Privacy Policy1. INTRODUCTION
1.1 This Privacy Policy explains how we use the personal data that RevoluGen collects or generates through: (i) our Website; and (ii) as part of our relationship with you (or your organisation) as a customer or business partner.
1.2 This Privacy Policy is directed to individuals whose personal data we handle in the course of carrying on our commercial activities, whether they are our customers or business partners or prospective customers or business partners. This Privacy Policy is also directed to visitors to our Website.
1.3 For the purposes of data protection law, we are a controller of your personal data.
1.4 We use the following these definitions in this Privacy Policy:
“RevoluGen”, “we”, “us” and “our” means RevoluGen Ltd (company number 03518866) with its registered office at 32-33 High Street, Ascot, Berkshire SL5 7HG, United Kingdom.
“Website” means www.revolugen.co.uk
2. PERSONAL DATA THAT WE COLLECT ABOUT YOU
2.1 We will collect and process the following personal data about you:
Information that you provide to us.This includes information about you that you provide to us by filling in forms or by communicating with us, whether face-to-face, by phone, e-mail or otherwise. This information may include: your name, address, email address, contact details, academic qualifications, publications, work history, occupation, employer details, and job title.
Information we collect or generate about you.This includes:
- files that we may produce as a record of our relationship with our current and prospective customers and business partners, including contact history, order history, site visits, technical support history, marketing approaches, referrals to other customers and website use;
- personal data that you provide during telephone and email communications with us which we may monitor and record in order to resolve complaints, and improve our service; and
if you use our Website, we may collect technical information through the use of cookies. For more information on the cookies used by us, please see our Cookie Notice
Information we obtain from other sources. This includes: information from publicly available sources (including academic publications, and press releases, publicly available internet sources, digital media applications, social media, company publications, third party agencies such as credit reference agencies;
3. HOW WE USE YOUR PERSONAL DATA
3.1 Your personal data may be stored and processed by us in the following ways and for the following purposes:
• to perform our contractual obligations under contracts with customers, business partners and third parties;
• to communicate with our current and prospective customers and business partners to provide information about our products;
• for the management and administration of our business;
• to understand feedback on our products to help provide more information on the use of those products;
• to keep our records up to date;
• to monitor our IT systems and Website to protect against cyber threats or malicious activity including abuse and misuse;
• to administer or maintain our IT systems to uphold standards of service;
• for ongoing review and improvement of the information provided on our Website;
• to comply with and to assess compliance with applicable laws, rules and regulations, and internal policies and procedures;
• to establish or defend legal rights or for other purposes relating to legal proceedings; and/or
• to assist customers using our products.
3.2 We can use your personal data in these ways because:
• we are performing our contractual obligations;
• we have obtained your consent;
• we have legal and regulatory obligations that we must discharge;
• we may need to do so in order to establish, exercise or defend our legal rights for the purpose of legal proceedings; and/or
• the use of your personal data as described is necessary for our legitimate business interests, such as:
- allowing us effectively and efficiently to manage and administer the operation of our business;
- maintaining compliance with internal policies and procedures;
- marketing our products;
- maintaining an awareness of the customer’s use of the technology; and
- ensuring the security of our IT systems and Website.
4. DISCLOSURE OF YOUR INFORMATION TO THIRD PARTIES
4.1 We may disclose your personal data to our company management, board of directors and subsidiaries of the company and its distributors.
4.2 We may also share your personal data outside with third parties for these purposes:
• if we sell our shares or we sell or licence any of our business or assets or licence-in rights, in which case we may disclose your personal data to the prospective buyer, licensee or licensor (and its advisers and financiers) for due diligence purposes;
• if we are acquired by a third party, in which case personal data held by us about you can be disclosed to a third-party bidder or buyer;
• if the distributors of our products request from us or gives us any client information related to sales and marketing, in which case, we may share your personal data with the distributor;
• if we enter into an arrangement supplying material to a clinical trial we may disclose your personal data to the body that is initiating, organising and carrying out the trial;
• to third party agents or contractors (for example, IT and communications providers, law firms, accountants and auditors, cloud service providers and consulting agencies) for the purposes of providing services to us; and/or
• to the extent required by law, for example if we are under a duty to disclose your personal data in order to comply with any legal obligation, or establish, exercise or defend our legal rights.
5. TRANSFERS OF PERSONAL DATA OUTSIDE THE EUROPEAN ECONOMIC AREA
5.1 The personal data that we collect from you may be transferred to, and stored at, a destination outside the European Economic Area (“EEA”). It may also be processed by staff operating outside of the EEA who work for us or for one of our suppliers.
5.2 Where we transfer your personal data outside the EEA, we will ensure that it is protected in a manner that is consistent with how your personal data will be protected by us in the EEA. This can be done in various ways, for instance:
• the country that we send the data to might be approved by the European Commission; or
• the recipient might have signed up to a contract based on “model contractual clauses” approved by the European Commission, obliging them to protect your personal data; or
• in other circumstances the law may permit us to otherwise transfer your personal Data outside the EEA.
6. RETENTION OF PERSONAL DATA
6.1 How long we hold your personal data for will vary. The retention period will be determined by various criteria including:
• the purpose for which we are using it – we will need to keep the data for as long as is necessary for that purpose; and
• legal obligations – laws or regulation may set a minimum period for which we have to keep your personal data.
7. YOUR RIGHTS
7.1 You have various legal rights in relation to the personal data that we hold about you. These rights include rights to:
• the right to obtain information regarding the processing of your personal data and access to the personal data which we hold about you;
• withdraw your consent to our processing of your personal data at any time. Please note, however, that we may still be entitled to process your personal data if we have another legitimate reason (other than consent) for doing so;
• in some circumstances, receive some personal data in a structured, commonly used and machine-readable format and/or request that we transmit those data to a third party where this is technically feasible. Please note that this right only applies to personal data which you have provided to us;
• request that we rectify your personal data if it is inaccurate or incomplete;
• request that we erase your personal data in certain circumstances. Please note that there may be circumstances where you ask us to erase your personal data, but we are legally entitled to retain it;
• object to, and the right to request that we restrict, our processing of your personal data in certain circumstances. Again, there may be circumstances where you object to, or ask us to restrict, our processing of your personal data but we are legally entitled to continue processing your personal data and / or to refuse that request; and
• lodge a complaint with the data protection regulator (details of which are provided below) if you think that any of your rights have been infringed by us.
7.2 You can exercise your rights by contacting us using the details set out in the “Contacting us” section below.
7.3 You can find out more information about your rights by contacting the Information Commissioner’s Office, or by searching their website at https://ico.org.uk/
8. CONTACTING US
8.1 If you would like further information on the collection, use, disclosure, transfer or processing of your personal data or the exercise of any of the rights listed above, please address questions, comments and requests to info@revolugen.co.uk