or claims.

We may also retain aggregate information for longer for statistical purposes to help us develop and improve the Site. You cannot be identified from aggregate data used for these purposes.

Changes to this Privacy Policy

We may change this Privacy Notice from time to time. This may be necessary, for example, if the law changes, or if we change our business or Site in a way that affects personal data protection.

Any changes will be immediately posted on our Site and you will be deemed to have accepted the terms of the Privacy Policy on your first use of our Site following the alterations. We recommend that you check this page regularly to keep up-to-date.

What are my rights?

Under the GDPR, you have the following rights,

• The right to be informed about our collection and use of your personal data. This Privacy Policy should tell you everything you need to know, but you can always contact us to find out more or to ask any questions using the details in below.
• The right to access and be provided with a copy of the personal data we hold about you.
• The right to have your personal data rectified if any of your personal data held us is inaccurate or incomplete.
• The right to be forgotten, i.e. the right to ask us to delete or otherwise dispose of any of your personal data that we have.
• The right to restrict (i.e. prevent) the processing of your personal data (while we verify or investigate your concerns with this information for example).
• The right to object to us further processing your personal data for a particular purpose or purposes (including for promotional communication purposes).
• The right for you to receive personal data concerning you, which you have previously provided in a “commonly used and machine-readable format” and to have that data transmitted to another controller.

Where our processing of your personal data is based upon your consent, you have the right to withdraw that consent without detriment at any time

Cookies and other tools

A cookie is a small piece of data (text file) that a website (when visited by a user) asks your browser to store on your device in order to remember information about you. Cookies permit to “remember” your actions or preferences for a limited period. To find out more about cookies, visit www.aboutcookies.org.

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

Most web browsers automatically accept essential 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 below. However, you may not be able to take full advantage of our Site if you block all cookies.

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 Site and will last for longer.

We use these cookies and other technologies on the basis that they are strictly necessary for the operation of the Site in our legitimate interests, (where we have considered that these are not overridden by your rights), and, in other cases, where you have consented to their use.

We use the following types of cookies:

• Strictly necessary cookies. These are cookies that are required for the operation of our Site session and under our terms with you. They include, for example, cookies that enable you to navigate and log into any secure areas of our Site.
• Analytical/performance cookies. These allow us to recognise and count the number of visitors and to see how visitors move around our Site when they are using it. This helps us improve the way our Site works, for example, by ensuring that users are finding what they are looking for easily.
• Functionality cookies. These are used to recognise you when you return to our Site. This enables us to personalise our content for you, greet you by name and remember your preferences (for example, your choice of language or region).
• Targeting cookies. These cookies record your visit to our Site, the pages you have visited and the links you have followed. We will use this information to make our Site and the advertising displayed on it more relevant to your interests. We may also share this information with third parties for this purpose.

Disabling cookies

The effect of disabling cookies depends on which cookies you disable but, in general, the Site 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 Site.

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

For more information about our use of your personal data or exercising your rights as outlined above, please contact us using the details provided in the contact us” section below.

If your request or concern is not satisfactorily resolved by us, you may approach your local data protection authority,

(see http://ec.europa.eu/justice/data-protection/bodies/authorities/index_en.html ).

The Information Commissioner is the supervisory authority in the UK.

Contact us

If you have questions about this Privacy and Cookie Policy, or if you would like to request the exercise of any individual rights, please contact us by emailing the [Theramex group] Privacy Officer, at:

dataprivacy@theramex.com

or write to the following address:

Theramex HQ U.K Limited
Privacy Officer
Sloane Square House
1 Holbein Place
Belgravia
London
SW1W 8NS