1. Introduction
1.1. Welcome to MediWales’ privacy notice.
1.2. This privacy policy (together with any terms and conditions applicable to any goods and/or services we supply) sets out the basis on which any Personal Data we collect from you, or that you provide to us, through your use of our Sites, will be processed by us.
1.3. Please read the following carefully to understand our views and practices regarding your Personal Data and how we will treat it.
1.4. This policy has been prepared to take account of the forthcoming changes under GDPR. We may change this policy from time to time to take account of:
1.4.1. changes to Data Protection Laws and other laws which may affect this policy
1.4.2. guidance issued by the ICO and others;
1.4.3. issues raised by our customers, partners and end users.
1.5. Accordingly, we suggest that you regularly check this page to ensure that you continue to be comfortable with the measures that we are taking to protect your privacy. This policy is effective from 24th May 2018.
2. Definitions used in this policy
2.1. In this policy the following words have the following meanings:
Act means the Data Protection Act 1988
Customer, you and your: means any of the following (a) subscribers to our Publications and websites (b) customers who have entered into a contract with us for the supply of our products and services (c) attendees at our events (d) attendees at awards (e) editorial contributors.
Data Protection Laws means the Act, GDPR, the Regulation of Investigatory Powers Act 2000, the Telecommunications (Lawful Business Practice) (Interception of Communications) Regulations 2000 (SI 2000/2699), the Electronic Communications Data Protection Directive (2002/58/EC), the Privacy and Electronic Communications (EC Directive) Regulations 2003 (SI 2426/2003) and all applicable laws and regulations relating to the processing of personal data and privacy, including where applicable the guidance and codes of practice issued by the ICO or any other supervisory authority, and the equivalent of any of the foregoing in any relevant jurisdiction.
Data Controller, Data Processor, Data Subject and Personal Data all have the meaning given to them in the Act and GDPR
Events means awards, conferences, competitions, exhibitions, roundtables, polls, surveys managed by the Company.
GDPR means EU General Data Protection Regulations
Company means MediWales including the following brands; UK HealthTech, MediWales Connects, Life Science Industry News, whose registered offices are at 1st Floor, The Bonded Warehouse, Atlantic Wharf, Cardiff, CF10 4HF.
CHECK THIS ONE
ICO means the Information Commissioner’s Office and any successor to it as data protection authority.
Publications means printed publications, digital publications, magazines, and e-newsletters published by the Company.
Site(s) means any of the Company’s websites including this website.
3. Data Controller
3.1. The Company is made up of different legal entities. This privacy notice is issued on behalf of the Group so when we mention “Company“, “we“, “us” or “our” in this privacy notice, we are referring to the relevant company in the Group responsible for processing your data. We will let you know which entity will be the controller for your data when you purchase a product or service with us. CHECK THIS ONE
3.2. Should we ask you to provide certain information by which you can be identified when using our Sites, subscribing for any of our Publications, our products or services or by other contact methods, then you can be assured that it will only be used in accordance with this privacy policy.
3.3. As Data Controller, we determine the purposes for which and the manner in which your Personal Data is, or is to be, processed.
3.4. In this policy we describe:
3.5.1. the data protection principles which underpin our processing activities;
3.5.2. the lawful grounds upon which we rely to process your Personal Data;
3.5.3. the types of processing we may undertake with respect to your Personal Data; and
3.5.4. certain of your rights under GDPR.
4. The Kind of Information we will hold about you
4.1. The Company will collect and process the following personal information:
4.1.1. Information you give to us;
4.1.2. Information we collect about you; and
4.1.3. Information supplied to us by third parties.
4.2. Information you give to us
We may process the following types of personal data:
4.2.1. Account Data – this will:
4.2.1.1. include your name, address, email address and telephone number
4.2.1.2. be supplied by you or your employer when you register for an account with us
4.2.1.3. be processed for the purposes of operating our Site, providing subscriptions/renewals to our Publications, providing our products and services, ensuring the security of our Site and services, maintaining back-ups of our databases and sending communications to you.
4.2.2. Profile Data – this will :
4.2.2.1. Include your name, address, email address and telephone number, job function/title, business demographics in relation to your role, business interests, business areas, business expertise
4.2.2.2. be supplied by you when you register a profile, complete surveys, contribute to our Publications, attend or contribute to events, register enquiry or tell us about any problems with our Site.
4.2.2.3. be processed for enabling and monitoring your use of our Site, products and services.
4.2.3. Publication Data – this will
4.2.3.1. include information that you may post for publication on our Site and/or on our Publications across any media platforms including print, digital or on-line (including, without limitation, discussion boards, chat rooms or other social media platforms on our Site);
4.2.3.2. be supplied by you when you post material for publication on our Site;
4.2.3.3. be processed for the purposes of enabling such publication and administering our Site, products and services
4.2.4. Enquiry Data – this will:
4.2.4.1. include information that you may supply in any enquiry which you submit to us regarding our Publications, subscriptions, products and/or services
4.2.4.2. be supplied by you or your employer when you submit an enquiry to us whether by telephone, email, via our Site or other channel
4.2.4.3. be processed for the purpose of marketing, offering and selling Publications, subscriptions, products and/or services to you.
4.2.5. Transaction Data – this will:
4.2.5.1. include information which you are required to provide to us in connection with the your purchase of Publications, subscriptions, events, Content and Information Services, products and services from us such as your name, address, email address, telephone number, card details and transaction details;
4.2.5.2. be supplied by you at the point of purchase;
4.2.5.3. be processed for the purpose of supplying you with the Publications, subscriptions, products and/or services you have purchased; record-keeping purposes; marketing purposes
4.2.6. Notification Data – this will:
4.2.6.1. include information which you are required to provide to us for the purpose of subscribing to free email notifications, newsletters etc (Notifications);
4.2.6.2. be supplied by you when you subscribe for such Notifications;
4.2.6.3. be processed by us for the purpose of sending you such Notifications as well as notifications from our Company and selected third parties.
4.2.7. Attendee Data – this will:
4.2.7.1. include information which you are required to provide to us for the purpose of attending any of our Events
4.2.7.2. be supplied by you, or your employer, when you register to attend an event;
4.2.7.3. be processed by us for the purpose of completing your registration for an event, sending you event details and notifications, reminders, entry badges, delegate lists and details which are an integral part of the event.
4.2.8. Marketing and Communications Data – this will include your preferences in receiving marketing from the Company and our third parties and your communication preferences.
4.3. Information we collect about you.
Whenever you access the Site we will automatically collect the following information:
4.3.1. Usage Data – this will:
4.3.1.1. include information about your use of our Site, products and services
4.3.1.2. be collected by our [analytics tracking system both advertising, customer insight];
4.3.1.3. include technical information such as your Internet protocol (IP) address, geographical locations, browser details, operating system, length of visit, page views, website navigation paths, details of the timing, frequency and patter of your Site usage and other information about your visit collected via cookies (see our cookies policy below);
4.3.2. Information we obtain about you from third parties
We may receive personal data about you from various third parties as set out below:
4.3.2.1. Technical Data from the following parties
4.3.2.1.1. analytics providers such as Google based outside the EU
4.3.2.1.2. advertising networks; and
4.3.2.1.3. search information providers (which may be based inside or outside the EU)
4.3.2.2. contact and Transaction Data from providers of technical, payment and delivery services. This may include billing address, delivery address, email address and telephone numbers;
4.3.3. Identity and contact data from:
4.3.3.1. data brokers or aggregators.
4.3.3.2. publicly availably sources such as Companies House and the Electoral Register based inside the EU; and
4.3.3.3. information which is publicly available (e.g. on websites associated with you or your business or on social media platforms).
5. How we use your personal data
5.1. We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:
5.1.1. Where we need to perform the contract we are about to enter into or have entered into with you.
5.1.2. 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.
5.1.3. Where we need to comply with a legal or regulatory obligation.
5.2. Generally we do not rely on consent as a legal basis for processing your personal data. This is because in most cases the processing is required to perform the contract with you, or, because it is necessary for our legitimate interests and your interests and fundamental rights do not override those interests. You have the right to withdraw consent to marketing at any time by contacting us.
5.3. In addition, we may process any of your personal data identified in this policy where this is necessary for:
5.3.1. the establishment, exercise or defence of legal claims – the legal basis for this is our legitimate interests, in particular the protection and assertion of our legal rights, your legal rights or the legal rights of others.
5.4. the purposes of obtaining or maintaining insurance, managing risk, or obtaining professional advice – the legal basis for this processing is our legitimate interests (the protection of our business).
You may contact us to let us know that you do not wish us to process your Personal Data by contacting us as set out later in this policy.
6. Purposes for which we will use your personal data
6.1. 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.
6.2. Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground can be seen below.
Purpose/Activity – To register you as (a) a new customer (b) a new user/profile in respect of our Site (c) a subscriber to any Notifications (d) an attendee at any Events
Type of data used – (a) Account (b) Profile, (c) Notification, (d) Attendee
Lawful basis for processing including basis of legitimate interest – (a) Performance of a contract with you (b) Necessary for our legitimate interests, (c) Consent (in some cases)
Purpose/Activity To process and deliver your order including: (a) Manage payments, fees and charges (b) Manage your subscriptions (c) Collect and recover money owed to us
Type of data used – (a) Account (b) Enquiry (c) Transactional (d) Notification (e) Marketing and Communications
Lawful basis for processing including basis of legitimate interest – (a) Performance of a contract with you (b) Necessary for our legitimate interests
Purpose/Activity – To manage our relationship with you which will include: (a) Notifying you about changes to our terms or privacy policy (b) supplying Notifications to you; (c) Asking you to leave a review or take a survey
Type of data used – (a) Account (b) Profile (c) Notification (d) Marketing and Communications
Lawful basis for processing including basis of legitimate interest (a) Performance of a contract with you (b) Necessary to comply with a legal obligation (c) Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services
Purpose/Activity – To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)
Type of data used – (a) Account (b) Profile (c) Usage (d) Marketing and Communications (e) Technical
Lawful basis for processing including basis of legitimate interest – (a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise) (b) Necessary to comply with a legal obligation
Purpose/Activity – To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you
Type of data used – a) Account (b) Profile (c) Usage (d) Marketing and Communications (e) Technical
Lawful basis for processing including basis of legitimate interest – (a) Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy) (b) Consent
Purpose/Activity – To use data analytics to improve our website, products/services, marketing, customer relationships and experiences
Type of data used – (a) Technical (b) Usage
Lawful basis for processing including basis of legitimate interest – 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)
Purpose/Activity – To make suggestions and recommendations to you about goods or services that may be of interest to you
Type of data used – (a) Account (b) Profile (c) Technical (d) Usage
Lawful basis for processing including basis of legitimate interest – (a) Necessary for our legitimate interests (to develop our products/services and grow our business) (b) Consent (in some cases
7. Marketing
We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising.
8. Promotional offers from us
8.1. We may use your Account, Profile, Technical and Usage Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you.
8.2. You will receive marketing communications from us if you have requested information from us or purchased goods or services from us or if you provided us with your details when you entered a competition or registered for a promotion and, in each case, you have not opted out of receiving that marketing.
9. Data Sharing for Third-party marketing
We will get your express opt-in consent before we share your personal data with any company outside the Company for marketing purposes.
10. Opting out
10.1. You can ask us or third parties 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.
10.2. Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a product/service purchase, warranty registration, product/service experience or other transactions.
11. If you fail to provide personal information
If you fail to provide certain information when requested, the Company may not be able to perform any contract we have entered into with you or we may be prevented from complying with our legal obligations.
12. Change of purpose
12.1. We will only use personal information for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If we need to use your personal information for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
12.2. Please note that we may process your personal information without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
13. Disclosure of your information to others
13.1. We may disclose your personal information to:
13.1.1. Any member of our Company insofar as reasonably necessary for the purposes, and on the legal grounds, set out in this privacy policy.
13.1.2. Our insurers and/or professional advisers as may be reasonably necessary for the purposes of obtaining or maintain insurance managing risk, taking professional advice, or the establishment, exercise, defence of legal claim.
13.1.3. A purchaser in circumstances where the Company or substantially all of its assets are acquired by a third party, in which case personal data held by the Company will be one of the transferred assets.
13.1.4. Other third parties:
13.1.4.1. who supply goods and/or services to the Company in order that the Company may perform its contractual, legal and other obligations including, but not limited to, our suppliers and sub-contractors, service providers, distribution services, debt collection services;
13.1.4.2. External services may include, and are not limited to; Google Analytics, WordPress, DropBox, Xero, PayPal, WorldPay, Twitter, MailChimp.
13.1.4.3. if we are under a duty to disclose or share your Personal Data in order to :
13.1.4.3.1. comply with any legal obligation, or in order to enforce or apply Terms; or
13.1.4.3.2. to protect the rights, property, or safety of the Company, our customers, or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction;
13.1.4.3.3. to assist us in improving our products and services. We monitor aggregated data that is collected by our Service and may share this with third parties collectively and in an anonymous way. This data will not reveal personal information
13.1.5. We will disclose Transaction Data to :
13.1.5.1. our payment service provider to the extent necessary for the purposes of processing payments, arranging refunds, dealing with complaints and queries. Our payment service providers’ will process certain data in accordance with the terms of their own privacy policy details of which can be supplied on request..
13.1.6. We will disclose Profile Data, Transaction Data, Attendee Data, Marketing and Communications data and Enquiry Data to:
13.1.6.1. One or more selected third party service providers who assist us with our activities, such as hosting providers, and other IT or payment service providers, may also have access to personal information held by us and may use this information on our behalf.
14. Where we will store your personal data
14.1. Our data is hosted in the UK on hired servers
15. International Transfers
15.1. Many of our external third parties are based outside the European Economic Area (EEA) so their processing of your personal data will involve a transfer of data outside the EEA.
15.2. 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:
15.2.1. 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.
15.2.2. 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.
15.2.3. Where we use providers based in the US, we may transfer data to them if they are part of the Privacy Shield which requires them to provide similar protection to personal data shared between the Europe and the US.
15.3. Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.
16. Security
16.1. You acknowledge the transmission of information via the internet is not completely secure. Although the Company will do its best to protect your personal data, the Company cannot guarantee the security of your data transmitted via the Site; any transmission is at your own risk and we cannot prevent the use (or misuse) of such personal data by others. Once the Company has received your information, the Company will use strict procedures and security features to try to prevent unauthorised access.
16.2. We are committed to ensuring that your information is secure. We have put in place appropriate security measures to prevent your personal data from being accidentally 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. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.
16.3. We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
17. How long we will retain your Personal Data
17.1. The Personal Data which we process for any purpose (or purposes) shall not be kept for longer than is necessary for that purpose or purposes.
17.2. We may retain your Personal data where this is necessary for:
17.2.1. Compliance with our legal obligations; and/or
17.2.2. To protect your vital interests or the vital interests of other person(s)
17.3. To determine the appropriate retention period for personal data, we consider the amount , nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.
17.4. Details of retention periods for different aspects of your personal data are available in our retention policy which you can request from us by contacting us.
18. Your rights as a data subject
Under certain circumstances, you have rights under data protection laws in relation to your personal data. We summarise below the rights which you have under GDPR effective from 25th May 2018. Your rights under the Act remain unaffected in the interim
19. No fee usually required
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.
20. What we may need from you
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
21. Time limit to respond
We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
22. You have the right to:
22.1. Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
22.2. Request correction of the personal data that we hold about you. 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.
22.3. Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object 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, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
22.4. Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. 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.
22.5. Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
22.6. Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
22.7. Withdraw consent at any time where we are relying on consent to process your personal data. 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.
23. Cookies
23.1. You should be aware that information may be collected using cookies, whenever accessing our Site or any Company websites. We use traffic log cookies to identify which pages are being used. This helps us analyse data about webpage traffic and improve our website in order to tailor it to customer needs. We only use this information for statistical analysis purposes and then the data is removed from the system. Cookies help us provide you with a better website by enabling us to monitor which pages you find useful and which you do not. A cookie in no way gives us access to your computer or any information about you, other than the data you choose to share with us.
23.2. You can choose to accept or decline cookies. Most web browsers automatically accept cookies, but you can usually modify your browser setting to decline if you prefer. This may prevent you from taking full advantage of the website.
23.3. For further information visit www.aboutcookies.org or www.allaboutcookies.org
24. Liability
You shall indemnify the Company against costs, claims, demands or expenses incurred or made against the Company as a result of any breach by you of this Privacy Policy.
25. Changes to our Privacy Policy
25.1. We keep our privacy policy under regular review and we will publish any updates or new versions on this web page. You should check on this page occasionally to ensure you are happy with any changes to this privacy policy.
25.2. If the changes are significant, we may also notify you by email.
25.3. Where required by applicable laws, we will obtain your consent to make these changes and provide users with the ability to opt out or unsubscribe at this time.
26. Our details
26.1. You can contact us at:
26.1.1. By post
26.1.2. Using our website contact form;
26.1.3. By telephone on +44 (0) 2920473456
26.1.4. By email to info@mediwales.com
27. Questions & Comments.
Please feel free to contact us using the details above if you have any questions about this privacy policy or if you are concerned about the information we hold about you, how your information is used or wish to exercise any of the rights set out in this policy.
