1.1 Deepscope Ltd (“we”, “us” or “Deepscope”) take the privacy of your information very seriously. This Privacy Notice is designed to tell you about our practices regarding the collection, use and disclosure of personal information which may be obtained via our apps, websites or other means including online forms, email, or phone.
1.2 This notice applies to personal information provided by our clients, customers and suppliers whose data we process. In this notice “you” refers to any individual whose personal data we hold or process.
1.3 In general, our services relate to the provision tools for developing, creating and sharing simulations and algorithms based on medicaldata. We do not process personal data on a large scale, but we will hold and process personal data in order to supply our services and this policy explains how we do so.
1.4 This notice is governed by the EU General Data Protection Regulation (the “GDPR”), the Data Protection Act 2018 and any other applicable data or privacy legislation.
2. Legal Basis on which we process personal data
2.1 Personal data we hold about you will be processed either because:
2.1.1 the processing is necessary in order for us to comply with our obligations under a contract between you and us, specifically for the provision of our services; or
2.1.2 the processing is necessary in pursuit of a “legitimate interest”, a legitimate interest in this context means a valid interest we have, or a third party has, in processing your personal data which is not overridden by your interests in data privacy and security; or
2.1.3 for certain ‘special categories’ of sensitive personal data including data relating to health which we may process from time to time we will process this data on the basis of your consent.
3. Personal data we collect
3.1 Please note that we will hold anonymous health and medical information (for instance medical images or scans) but this will not constitute personal data as the patient will not be identifiable.
3.2 Below we have set out the categories of data we collect, the legal basis we rely on to process the data and how we process the data:
3.2.1 we will hold contact information for our users who have registered with us such as name, email address, telephone number (for authentication), (“Contact Information”) which we will use to provide our services and communicate with you;
3.2.2 we will hold information about your professional status or role such as your profession, country of residence, grade and professional registration details, job title, your employer or institution (“Professional Information”) which we will use to provide our services and understand who our users are;
3.2.3 user generated content which you post to one of our services such as user comments which may contain personal information (“User Generated Information”) which we will use to display and share comments and other information for our users;
3.2.4 technical information about your interaction with our apps, services and website including the simulations or scans which you access (“Technical Information”) which we use to analyse and improve our services;
3.2.5 a record of any correspondence or communication between you and us (“Communication Information”) which we will use to provide our services and communicate with you;
3.2.6 we will hold information about our suppliers such as contact information (“Supplier Information”) which we will use to procure goods and services from those suppliers;
3.2.7 we may hold certain information about you in order to provide information about our services this may include names, email addresses, phone numbers, addresses, and other information (“Marketing Information”) which we will use to market and promote our services.
3.3 If you are a user of our services we process all of the categories of information above (except for Marketing Information and Supplier Information) on the basis of the performance of our contract with our client and on the basis of our legitimate interest in providing our services to our clients.
3.4 We process Marketing Information on the basis of our legitimate interests in communicating with interested individuals about our services or on the basis that you have consented to receive the information.
3.5 We process Supplier Information on the basis of our legitimate interests in obtaining goods and services from suppliers.
3.6 Generally we will collect information directly from you. If we obtain your personal data from a third party your privacy rights under this notice are not affected and you are still able to exercise the rights contained within this notice.
3.7 You do not have to supply any personal information to us in practice we may be unable to provide our services to you without personal data (for instance we will need contact information in order to communicate with you). You may withdraw our authority to process your personal data (or request that we restrict our processing) at any time but there are circumstances in which we may need to continue to process personal data (please see below).
4. Data Retention
4.1 Our current data retention policy is to delete or destroy (to the extent we are able to) personal data in accordance with the following retention periods:
Information relating to our users
We will hold information for registered and non-registered users for 8 years from the date on which we collect the data, or, if later, from the date on which you cease to be a registered user.
Information relating to our suppliers
We will hold information for suppliers for 8 years from the date on which our agreement with that supplier has been terminated.
Marketing and business development records (where we have not provided services to you and you have not provided information to us)
Up to 3 years from the last date on which you have interacted with us.
4.2 For any category of personal data not specifically defined in this notice, and unless otherwise specified by applicable law or regulations, the required retention period for any personal data will be deemed to be 8 years from the date of receipt by us of that data.
4.3 The retention periods stated in this notice can be prolonged or shortened as may be required (for example, in the event that legal proceedings apply to the data or if there is an on-going investigation into the data).
4.4 We review the personal data (and the categories of personal data) we are holding on a regular basis to ensure the data we are holding is still relevant to our business and is accurate. If we discover that certain data we are holding is no longer necessary or accurate, we will take reasonable steps to correct or delete this data as may be required.
4.5 If you wish to request that data we hold about you is amended or deleted, please see below, which explains your privacy rights.
5. Sharing your information
5.1 We do not disclose any information you provide to any third parties other than as follows:
5.1.1 From time to time we will transfer personal data to our sub-processors which will include our server provider, Google Firebase, and other service and technology providers. If we do supply your personal information to a third party we will take steps to ensure that your privacy rights are protected and that third party complies with the terms of this notice (see below for more information relating to Google Firebase).
5.1.2 Google Firebase operate as our data processor in accordance with the data processing terms set out here: https://firebase.google.com/terms/data-processing-terms/
5.1.4 We may be required to disclose certain data to regulators or other lawful authorities;
5.1.5 We may disclose information to our group companies;
5.1.6 if we are under a duty to disclose or share your personal data in order to comply with any legal obligation (for example, if required to do so by a court order or for the purposes of prevention of fraud or other crime);
5.1.7 in order to enforce any terms and conditions or agreements for our services that may apply;
5.1.8 If we are sub-contracting services to a third party we may provide information to that third party in order to provide the relevant services;
5.1.9 we may transfer your personal information to a third party as part of a sale of some or all of our business and assets to any third party or as part of any business restructuring or reorganisation, but we will take steps with the aim of ensuring that your privacy rights continue to be protected;
5.1.10 to protect our rights, property and safety, or the rights, property and safety of our users or any other third parties. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction.
5.2 Other than as set out above, we shall not disclose any of your personal information unless you give us permission to do so. If we do supply your personal information to a third party we will take steps to ensure that your privacy rights are protected and that third party complies with the terms of this notice.
6.1 We will take all reasonable steps to ensure that appropriate technical and organisational measures are carried out in order to safeguard the information we collect from you and protect against unlawful access and accidental loss or damage. These measures may include (as necessary):
6.1.1 protecting our servers with software firewalls;
6.1.2 locating our data processing storage facilities in secure locations;
6.1.3 encrypting all data stored on our server with an industry standard encryption method that encrypts the data between your computer and our server so that in the event of your network being insecure no data is passed in a format that could easily be deciphered;
6.1.4 when necessary, disposing of or deleting your data so it is done so securely;
6.1.5 regularly backing up and encrypting all data we hold.
6.2 We will ensure that our employees are aware of their privacy and data security obligations. We will take reasonable steps to ensure that the employees of third parties working on our behalf are aware of their privacy and data security obligations.
6.3 This notice and our procedures for handling personal data will be reviewed as necessary.
7. Cookies and IP Address
7.1 A cookie is a piece of data stored locally on your computer and contains information about your activities on the Internet. The information in a cookie does not contain any personally identifiable information you submit to our website.
7.3 Once you close your browser, our access to the cookie terminates. You have the ability to accept or decline cookies. Most web browsers automatically accept cookies, but you can usually modify your browser setting to decline cookies if you prefer. To change your browser settings you should go to your advanced preferences.
7.5 If you choose not to accept the cookies, this will not affect your access to the majority of information available on our website. However, certain online services may not be available.
7.6 An Internet Protocol (IP) address is a number assigned to your computer by your Internet Service Provider (ISP), so you can access the Internet. We may use your IP address to diagnose problems with our server, report aggregate information, and determine the fastest route for your computer to use in connecting to our website, and to administer and improve the website.
8. Your privacy rights
8.1 With respect to your personal data, you have the right to:
8.1.1 request that your personal data will not be processed;
8.1.2 ask for a copy of any personal data that we have about you;
8.1.3 request a correction of any errors in or update of the personal data that we have about you;
8.1.4 request that your personal data will not be used to contact you for direct marketing purposes;
8.1.5 request that your personal data will not be used for profiling purposes;
8.1.6 request that your personal data will not be used to contact you at all;
8.1.7 request that your personal data be transferred or exported to another organisation, or deleted from our records; or
8.1.8 at any time, withdraw any permission you have given us to process your personal data
8.2 All requests or notifications in respect of your above rights may be sent to us in writing at the contact details listed below.
8.3 We will endeavour to comply with such requests as soon as possible but in any event we will comply within one month of receipt (unless a longer period of time to respond is reasonable by virtue of the complexity or number of your requests).
9. Data Breaches
9.1 If personal data we hold about you is subject to a breach or unauthorised disclosure or access, we will report this to the Information Commissioner’s Office (ICO) and/or our data protection manager.
9.2 If a breach is likely to result in a risk to your data rights and freedoms, we will notify you as soon as possible.
10. Transferring your information outside Europe
10.2 We may store personal data on servers currently provided by Google Firebase which may transfer and store data outside of the EU. Under their data processing agreement with us, they agree to ensure that they will protect personal data in accordance with their processing agreement and will either be registered with the EU’s Privacy Shield (under which US companies are deemed by the European Commission to have adequate data protection measures and processes) or will put in place alternative transfer solutions.
10.4 Other than the processing of data by our service providers or server infrastructure we will not transfer your personal data in a systematic way outside of the EU but there may be circumstances in which certain personal information is accessed outside of the EU, for example:
10.4.1 Our users may access user generated content outside of the EU;
10.4.2 If you use our services while you are outside the EU, your information may be transferred outside the EU in order to provide you with our services;
10.4.3 From time to time your information may be stored in devices which are used by our staff outside of the EU (but staff will be subject to our cyber-security policies).
10.5 If we transfer your information outside of the EU, and the third country or international organisation in question has not been deemed by the EU Commission to have adequate data protection laws, we will provide appropriate safeguards and we will be responsible for ensuring your privacy rights continue to be protected as outlined in this notice.
11. Notification of changes to the contents of this notice
We will post details of any changes to our policy on our website to help ensure you are always aware of the information we collect, how we use it, and in what circumstances, if any, we share it with other parties.
12. Contact us
If at any time you would like to contact us with your views about our privacy practices, or with any enquiry or complaint relating to your personal information or how it is handled, you can do so by contacting Kate Jones using the details below:
If we are unable to resolve any issues you may have or you would like to make a further complaint, you can contact the Information Commissioner’s Office by visiting http://www.ico.org.uk/ for further assistance.