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Privacy

1. Introduction

1.1 At Immerse Medical Training, we respect your privacy and are committed to safeguarding the privacy of the personal data of our website visitors and service users.

1.2 This policy aims to give you information on how we collect and process your personal data through the use of our website or services provided to you.

1.3 This policy applies where we are acting as a data controller with respect to the personal data of our website visitors, goods and service users; in other words, where we determine the purposes and means of the processing of that personal data.

1.4 We will ask you to consent to our use of cookies in accordance with the terms of this policy when you first visit our website.

1.5 In this policy, “we”, “us” and “our” refers to Immerse Medical Training Ltd. For more information about us, see Section 14.

 

 

2. How we use your personal data

2.1 In this Section 2 we have set out:

(a) the general categories of personal data that we may process;
(b) in the case of personal data that we did not obtain directly from you, the source and specific categories of that data;
(c) the purposes for which we may process personal data; and
(d) the legal bases of the processing.

2.2 We may process data about your use of our website, goods and services (“Usage Data”). The Usage Data may include your IP address, geographical location, browser type and version, operating system, referral source, length of visit, page views and website navigation paths, as well as information about the timing, frequency and pattern of your service use. The source of the Usage Data is Google Analytics. This Usage Data may be processed for the purposes of analysing the use of the website, goods and services. The legal basis for this processing is our legitimate interests, namely monitoring and improving our website, goods and services.

2.3 We may process your account data (“Account Data”). The Account Data may include your name and email address. The source of the Account Data is you or your employer. The Account Data may be processed for the purposes of operating our website, providing our goods or services, ensuring the security of our website, goods and services, maintaining back-ups of our databases and communicating with you. The legal basis for this processing is consent.

2.4 We may process your information included in your personal profile on our website (“Profile Data”). The Profile Data may include your name, address, telephone number, email address, profile pictures, gender, date of birth, relationship status, interests and hobbies, educational details and employment details. The Profile Data may be processed for the purposes of enabling and monitoring your use of our website, goods and services. The legal basis for this processing is consent.

2.5 We may process your personal data that are provided in the course of the use of our services. (“Service Data”). The Service Data may include your name, email address, date of birth, gender, employer, telephone number and the scores and outcomes of any assessments that you undertake. The source of the service data is you or your employer. The Service Data may be processed for the purposes of operating our website, providing our services, ensuring the security of our website, goods and services, maintaining back-ups of our databases and communicating with you. The legal basis for this processing is consent.

2.6 We may process information that you post for publication on our website, or through our goods or services (“Publication Data”). The Publication Data may be processed for the purposes of enabling such publication and administering our website, goods and services. The legal basis for this processing is consent.

2.7 We may process information contained in any enquiry you submit to us regarding goods or services (“Enquiry Data”). The Enquiry Data may be processed for the purposes of offering, marketing and selling relevant goods or services to you. The legal basis for this processing is consent.

2.8 We may process information relating to transactions, including purchases of goods or services that you enter into with us and/or through our website (“Transaction Data”). The Transaction Data may include your contact details, your card details and the transaction details. The Transaction Data may be processed for the purpose of supplying the purchased goods or services and keeping proper records of those transactions. The legal basis for this processing is the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract and our legitimate interests, namely our interest in the proper administration of our website and business.

2.9 We may process information that you provide to us for the purpose of subscribing to our email notifications and/or newsletters (“Notification Data”). The Notification Data may be processed for the purposes of sending you the relevant notifications and/or newsletters. The legal basis for this processing is consent.

2.10 We may process information contained in or relating to any communication that you send to us (“Correspondence Data”). The Correspondence Data may include the communication content and metadata associated with the communication. Our website will generate the metadata associated with communications made using the website contact forms. The Correspondence Data may be processed for the purposes of communicating with you and record-keeping. The legal basis for this processing is our legitimate interests, namely the proper administration of our website and business and communications with users.

2.11 We may process any of your personal data identified in this policy where necessary for the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure. The legal basis for this processing is our legitimate interests, namely the protection and assertion of our legal rights, your legal rights and the legal rights of others.

2.12 We may process any of your personal data identified in this policy where necessary for the purposes of obtaining or maintaining insurance coverage, managing risks, or obtaining professional advice. The legal basis for this processing is our legitimate interests, namely the proper protection of our business against risks.

2.13 In addition to the specific purposes for which we may process your personal data set out in this Section 2, we may also process any of your personal data where such processing is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.

 

 

3. Providing your personal data to others

3.1 We may disclose your personal data to our insurers and/or professional advisers insofar as reasonably necessary for the purposes of obtaining or maintaining insurance coverage, managing risks, obtaining professional advice, or the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure.

3.2 We may disclose any of your personal data identified in this policy to our awarding organisations. Namely Qualsafe Awards identified at http://www.qualsafeawards.org insofar as reasonably necessary for the proper administration and recording requirements of regulated qualifications.

3.3 Financial transactions relating to our website, goods and services are handled by our payment services providers, Stripe and Square Up International Limited. We will share transaction data with our payment services providers only to the extent necessary for the purposes of processing your payments, refunding such payments and dealing with complaints and queries relating to such payments and refunds. You can find information about the payment services providers’ privacy policies and practices at
https://stripe.com/gb/privacy
https://squareup.com/gb/legal/privacy

3.4 We may disclose your Enquiry Data to one or more of those selected third party suppliers services identified on our website for the purpose of enabling them to contact you so that they can offer, market and sell to you relevant services. Each such third party will act as a data controller in relation to the enquiry data that we supply to it; and upon contacting you, each such third party will supply to you a copy of its own privacy policy, which will govern that third party’s use of your personal data.
3.5 In addition to the specific disclosures of personal data set out in this Section 3, we may disclose your personal data where such disclosure is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person. We may also disclose your personal data where such disclosure is necessary for the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure.
3.6 Where data received by us is reportable under Reporting of Injuries, Diseases and Dangerous Occurrences Regulations 2013 (RIDDOR 2013), the data will be automatically passed to the Health and Safety Executive via the Air software portal.

 

 

4. International transfers of your personal data

4.1 In this Section 4, we provide information about the circumstances in which your personal data may be transferred to countries outside the European Economic Area (EEA).

4.2 The hosting facilities for our website are situated in the United Kingdom, the United States of America and Germany. The European Commission has made an “adequacy decision” with respect to the data protection laws of each of these countries. Transfers to each of these countries will be protected by appropriate safeguards, namely the use of standard data protection clauses adopted or approved by the European Commission.

4.3 You acknowledge that personal data that you submit for publication through our website, goods or services may be available, via the internet, around the world. We cannot prevent the use (or misuse) of such personal data by others.

 

 

5. Retaining and deleting personal data

5.1 This Section 5 sets out our data retention policies and procedure, which are designed to help ensure that we comply with our legal obligations in relation to the retention and deletion of personal data.

5.2 Personal data that we process for any purpose or purposes shall not be kept for longer than is necessary for that purpose or those purposes.

5.3 We will retain your personal data as follows:

(a) Personal data will be retained for a minimum period of 3 years, and for a maximum period of 6 years.

5.4 Notwithstanding the other provisions of this Section 5, we may retain your personal data where such retention is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.

 

 

6. Amendments to this privacy policy and your duty to inform us of changes

6.1 We may update this policy from time to time by publishing a new version on our website.

6.2 You should check this page occasionally to ensure you are happy with any changes to this policy.

6.3 We may notify you of changes to this policy by email.

6.4 It is important that the personal data that we hold about you is accurate and current. Pease keep us informed if your personal data changes during your relationship with us.

 

 

7. Your rights

7.1 In this Section 7, we have summarised the rights that you have under data protection law. Some of the rights are complex, and not all of the details have been included in our summaries. Accordingly, you should read the relevant laws and guidance from the regulatory authorities for a full explanation of these rights.

7.2 Your principal rights under data protection law are:

(a) the right to 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;
(b) the right to rectification 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;
(c) the right to 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;
(d) the right to restrict 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.;
(e) the right to 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;
(f) the right to withdraw consent 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.
(g) 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.

7.3 To the extent that the legal basis for our processing of your personal data is:

(a) consent; or
(b) that the processing is necessary for the performance of a contract to which you are party or in order to take steps at your request prior to entering into a contract,
and such processing is carried out by automated means, you have the right to receive your personal data from us in a structured, commonly used and machine-readable format. However, this right does not apply where it would adversely affect the rights and freedoms of others.
7.4 If you consider that our processing of your personal information infringes data protection laws, you have a legal right to lodge a complaint with a supervisory authority responsible for data protection. You may do so in the EU member state of your habitual residence, your place of work or the place of the alleged infringement.
7.5 To the extent that the legal basis for our processing of your personal information is consent, you have the right to withdraw that consent at any time. Withdrawal will not affect the lawfulness of processing before the withdrawal.
7.6 You may exercise any of your rights in relation to your personal data by written notice to us in addition to the other methods specified in this Section 7.

 

 

8. Change of Purpose

8.1 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.
8.2 If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis for which the law allows us to do so.
8.3 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.

 

 

9. If you fail to provide personal data

9.1 Where we need to collect your 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 goods or services).

 

 

10. About cookies

10.1 A cookie is a file containing an identifier (a string of letters and numbers) that is sent by a web server to a web browser and is stored by the browser. The identifier is then sent back to the server each time the browser requests a page from the server.

10.2 Cookies may be either “persistent” cookies or “session” cookies: a persistent cookie will be stored by a web browser and will remain valid until its set expiry date, unless deleted by the user before the expiry date; a session cookie, on the other hand, will expire at the end of the user session, when the web browser is closed.

10.3 Cookies do not typically contain any information that personally identifies a user, but personal information that we store about you may be linked to the information stored in and obtained from cookies.

 

 

11. Cookies that we use

11.1 We use cookies for the following purposes:
(a) authentication – we use cookies to identify you when you visit our website and as you navigate our website
(b) status – we use cookies [to help us to determine if you are logged into our website
(c) personalisation – we use cookies to store information about your preferences and to personalise the website for you
(d) security – we use cookies as an element of the security measures used to protect user accounts, including preventing fraudulent use of login credentials, and to protect our website, goods and services generally
(e) advertising – we use cookies to help us to display advertisements that will be relevant to you
(f) analysis – we use cookies to help us to analyse the use and performance of our website, goods and services.
(g) cookie consent – we use cookies to store your preferences in relation to the use of cookies more generally.

 

 

12. Cookies used by our service providers
12.1 Our service providers use cookies and those cookies may be stored on your computer when you visit our website.
12.2 We use Google Analytics to analyse the use of our website. Google Analytics gathers information about website use by means of cookies. The information gathered relating to our website is used to create reports about the use of our website. Google’s privacy policy is available at: https://www.google.com/policies/privacy/.

 

 

13. Managing cookies
13.1 Most browsers allow you to refuse to accept cookies and to delete cookies. The methods for doing so vary from browser to browser, and from version to version. You can however obtain up-to-date information about blocking and deleting cookies via these links:
(a) https://support.google.com/chrome/answer/95647?hl=en (Chrome);
(b) https://support.mozilla.org/en-US/kb/enable-and-disable-cookies-website-preferences (Firefox);
(c) http://www.opera.com/help/tutorials/security/cookies/ (Opera);
(d) https://support.microsoft.com/en-gb/help/17442/windows-internet-explorer-delete-manage-cookies (Internet Explorer);
(e) https://support.apple.com/kb/PH21411 (Safari); and
(f) https://privacy.microsoft.com/en-us/windows-10-microsoft-edge-and-privacy (Edge).
13.2 Blocking all cookies will have a negative impact upon the usability of many websites.
13.3 If you block cookies, you will not be able to use all the features on our website.

 

 

14. Our details

14.1 This website is owned and operated by Immerse Medical Training Ltd.

14.2 We are registered in England and Wales under registration number 10511201, and our registered office is at 80 St Mary’s Road, Poole, Dorset, BH15 2LL.

14.3 Our principal place of business is at Weighbridge House, Bay Hog Lane, Poole, Dorset, BH15 1JF.

14.4 You can contact us:
(a) by post, to the postal address given above;
(b) using our website contact form;
(c) by telephone, on the contact number published on our website; or
(d) by email, using the email address published on our website from time to time.

 

 

15. Data protection officer

15.1 Our data protection officer’s contact details are: Martin Hyland, Immerse Medical Training, Weighbridge House, Bay Hog Lane, Poole, Dorset, BH15 1JF.

15.2 If you have any questions about this privacy notice, including any requests to exercise your legal rights, please contact our data protection officer using the details set out above.