Contact Details

If you have any questions about this privacy policy or our privacy practices, please contact our data privacy manager in the following ways

Full name of legal entity: Datapharm Limited

Email address: [email protected]

Postal address:

Datapharm Limited
Cassini Court
Randalls Way
Leatherhead
Surrey KT22 7TW

You have the right to make a complaint at any time to the Information Commissioner's Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.

Information collection and use

Personally identifiable information, means any information about an individual from which that person can be identified. It does not include information where the identity has been removed (anonymous data).

We may collect, use, store and transfer different kinds of personally identifiable information about you which we have grouped together as follows:

• Identity Data - this includes first name, last name, username or similar identifier, title.
• Contact Data this includes email address and telephone numbers.
• Technical Data this includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access this website.
• Profile Data this includes your username and password, your preferences, feedback and survey responses.
• Usage Data includes information about how you use our website.
• Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.

We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data could be derived from your personally identifiable information but is not considered personal data in law as this data will not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personally identifiable information which will be used in accordance with this privacy policy.

How is your data collected?

We use different methods to collect personally identifiable information from and about you including through:

• Direct interactions. You may give us your Identity or Contact Data by registering with the emc website or by corresponding with us by post, phone, email or otherwise.
• Automated technologies or interactions. As you interact with the emc website, we will automatically collect Usage Data and Technical Data about your equipment, browsing actions and patterns. We collect this personally identifiable information by using cookies and other similar technologies. Please see our cookie policy (Cookie policy) for further details.
• Third parties. We will receive Usage Data and Technical Data about you from our analytics providers such as Google who are based outside the EU and if you are a business user from our marketing provider HubSpot.

We do not collect or store any personally identifiable information about users of Datapharm products unless you voluntarily provide this information. You might voluntarily provide information when you:

• Contact us and we may keep a copy of the correspondence.
• Register to use our services.
• Log into Datapharm product websites
• Fill in a form to attend any of our events, meetings or training sessions
• Voluntarily complete a survey for research purposes; or
• Accept our user behaviour tracking cookies

How we use your data

We always aim to ensure that any personally identifiable information that we collect will be adequate, relevant, and not excessive for the purpose or purposes for which the personally identifiable information is stored and/or processed.

We will only use your personally identifiable information when the law allows us to. Most commonly, we will use your personally identifiable information in the following circumstances (being the lawful basis for our processing):

• Where you consent i.e. by accepting our data practices as set out in this privacy policy
• Where we need to perform the contract we are about to enter into or have entered into with you;
• 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; and
• Where we need to comply with a legal obligation.

We do not sell any personally identifiable information to any third parties.

We will only use the information you provide us to:

• Respond to your enquiries or requests;
• Notify you about changes to our services
• Carry out our contractual obligations;
• Provide you with relevant information about our products, services or training;
• Assess the user experience of the emc websites; and
• Identify any unauthorised use of the emc websites

We may disclose your personally identifiable information to third parties, but only under the following limited circumstances:

• where we are under a legal obligation to do so. For example:
  • if you provide safety data about a medicine we are obliged to pass this information to the company that markets that medicine so that they can fulfil their safety reporting obligations;
  • in response to any demand by law enforcement authorities in connection with a criminal investigation, or civil or administrative authorities in connection with a pending civil case or administrative investigation,
• where we choose to sell, transfer or merge parts of our business or our assets. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy policy; or
• where we choose to sell, transfer or merge parts of our business or our assets. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy policy; or

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

Change of Purpose

We will only use your personally identifiable 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 you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.

If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

Processing of Special Category Data Whilst the intention of our products is not to collect special categories of personally identifiable information (i.e. information concerning your health), we are mindful of the fact that linking your Usage Data and/or Profile Data to your personally identifiable information may inadvertently reveal information concerning your health.

As detailed further in our cookie policy (Cookie policy), when you use our product websites, we collect details of visitor behaviour patterns. For example, we collect the total number of visits to our websites, the number of visitors to each page and the domain names of our visitors' internet service provider. We use this information to analyse trends, administer the site and track users' movements so that we can improve our product websites and identify unauthorised use of our websites.

Our lawful basis for such processing is to rely on your explicit consent for us to do so. If you do not wish for your Usage Data to be processed in such a manner, please ensure that the relevant cookies are turned off (see our cookie policy for further details) and do not save or bookmark any preferences to your profile.

Please also note that we may use the Usage Data described above to provide analytical data to our customers, in order to assist them with trend analysis. Where we do share such analytical data, all personally indefinable information will be anonymised and therefore our customers will not be able to identify you personally from the analytical data we share with them.

We will take your acceptance of our privacy policy during registration and your continued use of the emc websites, as your explicit consent to process your Usage and/or Profile Data for the purposes described above. We therefore rely on your explicit consent as the lawful basis for the processing of any special categories of personally indefinable information.

How we will safeguard this data

We have procedures in place to ensure that we only process these special categories of personal information in accordance with the law. We ensure that:

(i) this personal information is processed lawfully, fairly and in a transparent manner. Our privacy policy sets out the legal bases on which we rely to process personal information for various purposes;

(ii) we only collect this personal information for specified, explicit and legitimate purposes and we only process the information for these purposes. A further explanation as to the purposes for which we collect personal information can be found in our privacy policy;

(iii) any personal information we collect is adequate, relevant and limited to what is necessary in order to provide you with our services;

(iv) this personal information is accurate and kept up to date as we require you to input your personal information on our website each time you use our services;

(v) we keep this personal information in a form which allows identification; and

(vi) we keep this personal information secure as we have put in place appropriate security measures to protect personal information from being accidentally lost, used, or accessed in an unauthorised way.

Links to Other Websites

Datapharm product websites may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave the emc websites, we encourage you to read the privacy policy of every website you visit.

Your Choices

You can choose not to submit any personally identifiable information to our websites. If you choose to submit information, you have the right to see and correct the information at any time, either by contacting us or, if you have access, using our systems to update your own data.

We strive to provide you with choices regarding certain personally identifiable information uses, particularly around marketing and advertising. If you receive communications, such as updates and newsletters from us, you can opt out at any time, by following the instructions in the communication. We will obtain your express opt-in consent before we share your personal data with any third party for marketing purposes.

You can prevent our use of cookies by following the instructions in our Cookie Policy (Cookie policy).

It is important to us that all personally identifiable information we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.

Where we store your personally identifiable information

Any personally identifiable information that you provide will be stored on secure servers. The data will primarily be stored and processed in the UK. As some of our external third-party providers are based outside the European Economic Area (EEA), your personally identifiable information may from time to time be stored and processed on servers located outside the EEA. Where your personally identifiable information is transferred outside of the EEA, we ensure that a similar degree of protection is afforded to it by ensuring at least one of the following safeguards are implemented:

• We will only transfer your personally identifiable information to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission.
• 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.

Please contact us if you want further information on the specific mechanism used by us when transferring your personally identifiable information out of the EEA.

Data Security

We have put in place appropriate security measures to prevent your personally identifiable information from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personally identifiable information to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personally identifiable information on our instructions and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected personally identifiable information breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

How Long Will You Use My Personally Identifiable Information For?

We will only retain your personally identifiable information for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personally identifiable information for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.

To determine the appropriate retention period for personally identifiable information, we consider the amount, nature and sensitivity of the personally identifiable information, the potential risk of harm from unauthorised use or disclosure of your personally identifiable information, the purposes for which we process your personally identifiable information and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.

In some circumstances we will anonymise your personally identifiable information (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.

Details of retention periods for different aspects of your personally identifiable information are available upon request.

Your Legal Rights

Under certain circumstances, you have rights under data protection laws in relation to your personally identifiable information. These are as follows (for further information as to your legal rights please visit the ICO’s website):

Request access to your personally identifiable information (commonly known as a "data subject access request"). This enables you to receive a copy of the personally identifiable information we hold about you and to check that we are lawfully processing it.

Request correction of the personally identifiable information 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.

Request erasure of your personally identifiable information. This enables you to ask us to delete or remove personally identifiable information 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 personally identifiable information 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 personally identifiable information 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.

Object to processing of your personally identifiable information 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 personally identifiable information 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.

Request restriction of processingof your personally identifiable information. This enables you to ask us to suspend the processing of your personally identifiable information in the following scenarios:

• If you want us to establish the data's accuracy.
• Where our use of the data is unlawful but you do not want us to erase it.
• 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.
• You have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.

Request the transfer of your personally identifiable information to you or to a third party. We will provide to you, or a third party you have chosen, your personally identifiable information 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.

Withdraw consent at any time where we are relying on consent to process your personally identifiable information. 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.

If you wish to exercise any of the rights set out above, please contact us.

No Fee Usually Required

You will not have to pay a fee to access your personally identifiable information (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 could refuse to comply with your request in these circumstances.

Time Limit to Respond

We try to respond to all legitimate requests within one month. Occasionally it could 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.

Updates to This Privacy Policy

We may from time to time revise this privacy policy, but we will notify you where we do so. Continued use of Datapharm product websites after receiving notice of a change to this privacy policy indicates your consent to the use of newly submitted information in accordance with the amendments. This privacy policy was last updated in April 2022.

Users of our website

When you use our website, we collect details of visitor behaviour patterns. For example, we collect the total number of visits to our websites, the number of visitors to each page and the domain names of our visitors' internet service provider. We use this information to analyse trends, administer the site and track users' movements so that we can improve our sites. We also use this information to provide certain of our analytics products to our clients, however all such information is provided on an anonymised basis.

Cookie Policy

At emc, we care about our users and we would like to reassure you that you are in control of the data that you are sharing with us.

We use cookies to deliver the best user experience to you and to understand how we can further improve our services.

How to manage cookies

A cookie is a small file of letters and numbers that is transferred from a website, via your web browser and is automatically stored on your device's hard drive. Cookies are widely used to make websites function properly or make them work better.

How do we use cookies?

We use our cookies for:

• Understanding and measuring our user traffic so that we can ensure that we have future capabilities to ensure that the speed of the emc websites stays consistent over time.
• Keeping you logged in every time you visit our website if you are a registered user.
• Ensuring permitted use of the emc website. The emc website offers accessible medicines information to patients and healthcare professionals. The emc websites should not be used for commercial purposes. For more information, please see our Legal and Privacy Policy (Legal and Privacy policy)

Before cookies are placed on your device, a cookie banner will display automatically requesting that you either accept or decline the placement of cookies on your device. By accepting the placement of cookies, you are enabling us to provide the best possible user experience and service to you. You may, if you wish, decline the placement of cookies on your device, unless those cookies are stated as strictly necessary for the proper functioning of the emc websites.

What cookies do we use on emc?

Performance Cookies

Performance cookies enable you to move around the website and use essential features. These cookies are useful for recognising our registered users, so you do not have to login every time you visit the emc websites.

How to manage: Most web browsers are set to accept cookies, but if you do not want to receive cookies, you can change your browser so that it notifies you when cookies are sent to your device or you can refuse cookies altogether (including essential cookies). If you restrict or block web browser cookies, you may find that some aspects of the emc websites will not function properly.

Third party cookies

These cookies are set by a site/service outside of our control. For example, the website might use embedded YouTube or Flickr content, or use third party advertising, and these sites may set their own cookies.

How to manage: you can customise the third-party cookie preferences by accessing the cookie banner, which displays automatically when you visit the emc websites.

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

Changes

We reserve the right to update this Cookie Policy at any time. Unless we advise otherwise, any amendments to this policy will be effective from the date on which an updated Cookie Policy is posted on the emc websites. We encourage you to periodically review this Cookie Policy for the latest information about our use of cookies on the emc websites.

IP address

An Internet Protocol (IP) address is a set of numbers that is automatically assigned to your device when you browse the internet. Our web servers may log the IP address and we may use this data to conduct system administration and to analyse website usage and performance. If you access our sites through mobile or other devices, we may also collect your unique device identifier.