How we protect and manage your personal data
We at PBB Group are committed to protecting and respecting your privacy. It is important that you know exactly what we do with personal information that you and others provide to us, why we gather it and what it means to you
This document is being provided to you in line with our obligations under the General Data Protection Regulation (GDPR), in force on 25 May 2018. From that date, the GDPR, together with applicable requirements in the United Kingdom, governs data protection law and places enhanced accountability and transparency obligations on organisations when using your information. The GDPR also introduces changes which give you greater control over your personal information, including a right to object to processing of your personal information where that processing is carried out for our business purposes.
Please take time to read this notice carefully. If you have any questions about how we use your information, please contact us by mail at firstname.lastname@example.org. If you are under 16 years of age, please read this summary with a parent or guardian and ensure you understand it.
This notice explains how we use your information and what rights you have in relation to your personal information.
1. Who we are
Throughout this document, “we”, “us”, “our” and “ours” refer to Pro Bono Bio plc and its affiliates (the “PBB Group”). Your information is held by the PBB Group. For more information about us, please see www.probonobio.com.
2. The information we collect from you
We will hold
- data to identify you, including your contact information
- information which you consent to us using, including the examples given below;
- information about you provided by others, including the examples given below; and
- other personal information such as information provided by you when exercising your rights
We may use your information whether or not you are our customer. For example, you may be a potential customer or you may not have a contract with us.
Examples of information which you will have consented to us using
- Information you give us. You may give us information about you by filling in forms on our websites or by corresponding with us by phone, e-mail or otherwise. This includes information you provide when you register to use our websites, subscribe to our service, search for a product, place an order on our websites, participate in discussion boards or other social media functions on our websites, enter a competition, promotion or survey and when you report a problem with our websites. The information you give us may include your name, address, e-mail address and phone number, financial and credit card information, personal description and photograph.
- Information we collect about you. With regard to each of your visits to our websites we may automatically collect the following information:
- technical information, including the Internet protocol (IP) address used to connect your computer to the Internet, your login information, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform;
- information about your visit, including the full Uniform Resource Locators (URL) clickstream to, through and from our websites (including date and time); products you viewed or searched for; page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), and methods used to browse away from the page and any phone number used to call our customer service number.
Examples of information about you provided by others
- We may receive information about you if you use any of the websites we operate or the other services we provide. In this case we will have informed you when we collected that data that it may be shared internally and combined with data collected on our websites. We are also working closely with third parties (including, for example, business partners, sub-contractors in technical, payment and delivery services, advertising networks, analytics providers, search information providers, credit reference agencies) and may receive information about you from them.
3. When we collect your information
We collect information: (i) you give us; (ii) information from your use of our products, services or our websites and mobile apps, and; (iii) information provided to us by third parties.
4. How we use your information and the legal basis
We use, and share, your data where:
- you have agreed or explicitly consented to the using of your data in a specific way (you may withdraw your consent at any time);
- use is necessary in relation to a service or a contract that you have entered into (e.g. to provide you with our product) or because you have asked for something to be done so you can enter into a contract with us or benefit from our products or services;
- use is necessary because we have to comply with a legal obligation (e.g. complying with regulatory authorities and law enforcement);
- use is necessary to protect your “vital interests” in exceptional circumstances;
- use for our legitimate interests (which you may object to) such as managing our business including conducting marketing activities, your purchase of goods or services from us, training and quality assurance, strategic planning and the purchase or sale of assets.
5. How we use automated processing or “analytics”
We may analyse your information using automated means to:
- help us understand your needs and develop our relationship with you;
- help us offer you products and service information we believe will be of interest to you;
- measure or understand the effectiveness of advertising we serve to you and others, and to deliver relevant advertising to you;
- in relation to our websites (including for this purpose our mobile apps):
- to administer our websites and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes;
- to improve our websites to ensure that content is presented in the most effective manner for you and for your device;
- to allow you to participate in interactive features of our websites, when you choose to do so;
- to fulfil your purchases of goods or services from us and communicate with you about your purchases;
- to keep our websites safe and secure, including by use of your IP address;
- to make suggestions and recommendations to you and other users of our websites about goods or services that may interest you or them
The types and sources of the information we process by automated means about you are listed above in Sections 2 and 3. We also use automated processing to assist in compliance with our legal obligations, for example in connection with the regulation of our products as medical devices in our relevant markets.
6. Who we share your information with
We do not sell, trade, or rent your information to others. When providing our products and/or services to you, we may share your information with:
- your authorised representatives;
- third parties with whom: (i) we need to share your information with to facilitate transactions you have requested; and (ii) you ask us to share your information;
- companies within the PBB Group;
- services providers who provide us with support services;
- advertisers and advertising networks that require the data to select and serve relevant adverts to you and others;
- business partners, suppliers and sub-contractors for the performance of any contract we enter into with them or you;
- statutory and regulatory bodies (including central and local government) and law enforcement authorities;
- credit reference agencies for the purpose of assessing your credit score where this is a condition of us entering into a contract with you;
- third parties in connection with a sale or purchase of assets by us: persons making an enquiry or complaint; debt collection agencies, budgeting and advice agencies, tracing agencies, receivers, liquidators, the Official Receiver and equivalent in other jurisdictions;
- analytics and search engine providers that assist us in the improvement and optimisation of our websites;
- trade associations and professional bodies, non-statutory bodies and members of trade associations;
- pension fund administrators and insurers;
- healthcare professionals and medical consultants;
- any prospective buyer of Pro Bono Bio plc or its businesses, companies or assets; and
- business or joint venture partners.
7. How long we hold your data
How long we hold your data for is subject to legislation and regulatory rules we must follow, set by authorities such as the Medicines and Healthcare products Regulatory Agency and the type of product or service provided to you.
8. Implications of not providing your data
If you do not provide information we may not be able to
We will tell you when we ask for information which is not a contractual requirement or is not needed to comply with our legal obligations.
9. Using companies to process your information outside the European Economic Area (EEA)
In some cases, we may transfer information about you and your products and services with us to our service providers and other organisations outside the EEA. We will always take steps to ensure that any transfer of information outside the EEA is carefully managed to protect your privacy rights.
10. How to exercise your information rights including the right to object
From 25 May 2018, you will have several enhanced rights in relation to how we use your information, including the right, without undue delay, to:
- find out if we use your information, access your information and receive copies of your information;
- have inaccurate/incomplete information corrected and updated;
- object to particular use of your personal data for our legitimate business interests or direct “marketing purposes”;
- in certain circumstances, to have your information deleted or our use of your data restricted;
- in certain circumstances, a right not to be subject to solely automated decisions and where we make such automated decisions, a right to have a person review the decision;
- exercise the right to data portability (i.e. obtain a transferable copy of your information we hold to transfer to another provider);
- to withdraw consent at any time where processing is based on consent.
If you wish to exercise any of your rights, you can contact us at email@example.com or by writing to us at 4th Floor Reading Bridge House, George Street, Reading, Berkshire, RG1 8L.
If we are unable to deal with your request fully within a calendar month we may extend this period by a further two calendar months and shall explain the reason why. If you make your request electronically, we will try to provide you with the relevant information electronically.
You also have the right to complain to the Information Commissioner’s Office:
Tel. 0303 123 1113 (local rate)
11. How to contact us
If you have questions about how we use your information, you can reach us by mail at firstname.lastname@example.org.
We will update our Data Privacy Notice from time to time. Any updates will be made available on this website and, where appropriate, notified to you by e-mail.
Date: 16 May 2018