37 Clinical Privacy Policy
Protecting your data, privacy and personal data is very important to 37 Clinical Limited (“us”, “we” or “our”). This privacy policy sets out how we look after your personal data and describes what data we collect through our website. It also refers to other activities of 37 Clinical where personal data may be processed, and tells you about your privacy rights and how the law protects you.
It is important that you read this privacy policy together with any other privacy policy, privacy information or privacy information we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy policy supplements these other privacy documents and is not intended to override them.
1 Who we are
We are 37 Clinical Limited, a company registered in England and Wales with company number 12159220. We are the data controller.
Contact details
If you have any questions, comments or concerns about this privacy policy or our privacy practices, or would like to exercise any of your legal rights, please contact [us OR our data privacy manager] using the details below:
Email address: [email protected]
Address:
37 Clinical Ltd, St Johns Innovation Centre, Cowley Road, Cambridge, CB4 0WS
Third-party links
This website 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 our website, we encourage you to read the privacy policy of every website you visit.
2 The data we collect about you
This website is not intended for children and we do not knowingly collect data relating to children.
We may collect, use, store and transfer different kinds of personal data about you as a result of your interactions with us. Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).
We may collect, use, store and transfer different kinds of personal data about you. The types of personal data which we collect are grouped together for ease of reference within this policy as follows:
- Identity Data includes information about you such as you name, date of birth, address, email, telephone number and username or similar identifier.
- Technical Data includes information such as your 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. It also includes details of your visit to the website such as page interaction information and length of visits to certain pages.
- Special Categories of Personal Data (includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data) or criminal convictions or offences data.
We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity.
Your duty to inform us of changes
It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.
If you fail to provide personal data
Where we need to collect personal data by law, or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you.
3 How is your personal data collected?
We use different methods to collect data from and about you including through:
Direct interactions. You provide Identity Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
correspond with or contact us;
create or set up an account within our mobile application;
provide feedback;
apply for a job;
enter into or discuss entering into a contract with us.
Automated technologies or interactions. As you interact with our website, we will automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies and other similar technologies. We may also receive Technical Data about you if you visit other websites employing our cookies.
Third parties or publicly available sources. We may receive personal data about you from various third parties and public sources as set out below:
· analytics providers such as Google based outside the UK;
Identity Data from publicly available sources such as Companies House and the Electoral Register based inside the UK.
4 How we use your personal data
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:
- 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.
- Where we need to comply with a legal or regulatory obligation.
We will not routinely collect any Special Categories of Personal Data or data relating to criminal convictions or offences about you through our website. We may collect these types of data through other channels (for example through our products or during a recruitment process) and you will be able to find out what we collect and for what purposes we will use it when you access the relevant channel. Where this information is provided to us, we will process it in accordance with applicable data protection law.
We will process personal data on the basis of your explicit consent only where there is no other legal basis available.
Purposes for which we will use your personal data collected through the website
We have set out below, in a table format, a description of the ways we plan to use your personal data collected through the website, and which of the legal bases we rely on to do so. 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.
This table does not set out all the ways in which we use personal data as a company and you should refer to any privacy notices, privacy information or separate privacy policies provided to you when you interact with us through other channels.
| Purpose/Activity | Type of data | Lawful basis for processing including basis of legitimate interest |
| To manage our relationship with you which will include: (a) Notifying you about changes to our terms or privacy policy (b) Asking you to leave a review or take a survey | Identity | (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) |
| To respond to your enquiry and to send you the information you have requested | Identity | Necessary for our legitimate interests (to develop our products/services and grow our business) |
| To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data) | (a) Identity (b) Technical | (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 |
| To deliver relevant website content to you | Technical | Necessary for our legitimate interests (to study how people use our website, to grow our business and to inform our marketing strategy) |
| To use data analytics to improve our website | Technical | Necessary for our legitimate interests (to keep our website updated and relevant, to develop our business and to inform our marketing strategy) |
Change of purpose
We will only use your personal data 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.
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.
5 Cookies
We do not use cookies, although the third-party provider of the website may collect Technical Data by using cookies, which are small files of letters and numbers stored (with your consent) on your browser or the hard drive of your device. We do not control this third-party provider and are not responsible for their privacy or cookie statements.
Cookies contain information that is transferred to your device’s hard drive.
If you want, you can block cookies by changing the settings on your browser. Blocking cookies may have an adverse impact upon the presentation of some, or all, of our website.
6 Disclosures of your personal data / who we share your data with
We may share your personal data with the following third parties:
- Service providers acting as processors who provide IT and system administration services, payroll or HR services, or who provide other services to us.
- Professional advisers acting as processors or joint controllers including lawyers, bankers, auditors and insurers who provide consultancy, banking, legal, insurance and accounting services.
- HM Revenue & Customs, regulators and other authorities acting as processors or joint controllers based in the United Kingdom who require reporting of processing activities in certain circumstances.
- If we are under a duty to disclose or share personal data to comply with any legal or regulatory obligation.
We may also have to share your personal data with third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. 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.
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.
- 7 International transfers
In some cases it will be necessary for us to transfer your personal data outside of the UK, where data protection laws may differ. This need may arise, for example, if those individuals or third parties involved in providing support services are not based in the UK. Whenever we transfer your personal data out of the UK, we ensure a similar degree of protection is afforded to it by putting in place appropriate safeguards.
8 Data security
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.
9 Data retention
How long will you use my personal data for?
We will only keep your personal data for as long as reasonably necessary to fulfil the purposes we collected it for. We may retain your personal data 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.
When deciding what the appropriate retention period is, we will take into account:
- 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
- any contractual obligations, applicable statutory or regulatory obligations, tax, accounting or other requirements.
In some circumstances we will anonymise your personal data (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.
10 Your legal rights
Under certain circumstances, you have rights under data protection laws in relation to your personal data which we hold. These include:
- Request access to your personal data.
- Request correction, erasure or restricted processing of your personal data.
- Object to processing of your personal data if we are relying on legitimate and you feel it impacts on your fundamental rights and freedoms.
- Request transfer of your personal data to you, or a third party you have chosen.
- Right to withdraw consent. You have the right to withdraw consent at any time where we are relying on consent to process your personal data.
If you wish to exercise any of the rights set out above, please contact us using the contact details set out above.
You also 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. However, we would appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.
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.
We keep our privacy policy under regular review. This version was last updated on 22 July 2021.