Generally, we do not rely on consent as a legal basis for processing your personal information.  In some circumstances, we may rely upon consent as a basis to send direct marketing communications to you via email or text message, where we are required to do so by law.  However, in other cases we will lawfully rely on our legitimate interest in being able to inform you about relevant Services, in a way which is not overly intrusive.  Regardless of our legal basis for marketing, you have the right to prevent marketing at any time by contacting us at GDPR@welmedical.com or by using the unsubscribe links contained in our emails. If you specifically consent to additional uses of your personal information, we may use your personal information in a manner consistent with that consent.  Separately, your employer may collect consents from you for their own purposes as a data controller.

Where you use the Services at the request of your employer, and we provide Services to your employer, we collect, use and share your personal information for the above purposes at the request of, and in accordance with the directions of your employer. Your employer is the data controller of your personal information for such purposes, and we are the data processor. Your employer has personal information protection policies and processes that may differ from the privacy notice you are currently reading and we recommend that you read such policies before accessing or using the Services.

If you have yourself individually subscribed to the Services, we collect, use and share your personal information for the above purposes for and on your behalf and we are the data processor of your personal information for such purposes.

We will not sell your personal information or share it with third parties for use in advertising or marketing of their products or services.

HOW WE SHARE YOUR INFORMATION

Where you use the Services at the request of your employer, and we provide services to your employer, we share your personal information with your employer for certain purposes as data processor of your employer – see “HOW YOUR PERSONAL INFORMATION IS USED” above.

We use third-party service providers to store and process your personal information. Where our Service is one that is being provided in conjunction with one of our partners, such as the American Red Cross, we will share personal information with that partner for the purpose of issuing certificates of competence endorsed by that partner. Our partners are required by us to provide substantially the same level of security and protection to your personal information as we ourselves are obliged to under this Privacy Statement.

We may share your personal information with our payment processing service providers in connection with the payment processing services that they perform for us in connection with processing your purchase of the Services. They are not authorized by us to use the information for their benefit.

Our service providers have to follow our express instructions when processing personal information you provide and they must comply with appropriate retention and security measures to protect such personal information and we do not allow them to use this information for their own purposes.

We may also share your personal information in response to a request by government or regulatory authorities, law enforcement or an order of the courts; to a potential acquirer of our business; and as permitted by applicable laws and regulations.

Links to other websites. The Websites contain links and interactive features with various social media platforms, such as Facebook, YouTube and Twitter. If you give information to these platforms then your information will be registered on these platforms and will be available to anyone who uses the platforms. If you already use these platforms, their cookies may be set on your device when using our Websites and they may already have certain information about you which they may combine with information collected on our Websites. These features may enable integration and/or access to your social media accounts. We do not control those social media services, your profiles on those services, modify your privacy settings on those services or establish rules about how your information on those services will be used. You and the social media service providers are in control of those issues. You are encouraged to read all policies and information on the applicable social media services to learn more about how they handle your information before using any such features made available to you on the Websites. We are not responsible for any acts or omissions by any social media service provider or your use of features that come from their features or platform.

INTERNATIONAL TRANSFERS OF YOUR PERSONAL INFORMATION

WEL Medical has operations around the world, and we also have partners and service providers who operate in a variety of countries.  As such, your personal information may be moved to, disclosed to or stored by us in countries other than your own country, where the data protection and privacy laws may be different to those in your country. One way in which this may occur is where your personal information is stored in a controlled access repository in the cloud. “In the cloud” refers to servers in a data centre that are managed by a third party and accessible through the Internet, and that data centre may be in a country other than your own. However, we have taken appropriate safeguards to require that your personal information will remain protected in accordance with this Privacy Statement. These include implementing an intra-group agreement based on the European Commission’s Standard Contractual Clauses for transfer of personal information between our group companies as well as supplementary data protection obligations relevant to the country of export in the case of export of personal information from Australia, Canada, Malaysia, Mexico, Poland or Singapore. These also include implementing appropriate data processing agreements with third parties, where relevant.  You acknowledge and agree to this transfer, storing and/or processing outside of your country. 

RETENTION OF YOUR PERSONAL INFORMATION

In the limited circumstances where we are the data controller of your personal information (see “HOW YOUR PERSONAL INFORMATION IS USED” above for further details), we maintain your personal information only for as long as is it is necessary.  In some circumstances we may store your personal information for longer periods of time, for instance where we are required to do so in accordance with legal, regulatory, tax and accounting  requirements. In specific circumstances we may also store your personal information for longer periods of time so that we have an accurate record of your dealings with us in the event of any complaints or challenges, or if we reasonably believe there is a prospect of litigation relating to your personal information or dealings

Where your employer or another organisation is the data controller of your personal information, please refer to their personal information protection policies and processes for information about the relevant retention period(s).

DATA INTEGRITY AND SECURITY

We are committed to the privacy and confidentiality of the personal information in our control or possession (as the case may be). We are obliged to have appropriate physical, electronic and managerial protection measures in place to prevent unauthorized access, erasure, loss, use, processing or disclosure of your personal information, and we take reasonable steps to do so. We will continue to review and update our security measures where appropriate, as new technology becomes available.

Unfortunately, transmission of information via the Internet is not completely secure. Although we use reasonable measures to protect your personal information, we cannot guarantee the security of your personal information.

YOUR RIGHTS

Subject to certain exemptions, and in some cases dependent upon the processing activity we are undertaking, you have certain rights in relation to your personal information:

• To access personal information
• To correct / erase personal information
• To restrict the processing of your personal information
• To transfer your personal information
• To object to the processing of personal information
• To object to how we use your personal information for direct marketing purposes
• To obtain a copy of personal information safeguards used for transfers outside your jurisdiction
• To lodge a complaint with your local supervisory authority or in the case of Australian residents, the right to complain about our processing of your personal information.

Importantly, in situations where we act as a data processor (for example, where we collect personal information from you through the use of our Services, as more fully described throughout this Privacy Statement) you should exercise your rights against the relevant data controller (for example, your employer, where your employer is the customer organisation which has purchased our Services).

How to contact us:

You may contact us in a number of ways listed below in connection with your personal information.

We may ask you for additional information to confirm your identity and for security purposes, before disclosing the personal information requested to you. We reserve the right to charge a fee where permitted by law, for instance if your request is manifestly unfounded or excessive.

If you wish to opt out of marketing communication we send you at any time you can either do this by clicking on the form above or by clicking on the “unsubscribe” link in the marketing emails that we send to you or by contacting us directly GDPR@welmedical.com

1. You may choose to Exercise Your Rights here
   1. If you have any questions about this Privacy Statement including any requests to access, correct or delete the personal information we hold about you or to complain about our handling of your personal information, you can also contact our data protection manager using the details set out below:

WEL Medical

FOR THE ATTENTION OF THE DATA PROTECTION MANAGER

Email: GDPR@welmedical.com

Postal: Unit 1 Chancerygate Way, Farnborough, Hampshire, GU14 8FF, United Kingdom

Additional information for California residents only:

With regard to personal information of California residents, in addition to the information already provided in the sections above, the following additional section of this Privacy Statement also applies to you.

This Privacy Statement does not address or apply to:

• Our handling of personal information which is exempt under section 1798.145 of the California Consumer Privacy Act 2018; or
• Personal information we collect about employees, contractors or job applicants or other individuals who are not California residents; or
• Personal information we collect about persons acting in their capacity as representatives (B2B contacts) of our customers, prospective customers, suppliers and other businesses we conduct business with to the extent that we use this personal information only in the context of conducting our business relationship with their respective business.

Rights for California residents:

You have the right to:

• request that we disclose the categories of your personal information that we have collected, used, disclosed and sold (if applicable) in the 12 months prior to your request as well as the categories of sources of such personal information within the last 12 months prior to your request
• request that we delete your personal information and we will respond to verifiable requests to do so;
• non-discriminatory treatment for the exercise of any of your data protection rights;
• access your personal information in a portable and to the extent, technically feasible, readily usable format that allows you to transmit this information to others without hindrance
• opt-out of the sale of your personal information. We are exempt from providing a notice to opt-out because we do not and will not sell your personal data.

California residents may submit a request to disclose or a request to delete by contacting us in the method described in the How to Contact Us section above.

Additional information for USA and Canada residents

With regard to personal information of USA or Canada residents only, please be aware of the following:

Interest Based Advertising

We may work with third parties to deliver targeted advertising to you when you visit our Websites. We may use Cookies and similar technologies in this process. For example, if you search for information on a particular WEL Medical product, we may cause an advertisement for such a product to appear on other websites that you view. This form of advertising (also known as Interest Based Advertising) is based on non-personal information which does not specifically identify you. As a result, third parties may be aware of your interests but cannot personally identify you in connection with the delivery of that specific advertisement. We believe such advertising is helpful because you will see advertisements that are relevant to your interests and activities. However, you can opt out of targeted advertising from certain providers at www.aboutads.info/consumers. This process relies on an opt out cookie so if you delete your cookies or use a different computer you will have to repeat this process. Please note that by opting out, you will continue to see advertising online but it may not be tailored to your specific interests and activities.

We comply with the Self-Regulatory Principles for Online Behavioural Advertising set forth by the Digital Advertising Alliance.

It is important that the personal information we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.   We will update this Privacy Statement when necessary. All updates will be posted on the Websites. When we post such updates, we will revise the “last updated” date at the top of the statement. We encourage you to periodically review this Privacy Statement to learn how WEL Medical is protecting your information.