Privacy Policy
We take your privacy very seriously. Please read this privacy policy carefully as it contains important information on who we are, and how and why we collect, store, use and share your personal information. It also explains your rights in relation to your personal information and how to contact us or supervisory authorities in the event you have a complaint. We collect, use and are responsible for certain personal information about you. When we do so we are subject to the General Data Protection Regulation, which applies across the European Union (including in the United Kingdom) and, except as provided in the next paragraph, we are responsible as controller of that personal information for the purposes of those laws. Please note, individuals may only access and use our product, COPDPredict™ if they have been granted access by a healthcare provider with whom we have entered into a valid supply and/or software-as-as service agreement. We will not be the controller of your personal information which is submitted or otherwise processed using COPDPredict™ in such circumstances. Instead, we will act as the processor of that personal information for the healthcare provider that provided you with access to COPDPredict™. Our agreement with the healthcare provider includes mandatory provisions required by the General Data Protection Regulation to protect your personal information when we act as processor. Please refer to your healthcare provider’s privacy policies and privacy statements to understand how they will collect, store, use and share your personal information when you access and use COPDPredict™.
KEY TERMS
Key terms used in this policy:
| We, us, our | NEPeSMO Limited, acompany registered in England and Wales (company number 11071606) |
| DataProtection Manager | The person responsible for ensuring we look after your data |
| Personal information | Any information relating to an identified or identifiable individual |
| Special category personal information | Personal information revealing racial or ethnic origin, political opinions, religious beliefs, philosophical beliefs or trade union membership Genetic and biometric data Data concerning health, sex life or sexual orientation |
PERSONAL INFORMATION WE COLLECT ABOUT YOU
We may collect and use the following personal information about you:
- your name and contact information, including email address, postal address, telephone number and company details;
- location data, if you choose to give this to us;
- your contact history and saved items;
- information from accounts you link to usg.social media accounts;
- information about how you use our website, applications, IT, communications and other systems; and
- your responses to surveys.
This personal information is required to provide ourservices to you, to enable us to improve our services and tailor them to your and other users’ needs. If you do not provide personal information we ask for, it may delay or prevent us from providing ourservices to you.
How your personal information is collected
We collect most of this personal information directly from youthrough our website and our applications, as well as by text, telephone and email. However, we may also collect information:
- from publicly accessible sources;
- directly from a third party;
- from a third party with your consent;
- from cookies on our website—for more information on our use of cookies, please see our Cookie Policy (accessible here) and
- via our IT systems e.g.automated monitoring of our websites and other technical systems, email and instant messaging systems.
How and why we use your personal information
Under data protection law, we can only use your personal information if we have a proper reason for doing so, e.g.:
- to comply with our legal and regulatory obligations;
- for the performance of our contract with you or to take steps at your request before entering into a contract;
- for our legitimate interests or those of a third party; or
- where you have given consent.
A legitimate interest is when we have a business or commercial reason to use your information, so long as this is not overridden by your own rights and interests. The table below explains what we use (process) your personal information for and our reasons for doing so:
| What we use your personal information for | Our reasons |
| To provide services to you | For the performance of our contract with you or to take steps at your request before entering into a contract |
| To prevent and detect fraud against you, us or the third parties we work with | For our legitimate interests or those of a third party, i.e. to minimise fraud that could be damaging for us and for you |
| Conducting checks to identify our users and verify their identity Other processing necessary to comply with professional, legal and regulatory obligations that apply to our business | To comply with our legal and regulatory obligations |
| Gathering and providing information required by or relating to audits, enquiries or investigations by regulatory bodies | To comply with our legal and regulatory obligations |
| Aggregating data to determine trends and patterns | For our legitimate interests or those of a third party i.e. to assess and improve our service |
| Ensuring business policies are adhered to e.g. policies covering security and internet use | For our legitimate interests or those of a third partyi.e. to make sure we are following our own internal procedures so we can deliver the best service to you |
| Operational reasons, such as improving efficiency, training and quality control | For our legitimate interests or those of a third party, i.e. to be as efficient as we can so we can deliver the best service for you |
| Ensuring the confidentiality of commercially sensitive information | For our legitimate interests or those of a third party, i.e. to protect trade secrets and other commercially valuable information To comply with our legal and regulatory obligations |
| Statistical analysis to help us manage our business e.g. in relation to our user base, services or other efficiency measures | For our legitimate interests or those of a third party, i.e. to be as efficient as we can so we can deliver the best service for you |
| Preventing unauthorised access and modifications to systems | For our legitimate interests or those of a third party i.e. to prevent and detect criminal activity that could be damaging for us and for you To comply with our legal and regulatory obligations |
| Updating and enhancinguser records | For the performance of our contract with you or to take steps at your request before entering into a contract To comply with our legal and regulatory obligations For our legitimate interests or those of a third party e.g. making sure that we can keep in touch with our users about new services |
| Statutory returns | To comply with our legal and regulatory obligations |
| Ensuring safe working practices, staff administration and assessments | To comply with our legal and regulatory obligations For our legitimate interests or those of a third party e.g. to make sure we are following our own internal procedures and working efficiently so we can deliver the best service to you |
| Marketing our services and those of selected third parties to: · existing and former customers; · third parties who have previously expressed an interest in our services; · third parties with whom we have had no previous dealings. | For our legitimate interests or those of a third party i.e. to promote our business to existing and former users |
| External audits and quality checks | For our legitimate interests or a those of a third party i.e. to maintain our accreditations so we can demonstrate we operate at the highest standards To comply with our legal and regulatory obligations |
The above table does not apply to special category personal information, which we will only process with your explicit consent.
Promotional communications
We may use your personal information to send you updates (by email, text message, telephone or post) about our services including, offers, promotions or new services. We have a legitimate interest in processing your personal information for promotional purposes (see above How and why we use your personal information). This means we do not usually need your consent to send you promotional communications. However, where consent is needed, we will ask for this consent separately and clearly. We will always treat your personal information with the utmost respect and never sell itto other organisations for marketing purposes. You have the right to opt out of receiving promotional communications at any time by:
- contacting us at optout@139.59.182.125; or
- using the ‘unsubscribe’ link in emails or stop number in texts.
We may ask you to confirm or update your marketing preferences if you instruct us to provide further services in the future, or if there are changes in the law, regulation, or the structure of our business.
Who we share your personal information with
We routinely share personal information with:
- third parties we use to help deliver our services to you;
- other third parties we use to help us run our business, e.g. marketing agencies or website hosts;
- third parties approved by you e.g. social media sites you choose to link your account to; and
- our insurers, brokers, bank, accountants, solicitors and auditors.
We only allow our service providers to handle your personal information if we are satisfied they take appropriate measures to protect your personal information. We also impose contractual obligations on service providers, where appropriate, to ensure they can only use your personal info