1. Introduction
ClearView Endoscopy Ltd respects your right to privacy. This ‘Privacy Policy’ explains in detail the types of personal information we may collect about you when you interact with us. It also explains how we will store and handle that personal information, how we keep it safe.
If you have any questions or concerns about ClearView’s use of your personal information, then please contact us using the contact details provided in the section of this ‘Privacy Policy’ headed ‘How to contact us’ in Section 12, on page 7 of this document.
2. When do we use your personal data?
3. When do we use your personal data?
Information that you provide voluntarily:
information you submit in any of the above circumstances.
Information that we collect automatically:
When you visit our Website, we may collect certain information automatically from your device. In some countries, including countries in the European Economic Area, this information may be considered personal information under applicable data protection laws.
Specifically, the information we collect automatically may include information like your IP address, device type, operating system, unique device identification numbers, browser-type, broad geographic location (e.g., country or city-level location) and other technical information. We may also collect information about how your device has interacted with our Websites and Apps, including the pages accessed and links clicked.
Collecting this information enables us to better understand the visitors who come to our Websites or Apps, where they come from, what content on our Websites and Apps is of interest to them, what they have viewed or looked at and in some instances what they have purchased. We use this information for internal analytics purposes, to improve the quality and relevance of our Websites and Apps to our visitors and users and to deliver personally tailored retail offers, both on the website and through triggered email, SMS and direct mail (but only where you have agreed to these channels).
Some of this information may be collected using cookies, tracking pixels and similar tracking technology, as explained within this document under the heading ‘Cookies and similar tracking technology’ to follow.
Information that we obtain from third party sources:
From time to time, we may receive personal information about you from third party sources, but only where we have checked that these third parties either have your consent or are otherwise legally permitted or required to disclose your personal information to us.
We may use your personal information (including by anonymising and aggregating it with other customers’ personal information) for sales, supply chain and financial analysis purposes, to determine how we are performing and where improvements can be made. This is necessary for the purposes of our legitimate interests in understanding how our business is performing and considering how to improve our performance.
4. Who do we share your personal information with?
We may disclose your personal information to the following categories of recipients:
to specialist sub-contractors who, with your consent we may send equipment for repair.
to our insurance company if specialist indemnity cover is required.
to other prospective customers, with your permission, when using your details as a reference site.
to any competent law enforcement body, regulatory, government agency, court or other third party where we believe disclosure is necessary (i) as a matter of applicable law or regulation, (ii) to exercise, establish or defend our legal rights or apply our Terms and Conditions, or (iii) to protect your vital interests or those of any other person.
to a potential buyer (and its agents and advisers) in connection with any proposed purchase, merger or acquisition of any part of our business, provided that we inform the buyer it must use your personal information only for the purposes disclosed in this Privacy Policy.
Where we share your personal information with third party service providers and partners, we apply a policy to ensure your personal information is safe and in order to protect your privacy.
Our policy requires:
we provide only the information they need to perform their specific services.
they may only use your data for the exact purposes we specify in our contract with them.
we work closely with them to ensure that your privacy is respected and protected at all times.
if we stop using their services, any of your personal information held by them will either be deleted or rendered anonymous (subject to applicable law).
If you have any questions about the third parties, we share your personal information with, please contact us using the contact details provided under the ‘How to contact us’ heading.
5. Legal basis for processing personal information?
Our legal basis for collecting and using the personal information described above will depend on the personal information concerned and the specific context in which we collect it.
However, we will normally collect personal information from you only (i) where we need the personal information to perform a contract with you, (ii) where the processing is in our legitimate interests and not overridden by your data protection interests or fundamental rights and freedoms, or (iii) where we have your consent to do so. In some cases, we may also have a legal obligation to collect personal information from you or may otherwise need the personal information to protect your vital interests or those of another person.
If we ask you to provide personal information to comply with a legal requirement or to perform a contact with you, we will make this clear at the relevant time and advise you whether the provision of your personal information is mandatory or not (as well as of the possible consequences if you do not provide your personal information).
Similarly, if we collect and use your personal information in reliance on our legitimate interests (or those of any third party), we will make clear to you at the relevant time what those legitimate interests are.
If you have questions about or need further information concerning the legal basis on which we collect and use your personal information, please contact us using the contact details provided under the ‘How to contact us’ heading.
6. Cookies and similar tracking technology
We use cookies and similar tracking technology (collectively, ‘Cookies’) to collect and use personal information about you.
7. How do we keep your personal information secure?
We use appropriate technical and organisational measures to protect the personal information that we collect and process about you. The measures we use are designed to provide a level of security appropriate to the risk of processing your personal information.
Specific measures we use include:
encrypting your personal information.
keeping your information up-to-date and accurate. Please note that, to do this, we require you to tell us if any of your details such as your name or address change; and
having in place strict security procedures for the storage and disclosure of your information to prevent unauthorised access.
Unfortunately, the transmission of information via the Internet is not completely secure. Although we will do our best to protect your personal information, we cannot guarantee the security of your data transmitted to and/or through our Websites and Apps; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access.
8. Data Retention
We retain personal information we collect from you where we have an ongoing legitimate business need to do so (for example, to provide you with a service you have requested or to comply with applicable legal, tax or accounting requirements).
When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymise it or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.
For more information about the specific periods for which we retain your data, please contact us using the contact details provided under the ‘How to contact us’ heading.
9. Your data protection rights
You have the following data protection rights:
If you wish to access, correct, update or request deletion of your personal
information, you can do so at any time by contacting us.
In addition, you can object to processing of your personal information, ask us to restrict processing of your personal information or request portability of your personal information.
You can exercise these rights by contacting us using the contact details provided under the ‘How to contact us’ heading.
We do not use e-mail marketing communications. To opt-out of other forms of marketing (such as postal marketing or telemarketing), then please contact us using the contact details provided under the ‘How to contact us’ heading.
Similarly, if we have collected and processed your personal information with your consent, then you can withdraw your consent at any time. Withdrawing your consent will not affect the lawfulness of any processing we conducted prior to your withdrawal, nor will it affect processing of your personal information conducted in reliance on lawful processing grounds other than consent.
You have the right to complain to a data protection authority about our collection and use of your personal information. For more information, see the section headed ‘contacting the regulator’.
We respond to all requests we receive from individuals wishing to exercise their data protection rights in accordance with applicable data protection laws.
10. Contacting the Regulator
If you feel that your personal information has not been handled correctly, or you are unhappy with our response to any requests you have made to us regarding the use of your personal information, you have the right to raise a complaint with the Information Commissioner’s Office.
You can contact them by calling 0303 123 1113 or go online to
www.ico.org.uk/concerns
(please note we cannot be responsible for the content of external websites).
11. Updates to this Privacy Policy
You can see when this ‘Privacy Policy’ was last reviewed and updated by checking the ‘Date of Revision’ information displayed within the document history of this ‘Privacy Policy’.
12. How to contact us