Privacy Notice

Creavo Medical Technologies Ltd – Privacy Notice

Welcome to the Creavo Medical Technologies Limited (“Creavo”) privacy notice.

Creavo respects your privacy and is committed to protecting your personal data. This privacy notice will inform you as to how we look after your personal data and tell you about your privacy rights and how the law protects you. The UK and Europe are governed by strict data protection and data privacy laws which we are committed to adhering to, regardless of where in the world your data is collected and processed.

1. Important information and who we are

Purpose of this privacy notice.

In compliance with UK and European data protection regulations, this privacy notice aims to provide you with information on how Creavo collects data from you when:

  • you visit our website or
  • are a recipient of our services or
  • when you make a general enquiry or
  • when you contact us regarding careers opportunities

This website is not intended for children and we do not knowingly collect data relating to children.

It is important that you read this privacy notice together with any other privacy notice or fair processing notice which we may provide. These may be provided on specific occasions when we are collecting or processing personal data about you and are intended to ensure that you are fully aware of how and why we are using your data. This privacy notice supplements the other notices and is not intended to override them.

Creavo is committed to processing personal information about its customers in ways that comply with its legal and regulatory obligations, and to being clear with customers and other stakeholders about what it does with their personal information.

Controller

Creavo is the controller and responsible for your personal data (collectively referred to as Creavo, “we”, “us” or “our” in this privacy notice).

We have appointed a Data Protection Officer (DPO) who is responsible for overseeing questions in relation to this privacy notice. If you have any questions about this privacy notice, including any requests to exercise your legal rights, please contact the DPO using the details set out below.

Contact details

Our full details are:

Full name of legal entity: Creavo Medical Technologies Limited

Email address: dpo@creavomedtech.com

Postal address:CEL House, Westwood Way, Westwood Business Park, Coventry, CV4 8HS, UK.

Telephone number: +44 (0) 1926 670560

As our organisation is headquartered in the UK, the way in which we process data is regulated by the UK supervisory authority which is called the Information Commissioner’s Office (ICO).  Our registration number with the ICO is ZA26052. You have the right to make a complaint at any time to the ICO for data protection issues (www.ico.org.uk). We would, however, appreciate the opportunity to deal with your concerns before you approach the ICO so please contact us in the first instance.

2. Data collection

The terms ‘personal data’, or ‘personal information’, mean any information about an individual from which that person can be identified, either directly (e.g. name), or indirectly (by bringing together different elements of data). It does not include data where the identity has been anonymised.

Creavo may collect personal information which we receive when:

  • you use our website
  • you use our services
  • you contact us or
  • you are a recipient of our services

We may collect, use, store and transfer different kinds of personal data about you which we have grouped together follows:

  • Identity Data includes first name, last name, title
  • Contact Data includes billing address, delivery address, email address and telephone
  • Financial Data includes bank account and payment card details
  • Transaction Data includes details about payments to and from you and other details of equipment you have purchased from us
  • Company data Includes your company’s name, your position in the company; the company’s address, company’s email address and telephone number
  • Usage Data includes information about how you use our website, products and services.
  • Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication

We will only collect Special Category Data in the form of health data which is encrypted, pseudonymised & permission access protected.

Medical data for employees is only collected where there is a requirement to make reasonable adjustments in the workplace. If you are an Employee, please reference the Employee privacy policy notice for employees, contractors and other workers.

We do not collect any other Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, genetic and biometric information). We do not collect any information about criminal convictions and offences.

3. Medical testing data

In order to develop and test our medical devices, we use patient data as part of our development processes. The patient data that is passed to us by our partners is pseudonymised by them prior to transmission to ourselves. We are unable to identify any individual from this data, either directly or indirectly. We have strict data processing agreements in place with each of our partners which prevents the transfer of data that can identify any person. This is further strengthened by our own internal processes and procedures that prevent staff from attempting to ‘de-anonymise’ data.

If you have a concern that your medical data may have been used as part of medical device development, then please contact your Consultant or GP.

Finally, to ensure that we use appropriate processes to develop equipment, we are certified to an international standard, ISO13485. This international standard was written to support medical device developers. We are independently audited on an annual basis by the British Standards Institute to ensure that our management system and processes for the development of devices is robust and effective. Certification to the standard ensures that we are able to deliver consistent design, development, production, installation, and delivery of medical devices that are safe for their intended purpose. ISO13485 provides the basis for CE marking medical devices under European Directives and Regulations.

4. 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 (for example, to provide you with services). In the event that we have to cancel a product or service you receive from us; we will notify you.

5. How do we collect this information?

We collect personal information:

  • directly from customers: e.g. when a customer signs up to receive our services or registers on our website
  • from our partners eg. medical testing data
  • from publicly available sources: social media, internet services.

We are committed to keeping your information up to date as far as is reasonably possible. However, if you believe that we have made an error, then please contact us as we have outlined below and we will use reasonable endeavours to correct.

6. Website cookies

Cookies are small files of letters or numbers downloaded onto a device when users access websites. They are widely used in order to make websites work, or work more efficiently, as well as to provide service information to the owners of the site.

How we use cookies is documented in our cookie policy which can be found HERE but we have summarised the main points below.

Cookie Purpose
Google Analytics We use cookie to gather data about how visitors use our website.  We then use this to help us to improve your experience of our website. The cookies collect information in an anonymous form, and capture information such as the number of visitors to the website, which pages they have used, where they have from etc.
Distillery To support video functionality that may be found throughout the website. In addition to keeping track of the website visitor’s position in a video should playback be interrupted; this cookie also notes user behaviour regarding the video itself.
Cookie Consent We are legally obliged to tell you that we use cookies on our site and gain your consent to their use. We do this via a pop-up message when you first visit us. We store a cookie on your computer so that we know that you have acknowledged the pop-up and the site knows not to show it again

To find out more about cookies, including how to see what cookies have been set, visit www.aboutcookies.org or www.allaboutcookies.org.

Find out how to manage cookies on popular browsers:

To find information relating to other browsers, visit the browser developer’s website.

To opt out of being tracked by Google Analytics across all websites, visit http://tools.google.com/dlpage/gaoptout.

7. Why do we collect this information?

We collect your personal information to:

  • provide you with services that you may request from us.
  • Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those
  • meet our legal and regulatory obligations.

8. Keeping your information safe and secure

Creavo is committed to keeping customers’ personal information secure to protect it from being inappropriately or accidentally accessed, used, shared or destroyed, and against it being lost.

9. Third party access

Access to your personal information is only allowed when required by law, we do not, and will never, sell or share your personal information with third parties.

10. Third Countries or International Organisations

The following third countries (ie. where your information is not held in the European Union / EEA) are listed below will receive your personal data for the processing activity as detailed below :

Third Country (non-EU / non-EEA / International organisation) Purpose of processing Safeguards in place and further information
Xero – hosted in New Zealand and US Accountancy, invoicing etc

Use of Amazon Web Services and Microsoft Azure.

An adequacy statement is in place for all data processing in New Zealand, and the company has certified to US Privacy Shield in the US.

 

A full Statement is here

All other data is processed either in the UK or within the EU.

11. Our Service Providers

This includes external third-party service providers, such as accountants, auditors, experts, lawyers and other outside professional advisors; IT systems, support and hosting service providers; printing, advertising, marketing outsourced service providers that assist us in carrying out business activities.

12. How long do we keep personal information?

We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorized 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 the applicable legal requirements.

By law we have to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for six years after they cease being customers for tax purposes.

In some circumstances you can ask us to delete your personal data. If you would like us to do this, then please contact us at the address below and, where we are able (subject to legal requirements to hold information for a defined period), we will process your request.

In some circumstances we may pseudonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes. Where this has occurred, we may use this information indefinitely without further notice to you.

13. Marketing

If you have consented to receive marketing information, you may opt out at a later date by writing to us at dpo@creavomedtech.com. You have a right at any time to stop us from contacting you for marketing purposes.

14. Access to personal information

Under certain circumstances, you have rights under data protection laws in relation to your personal data.  Your rights are as follows:

  • Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
  • Request correction of the personal data 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 personal data. This enables you to ask us to delete or remove personal data 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 personal data 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 personal data 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 personal data 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 personal data 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 processing of your personal data.  This  enables you  to  ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) 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; or (d) 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 personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data 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 personal data.  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 ever have any concerns that we are not processing your personal information in accordance with the law, please contact us using the email address or postal address below.

No fee is usually required

You will not have to pay a fee to access your personal data (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 may refuse to comply with your request in these circumstances. We will inform you if we believe this to be the case.

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.

Time limit to respond

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

To make a request to Creavo for any personal information we may hold, we need you to contact us by writing to the address provided below:

Creavo Medical Technologies Ltd

Postal address: CEL House, Westwood Way, Westwood Business Park, Coventry, CV4 8HS, UK.

Telephone number: +44 (0) 1926 670560

Or by emailing us at: dpo@creavomedtech.com

We want to make sure that your personal information is accurate and up to date. You may ask us to correct or remove information you think is inaccurate.

15. Changes to our Privacy Policy

We keep our privacy policy under regular review and will place any updates on this web page. This privacy policy was last updated in March 2020.
Previous copies of the policy are available on request.

16. How to contact us

Please contact us if you have any questions about our privacy policy or about information, we hold about you:

Creavo Medical Technologies Ltd

Postal address: CEL House, Westwood Way, Westwood Business Park, Coventry, CV4 8HS, UK.

Telephone number: +44 (0) 1926 670560

Or by emailing us at: dpo@creavomedtech.com