If it is worth doing - it is worth doing well

ADS-Limathon Limited Data Privacy Notice - May 2018

 

Data Privacy Notice - Overview

We appreciate you putting your trust in us concerning your personal data. We would like to assure you that we only hold the minimum data required to contact you and deliver services or information from our company. We do not share your data with any third parties. We store your details in a secure database, on a firewall protected server, not in the cloud. Please read this Privacy Notice ("Privacy Notice") carefully as it describes how we collect, use and disclose your personal data. Personal data is any information relating to a living person. In this Privacy Notice, when we refer to "we", "our", "us" or "ADS-Limathon ", we mean ADS-Limathon Limited (“ADSL”) and its affiliated sites, including limathon.com, i-BLIPS.com FootballNewshound.com, MedicalNewshound.com and 3HTs.com) ("Affiliates"). If you have any questions about this Privacy Notice, please contact us using the details in the "How to contact us" at the end of this notice.

What information do we collect about you?

 

Information you give to us

We may collect personal data from you

(a)    When you buy or use our products or services,

(b)    Use any of our Services, Websites or Apps.

(c)    Following an information request from yourself.

(d)    If you sign up to newsletters or other subscription services,

(e)    Enter into offers or promotions

(f)     Interact with us on social media platforms,

(g)   If you contact us, or make a complaint

The categories of personal data we may request include your name, user level, contact information (email, postal address and phone/mobile number), and general information about you such as your experience with ADSL products and services. We may also keep copies of any correspondence you send us which may include personal data.

You should only give us personal data on behalf of someone else if you have their permission to do so or you know that they would not have any objection to us processing their information in accordance with this Privacy Notice.

Information collected automatically

We may also obtain some data by automated means, for example, when you visit our Websites we may collect the IP address of the device you use to connect to the Internet, the geographical location of your device, the browser you are using, the type of device you are using (tablet, mobile, desktop), the URL you came from and the web pages you access. This is normally not personalised data, and is only used in statistical analysis for product development or for optimising security in firewalls .

 

Information from third parties

In our clinical software-as-a-service business (eg BLIPS) your information may be supplied by a third party, (eg, your employer, or a CRO, or a Clinical Trial sponsor) in order to create an account for you in a particular study. There will normally be a contract between yourself and the third party, and a contract between the third party and ourselves.

In our news aggregation services (eg Newshound) we only collect information from our end-users.

We only hold information supplied by our customers, our users, and those who have requested information from us.

We do not use third party mailing lists.

 

How do we use your personal data?

 

We are required by law to provide you with information about the purposes for which we use your information and the legal justification for us to use that information. For example, there may be a legal justification for us to use your personal data where:

  • We need to use your information to deliver a service or information to you or to fulfil a request originated by you.
  • You have given your consent to us to use your information for a particular purpose.
  • Using your information is in our legitimate business interests (provided these interests are balanced against your rights).
  • We need to process your personal data to comply with legal obligations to which we are subject.

 The table below sets out the different purposes for which we may use your personal data and the legal basis for each one. Note that the purposes for which we use your personal data may change from time to time, in which case we will update this privacy notice (see further "Updates to our Privacy Notice" below

Purposes for which we may use your personal data

How we use personal data for this purpose

Legal basis for using personal data for this purpose

Improve your experience in software services,  and in our Apps and on our Websites

We use personal data such as your demographic information, IP address, preferences, site usage information and purchase history to improve your experience in our services. We may use this information to track your activities on our Websites; to recognise device so that you are able to save your preferences and stay logged in to the Website without having to re-enter your online account credentials; and to otherwise enhance, monitor and analyse your usage of the Websites.

Our legitimate business interests in providing the best user experiences to our customers and visitors, to enable the use of our Websites and functionality and to protect their operation, to identify and resolve possible technical issues, and to continuously improve and protect our company, property and customers against fraud (referred to as “our legitimate interest”)

Identify you when you contact us

We may use your name, email address to  identify you when you contact us, for the purposes of processing and fulfilling your requests for products and services and keeping you informed about your requests.

Performance of our contractual obligations, our legitimate interest, or your consent.

Product development, to understand what products and services you might prefer, and tailor your experience according to your preferences

We use personal data (such as your IP address; preferences, and site usage information) to better understand you and your preferences so that we can provide you with tailored offers and personalise your experience when using our services, website or app.

Our legitimate interest, or your consent.

Send you service-related communications regarding your product or any other products you may have with us

We use your personal data to send you service-related communications about your product and other products you have with us, for example to let you know when new topics or functionality is available

Performance of our contractual obligations, our legitimate interest or your consent.

Carry out surveys, research, analysis and customer profiling

We use your email address to carry out market research to help improve our products and services, marketing, Website content, customer service, business planning, online and offline operations and your overall customer experience.

Our legitimate interest or your consent.

Invite Clinical Sites to participate in future Clinical Studies

Clinical Services Only eg BLIPS) We may use the contact information you provide to us (such as  email address) to invite you to participate in new clinical studies.

Your consent.

Answer your technical queries and general enquiries

We use your personal data including to answer your technical queries about our services and any other general enquiries you make.

Performance of our contractual obligations, or our legitimate interest.

Resolve other customer service issues (e.g. organising changes to software or databases)

We use your personal data a when we deal with complaints or other customer service issues, such as deploying new releases.

Performance of our contractual obligations, or our legitimate interest.

Process and track your orders, contracts and change requests

We need to use your personal data to process your orders and keep you informed of their progress.

Performance of our contractual obligations, or our legitimate interest.

Administer service outages

If we become aware of a issue with a particular software service, we need to use your personal data to advise you of service outages, and when the service is back online again.

Compliance with our legal obligations.

Protect the security or integrity of the Websites, our customers and our business in general

We may need to process personal data to protect the security and integrity of our Websites, our customers and our business in general.

Compliance with our legal obligations, our legitimate interest and best business practice.

Send you newsletters and marketing information about our products and services.

We use your personal data to send you newsletters and other information about products and services that you may be interested in, provided this is in line with your marketing choices. You can unsubscribe from marketing communication at any time by following the instructions in any of the messages you receive.

Our legitimate interest or your consent.

Retention of clinical audit trail.

In our clinical applications, (eg BLIPS), if you have assessed patients or entered assesment data, or adjudicated data, your name will be associated with the assessment record and will recorded in the audiit trail for the patient. Note that in the In the EU, clinical trial data may be required to be held for up to 25 years.

Compliance with our legal obligations, customer contracts, or clinical best practices.

Defend our legal rights and protect our business interests

We may need to process personal data in order to defend our legal rights, for example to enforce our terms and conditions or to collect unpaid debts that we are owed.

Our legitimate interest.

 

Providing your personal data to us may be required due to a legal obligation, which could be a statutory or contractual obligation, may be on a voluntary basis or may be necessary for us to enter into the contract with you, depending on the purposes for which we collect and use your personal data as set out in this Privacy Notice. However, if you do not provide your personal data to us this may result in disadvantages to you, e.g. we may not be able to provide certain products or services to you. However, unless otherwise stated, not providing your personal data will not result in legal consequence for you.

Your Data Protection Rights

 

You have the following rights in relation to your personal data:

Your Rights

How we facilitate your rights

Access

 You have the right to request a copy of the personal data we are processing about you, which we will provide back to you in electronic form. For your own privacy and security, in our discretion we may require you to prove your identity before providing the requested information. If you require multiple copies of your personal data, we may charge a reasonable administration fee where we are permitted to do so in accordance with the GDPR.

Rectification

 You have the right to have incomplete or inaccurate personal data that we process about you rectified. Note that you can always make certain adjustments to certain personal data directly through your online account

Deletion

You have the right to request that we delete personal data that we process about you, except we are not obligated to do so if we need to retain such data in order to comply with a legal or contractual obligation or to establish, exercise or defend legal claims.

Portability

 You have the right to obtain personal data we hold about you, in a structured, electronic format, and to transmit such data to another data controller, where this is (a) personal data which you have provided to us, and (b) if we are processing that data on the basis of your consent (such as for direct marketing communications) or to perform a contract with you.

Objection

Where the legal justification for our processing of your personal data is our legitimate interest, you have the right to object to such processing on grounds relating to your particular situation. We will abide by your request unless we have compelling legitimate grounds for the processing which override your interests and rights, or if we need to continue to process the data for the establishment, exercise or defence of a legal claim.

Withdrawing Consent

 

 If you have consented to our processing of your personal data, you have the right to withdraw your consent at any time, free of charge. This includes cases where you wish to opt out from marketing messages that you receive from us. You can unsubscribe from marketing communications at any time by following the instructions in any individual message. The legality of the processing of your personal data prior to you withdrawing your consent remains unaffected by this.

Arbitration

In the event a data protection issue can not be resolved through contacting ADS-Limathon, then If you are based in, or the issue relates to, the UK, the Information Commissioner’s Office can be contacted as follows:

If you are based in the European Economic Area (EAA) or the issue you would like to complain about took place elsewhere in the EEA, you can contact the data protection authority in your place of residence or your country

 

Who do we share your information with ?

 

In general we do not disclose your data to any other party. However depending on the product you are using, and it's licencing agreement, there may be some legal or contractual exceptions to the general rule.

Product

How we share data

BLIPS Entry

BLIPS Certify

BLIPS Dashboard

BLIPS Query

BLIPS Quality

 Patient data is psuedo-anonymised and is stored for for exclusive use by licencee. The licensee must have the patients consent to collect and store the data in our system.

Software users personal data as follows :
Customer / Licensee - No data discosure, unless acting as a referee.
Site Clinician - Training data, exam data. user audit trail - shared with Employer or Licensee
Site Data Entry  - Training data, exam data. user audit trail - shared with Employer or Licensee
Study investigator  - Training data, exam data, user audit trail  -shared with Sponsor and/or CRO
Study Data Entry  - Training data, exam data, user audit trail - shared with Sponsor and/or CRO
Study Team/CRA - Training data, exam data, user audit trail - shared with Sponsor and/or CRO

No other data disclosure without consent

BLIPS Direct

 Patient Self-Assessment Data is stored without patient name, and clinical team (doctors/nurses) have access to the responses in the assessment forms and can identify the patient.

No other data disclosure without patient consent

BLIPS Lifestyle

 Patient Lifestyle Data is stored without patient name, and clinical team (doctors/nurses) have access to the responses in the assessment forms and can identify the patient.

No other data disclosure without patient consent

Football Newshound

 No data disclosure

Medical Newshound

No data disclosure

3HTs

Emergency services - if you are carrying a Healthy Tweeting Emergency Card

Your Doctor - if he has access to Heathly Treating and f you grant him/her access to your data

How long do we keep your personal information?

 

Your personal information is processed by us only for the period necessary for the purposes for which the information is collected, or where we are relying upon your consent until you withdraw that consent. When we no longer need to use your information for those purposes or if we are relying on your consent where you withdraw that consent, we will remove it from our systems and records or take steps to anonymise it so that you can no longer be identified from it (unless we need to keep your information to comply with legal or regulatory obligations to which we are subject).


Purpose

Retention period 

Clinical Data

Patient data is psuedo-anonymised and retention is determined by Licencee.

User's personal data - audit trail, training , exams - retention is determined by Licencee

Note : In the EU data retention of clincal trial data may be as much as 25 years

User Registration Data

 Users of our non-clinical products may be required to register for use. Registration Data is maintained until the account is deactivated or deleted.

Marketing Data

 Corporate Users, past and present, do not need to give consent to continue recieving our news and updates, although we may ask you to give consent.
Private (non-corporeate) users will need to give consent to recieve our news, updates and communications.
For all users, retention on this list is discontinued when the user's consent is revoked, either by e-mail instruction, or by using the Unsubscribe facility in any of our marketing communications.

Updates to our Privacy Notice

 

 As our business changes, from time to time we may need to make changes to the way we collect and use your personal information. Therefore, this Privacy Notice may be updated from time to time. If we make changes to this Privacy Notice, we will notify you of these changes by email and post an alert on the home page of our Website.

This Privacy Notice was last updated: 24 May 2018

Ref ADS-Limathon GDPR PN01

How to Contact us

 

 

If you have any questions or comments about this Privacy Notice or if you would like to make a request relating to your personal data:

.