PRIVACY POLICY

04 June 2020

This privacy policy describes data protection practices of NeoGen Medical Education Ltd. and its subsidiaries.

We aim to work in line with global GDPR. We pledge to safeguard and preserve your valued privacy. This privacy policy explains what happens to any personal data that we collect from you and what we might do with it. We will use any information you give us in line with data protection and privacy laws. This means we will make sure you know how we are going to use your information.

We are committed to not share any of your personal data with third parties. Under data protection law, we have to:

Keep only enough data to provide information about our products and services and meet our contractual responsibilities
Tell you about your rights regarding the processing and control of your personal data
Keep your records accurate and held securely
Only keep your information for as long as it is necessary for a specific purpose
Process personal data fairly and lawfully
Be transparent about what information we process and how we use personal information
Give you the option to opt out of data collection by our company.

What is personal data? What personal data do we collect?

Personal data includes information that relates to an identified or identifiable person or company. This may include your name, email address, organization you work for and job title. Information is also collected about how you use the NME website. We collect personal data when you interact with us for a legitimate business purpose as a customer or partner, or when you complete a form on our website.

Information we may collect include:

Your name - first name and last name
Your job title
Your business email address (or personal email address if provided by you)
Name and address of the organization you work for
Your business phone and/or mobile number (or personal number if provided by you)
Your username for logging in to the secure areas of the NME website portals
Details of products or services you have purchased

The personal information we have for you is made up of what you tell us, and data we collect when you use our services, or from related third parties we work with. We may also collect information about your online and website activity such as:

Your IP address
Cookie details
We may track the details of the pages you visit on our website such as pages viewed and the resources that you access. Such information includes traffic, location and other communication data.

Cookies and Tracking technologies

IP address tracking technology is used to analyze data about website traffic to help us improve our services and provide you with more relevant content.
Cookies are used to make the website work better, as well as to provide information on how the site is used
To understand and improve upon how our customers and partners are engaging with our email communications, we may use analytics tools to allow us to analyze open and click rates

How do we collect this data?

When you enter into a legal or financial contractual agreement
When you complete a form on the website
Through the use of cookies when you browse our website
When you provide your details to us at an event/trade show
When you sign up for a webinar
When you register to attend a training course
When you complete an online survey sent by NME
When you register for access to the Support, Partner or Consultant sections of our website
When you send a message to our support team - we collect this data in order to reply to help you and answer your inquiry
When you apply for a job vacancy

Why and how do we use personal data?

Under GDPR, we can only use your personal data if we have a legal or business basis for doing so, e.g.:

For the performance of our contract with you or to take steps at your request before entering into a contract;
To comply with our legal and regulatory obligations;
For our legitimate interests or those of a third party (see below);
For the establishment, exercise or defense of legal claims or proceedings; or
Where you have given consent.

The basis on which we use your personal data

If you have previously purchased products or services from us we use your data to provide to you details of related products or services, or other products and services in which you may be interested.

Marketing

We may use your personal information to tell you about relevant products and offers. This is what we mean when we talk about ‘marketing’.
We study this to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you.
We can only use your personal information to send you marketing messages if we have either your consent or a ‘legitimate interest’ to do so, which is when we have a business or commercial reason to use your information. It must not unfairly go against what is right and best for you.
You can ask us to stop sending you marketing messages by contacting us at any time.
Whatever you choose, you will still receive commercial statements, and other important information such as changes to your existing products and services.
We may ask you to confirm or update your choices, for example, if you take out any new products or services with us in future. We will also ask you to do this if there are changes in the law, regulation, or the structure of our business.
If you change your mind you can update your choices at any time by contacting us.

Processing Personal Data on the basis of consent

Data may be processed if we have gained freely given consent from an individual for any number of reasons outlined above. Consent can be withdrawn at any time by clicking on the unsubscribe link in any of our email communications or send email to info@neogenmedicaleducation.co.uk and we will ensure that your details are removed from our mailing lists as requested within 5-7 business days.

Processing Personal Data for a Legitimate Interest

What does legitimate interest mean?

Legitimate interest means the interests of our company in conducting and managing our business to enable us to give our customers and partners the best and most secure experience. For example, we have an interest in making sure our marketing is relevant for you, so we may process your information to send you marketing that is tailored to your interests and which will enable you to effectively use and/or promote our products and services.

Why would we process your information for a legitimate interest?

We process personal information for certain legitimate business purposes, which include some or all of the following:

Where the processing enables us to enhance, modify, personalize or otherwise improve our products, services and communications for the benefit of our customers and partners
To identify and prevent fraud
To enhance the security of our network and information systems
To better understand how people interact with our websites
To determine the effectiveness of promotional campaigns and advertising
To protect our commercially valuable information and also our intellectual property
To prevent and detect fraud and/or criminal activity that could be damaging for us and for you;
Ensuring we are able to keep up to date with our customers and contacts and developments in their organizations.

Whenever we process data on the basis of legitimate interest we will ensure that we always keep your personal data rights in high regard and take account of these rights. You have the right to object to this processing if you wish, and if you wish to do so please contact info@neogenmedicaleducation.co.uk. Please bear in mind that if you object this may affect our ability to carry out tasks above for your benefit.

Direct Marketing

Any marketing undertaken by NME is processed in compliance with best practices for e-privacy regulation and direct marketing. We may process personal data for direct marketing by email. If you are an existing partner or customer it is important that we are able to keep you updated with the latest news about our products, services and events. We are therefore legally allowed to send direct marketing to personal data obtained using soft opt-in consent.

Processing Personal data with Consent for direct marketing

You may freely consent to your personal data being processed for direct marketing in the following circumstances:

When you tick an optional field for opt-in on a form on the website
Where you click through to opt-in from an opt-in button in an email
When you leave a business card or have your details collected at an event/ trade show - we may verbally ask whether you consent to receive communications from us
Signing a consent statement on a paper form to receive marketing communications - you may be asked to do this at a trade show or event

Where applicable we keep clear records of where, when and how consent was obtained. We process personal data for the purpose of direct marketing by electronic means, i.e., email. For individuals who are not current partners or existing customers, we require that individuals give consent - or opt-in - to receive direct marketing in accordance with applicable laws. We ensure you have a free and fully informed choice to exercise your right to consent or actively opt-in. Where explicit consent is to be gathered we endeavor to ensure that you are fully aware of what you are consenting to and how your personal data will be used. These purposes may fall under the section Why and How do we use personal data?

You are able to withdraw your consent at any time by clicking on the Unsubscribe link in any of our email communications or you can email info@neogenmedicaleducation.co.uk and we will ensure that your details are deleted as requested within 5-7 business days.

Disclosing your information

We will NOT share your personal data with our suppliers and service providers for the purposes set out in this privacy policy. Reasons we may disclose your personal data in these certain circumstances:

In accordance with federal laws, to aid any investigation of fraud, theft or where a crime has been committed.
To further protect and reduce the risk of fraud
In the event that we sell any or all of our business to a buyer

Other than for the purposes communicated to you in this privacy policy, we will not share your personal information with any other third parties without your prior information and consent unless we are required to do so by law. Where disclosure to third parties is required by law, our legal basis for processing your information in this way is that it is necessary to comply with a legal obligation that we are subject to.

How long do we keep your personal data?

We do not keep any personal data for any longer than is reasonably necessary. If you are an existing partner or customer, it is important that you receive product and services information to ensure you are kept informed and up to date with the latest news. We will continue holding and processing this personal data until told otherwise e.g. by unsubscribing to marketing communications. For individuals who are not existing channel partners or end users we will keep data until consent is withdrawn, e.g. by unsubscribing to marketing communications or any other means.

Data Storage and Security

We ensure that all data is stored securely. All data is stored on secure servers within the EEA and where applicable is held in password protected accounts and accessible only by relevant personnel of the company. A company-wide firewall is in place to ensure security. Unfortunately, the sending of information via the internet is not totally secure and on occasion such information can be intercepted. We cannot guarantee the security of data that you choose to send us electronically and it will be done so at your own risk. Your personal data will be kept strictly confidential and will not be shared with any third parties unless in relation for a legitimate business purpose, for example, as a customer we may share your information with a relevant channel partner to assist with a specific project or as set out in this privacy policy. Where we disclose personal data to third parties such as our channel partners we require them to adhere to relevant measures to ensure all personal data is protected and securely held.

Your rights

If you ask us to delete your information in accordance with your rights set out below, we will retain basic information on a suppression list to record your request and to avoid sending you unwanted materials in the future. You have the following rights regarding the processing of your personal data:

The right to be informed about privacy information - we have done this in our Privacy Policy.
The right to object to the processing of your personal data based on legitimate interests.
The right to withdraw your consent to processing at any time. This can be done at any time by you by unsubscribing to email communications or emailing info@neogenmedicaleducation.co.uk. This does not affect the lawfulness of processing based on consent before withdrawal;
The right to request your data is erased where it is no longer necessary to retain such data.
The right to port your personal information in certain circumstances;
The right to lodge a complaint with the relevant data protection agency in your region/country
You have a right to see what information we hold about you. This is known as Subject Access and can be obtained by emailing info@neogenmedicaleducation.co.uk
Right to rectification - we ensure that all data that is held is up to date and accurate. You have the right to have any inaccurate personal data we may hold about you rectified.
Right to restrict processing - you may consent not to receive marketing communications when you complete any forms on our website. As a result, we may store your personal data but will not process it for any reason as we do not have your consent.

Changes to our Privacy Policy

We may update this privacy notice where necessary. Please check back frequently to see any changes and where applicable, we will ensure you are informed of any changes that have been made.

If you would like to contact us regarding any matter relating to this Privacy Policy, get in touch with us at info@neogenmedicaleducation.co.uk