Privacy Policy

Last updated: 29 May 2020

1. Collection of personal information

1.1          We collect personal information from customers (existing and prospective), as well as end users of the Emend UK Limited websites, the ReAbility platform and individuals who engage with us via our social media accounts. We also collect personal information from suppliers, contractors, shareholders, prospective employees, and consumers and other individuals who interact with us for various business and other purposes further listed in section 2.2 below. In this section 1, we explain the kinds of personal information which we usually collect and hold as well as how we collect this information.

1.2          The kinds of personal information Emend will collect and hold about you will depend on the circumstances in which that information is collected. It may include:

(a)           contact details which may include your name, address, email and phone details;

(b)           age or date of birth information;

(c)           personal information that you include in any content that you enter into the Emend websites or the ReAbility Online platform, being any information relating to a natural person who can be identified, directly or indirectly, by reference to that information (e.g. name, identification number, location data, or one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identify of a person);

(d)           information required for you to open a trading or subscription account with us or subscribe to any of the Emend websites or the platform or to otherwise do business with us, including bank account details, and any other relevant financial information;

(e)           your device/s type, dates and times of visits, computer and connection information including browser type and operating system, statistics on page views, traffic to and from the sites and referring website addresses, ad data, IP address, standard web log information including online usage, and any other information or online analytics regarding the use of the Emend websites and the ReAbility Online platform, unless you object to such processing pursuant to rights that exist under the GDPR Privacy Laws;

(f)            information regarding the use of the Emend websites and the ReAbility Online platform, including users’ IP addresses and the dates, the country from which the user accessed the websites and the ReAbility Online platform, times and durations of visits, referring website address and device location, unless you object to such processing pursuant to rights that exist under applicable Privacy Laws (including the GDPR);

(g)           information on your dealings with Emend, including details of the products and services we have provided to you or that you have enquired about, including any additional information necessary to deliver those products and services and respond to your enquiries;

(h)            information regarding the use of the Emend websites and the ReAbility Online platform, including users’ IP addresses and the dates, the country from which the user accessed the websites and the App, times and durations of visits, referring website address and device location;

(j)            any additional information relating to you that you provide to us directly through our websites or the App or indirectly through your use of our websites or the App or online presence or through other websites or accounts from which you permit us to collect information; and

(k)           information you provide to us through customer surveys.

1.3          If you are a healthcare professional, additional personal information we may collect includes:

(a)           your medical specialty; and

(b)           your clinical interests.

1.4          If you are a patient, additional personal information we may collect includes:

(a)           details of your healthcare professional; and

(b)           information about your health, including medical conditions.

1.5          We usually collect personal information either directly from you, someone acting on your behalf, or from third parties through:

(a)           your use of Emend websites and the ReAbility Online platform, including when you register or subscribe for an account, create a profile, post or otherwise submit content or via our use of website analytics;

(b)           use of social media;

(c)           information that you communicate to us including through correspondence, chats, and other social media applications, services or websites, email, telephone, SMS, third party apps and any other forms of communication sent or given to us electronically or in hard copy;

(d)           interaction with our services, content and advertising;

(e)           orders for products or services;

(f)            third party service providers;

(g)           requests for brochures, to join a mailing list or to be contacted for further information about our products or services;

(h)           warranty claims;

(i)            provision of customer service and support;

(j)            our shareholder registry;

(k)           responses to surveys or research conducted by us or on our behalf; and

(l)            entries into competitions or trade promotions conducted by us or on our behalf.

1.6          If you do not provide us with the information we request, we may not be able to fulfil the applicable purpose of collection, such as to supply products or services to you or to assess your application for employment.

1.7          Where reasonable and practicable, we will collect personal information directly from you. If we collect information about you from someone else (for example from someone who supplies goods or services to us), we will ensure you are aware that we have collected personal information about you and the circumstances of the collection and provide any additional disclosure required under GDPR Privacy Laws.

Sensitive Information (or special categories of personal information)

1.8          Given the nature of the Emend websites and the ReAbility Online platform, it is possible that there could be instances where we collect sensitive information or special categories of personal data such as:

(a)           health information or data relating to health; and

(b)           other sensitive information or special categories of personal data, but only where you choose to disclose it to us via the Emend websites and the ReAbility Online platform.

1.9          Depending on the applicable Privacy Laws, we will only collect such information about you:

(a)           with your explicit consent or

(b)           where otherwise permitted by law.

2.          Use and disclosure of personal information

2.1          We will only use and disclose your personal information in accordance with GDPR Privacy Laws and in accordance with this Privacy Policy.

2.2          Our main purposes for collecting, holding, using and disclosing personal information are the following:

(a)           to supply products or services to our customers and end users of our websites and the ReAbility Online platform;

Legal basis: we need to process your personal information in order to perform our contractual obligations to you in relation to the supply of products or services.

(b)           to manage your account with us;

Legal basis: it is in our legitimate business interests to collect and process your personal information to enable us to deliver our goods and related services to you, our customers, and to manage your account with Emend.

(c)           to obtain products and services from our suppliers;

Legal basis: it is in our legitimate business interest to process minimal amounts of business contact information in order to conduct business with our third-party suppliers.

(d)           to respond to enquiries from existing or prospective customers seeking information about our products or services;

Legal basis: it is in our legitimate business interests to collect and process personal information to provide quality customer service and assistance to our valued customers (existing or prospective).

(e)           to assess and process warranty claims;

Legal basis: it is in our legitimate business interests to process your personal information in order to assess and process warranty claims.

(f)            to process and assess employment applications;

Legal basis: it is in Emends legitimate business interest to collect personal information relating to job applicants/candidates. This enables Emend to contact candidates and conduct other reasonable enquiries as part of the recruitment process.

(g)           to enforce agreements between you and Emend;

Legal basis: we may process your personal data for the performance of an agreement between you and Emend (including enforcement of agreements).

(h)           to undertake research and surveys and analyse statistical information including the disclosure of de-identified, aggregated statistics created using your personal information (including health data) to third parties if you have given Emend express consent, in writing, to do so;

Legal basis: it is in our legitimate business interests to collect and process personal information to monitor, evaluate and improve our goods and service offerings and ensure they are tailored to our customers’ needs and preferences. Further, personal data can be shared with approved third parties in circumstances where you have provided express written consent for Emend to do so.

(i)            to communicate updates or orders with you, including for competitions and trade promotions; and

Legal basis: we will only process your data in this way if you have provided consent and have not unsubscribed from receiving such information.

(j)            to comply with legislative and our policy requirements including in relation to occupational health and safety and environmental matters. To provide information to, and respond to queries from, shareholders.

Legal basis: we may need to process your personal information in order to comply with applicable laws.

2.3          We will only use or disclose personal information for a purpose other than for which it was collected or a related purpose if you have consented to such different use or disclosure or to the extent that such use or disclosure is permitted by applicable law.

2.4          In carrying out our business, it may be necessary to share information about you with and between our related bodies corporate and organisations that provide services to us (e.g. our alliance partners). We would not otherwise routinely disclose personal information to an organisation other than as set out in this Privacy Policy unless:

(a)           required or permitted by law;

(b)           we believe it is necessary to provide you with a product or service which you have requested;

(c)           it is necessary to protect the rights, property or personal safety of any of our customers, any member of the public or our interests;

(d)           the assets and operations of our business are transferred to another party as a going concern; or

(e)           you have provided your consent.

3.           Service providers

3.1          Like most large organisations, we use a range of service providers to help us maximise the quality and efficiency of our services and our business operations. This means that individuals and organisations outside of Emend, such as cloud and web hosting service providers, software as a service providers, providers of IT support services, providers of analytics and marketing support services and online payment system providers, will sometimes have access to or be disclosed personal information held by us and may only use it on behalf of us to facilitate our services, provide services on our behalf, perform service-related services or assist us in analysing how our service is used. We require our service providers to adhere to strict privacy guidelines which require the service providers not to keep this information, nor to use it or disclose it for any unauthorised purposes.

3.2          If you are a patient, personal information you provide via the ReAbility Online platform will also be collected by your healthcare professional. Before disclosing your personal information, we recommend that you examine the relevant healthcare practice’s Privacy Policy. Emend is not responsible for the privacy practices of your healthcare professional that might breach your privacy.

4.           Disclosure of personal information outside the jurisdiction of collection

General disclosure

We disclose personal information outside of the jurisdiction from which it was collected. In the conduct of our business, we transfer to, hold or access personal information from the state of Israel. Israel has been recognised by the European Commission as an adequate jurisdiction for processing personal information, which allows a straight-forward movement of personal data between controllers and processors in both jurisdictions.

5. Direct marketing

5.1          Marketing is important to our business’ success. Emend therefore, from time to time, send marketing materials to current or prospective customers. We only do so in accordance with applicable laws (which may or may not require Emend to obtain your prior consent).

5.2          If you are receiving promotional information from us and do not wish to receive this information any longer, please contact Emends Data Protection Officer directly at operations@reabilityonline.co.uk asking to be removed from our mailing lists, or use the unsubscribe facilities included in our marketing communications.

5.3          After you opt-out or update your marketing preferences, please allow us sufficient time to process your marketing preferences. Unless otherwise required to process your requests earlier by law, it may take up to 5 business days to process your opt out requests in relation to receipt of electronic marketing materials such as emails and SMS, and up to 30 days for all other marketing-related requests.

6.            Accessing and correcting the information we keep about you

You have the right to ask us what personal information we are using or storing about you. You can ask us for copies of this information verbally or in writing and you can ask us to correct any personal data we hold about you.

Please contact us in the following ways;

Tel          : +44 7808 142188

Email     : operations@reabilityonline.co.uk

Contact: Data Protection Officer

To exercise any of your ‘Individual Rights’ under GDPR please contact us using the above contact details.

We will take all reasonable steps to action your request within 28 days unless we need to retain the data for legal reasons or to comply with the law of England and Wales.

7.        Retention of personal data

7.1       We will retain and process your personal data only for as long as is necessary for the purposes for which the information is collected. In addition, we will retain and use your personal data to the extent necessary to comply with our legal obligations and exercise our legal rights (for example, if we are required to retain your data to comply with applicable laws), resolve disputes and enforce our legal agreements and policies.

7.2       When we no longer need to use your personal information or retain it pursuant to legal obligations in order to exercise our legal rights, we will remove it from our systems and records or take steps to anonymise it so that you can no longer be identified from it in accordance with relevant Privacy Laws.

8.        Making a complaint

If you have any complaints about how we handle your personal information, or if you have any questions about this policy, please contact us at operations@reabilityonline.co.uk or at the address below:

Data protection Officer
Emend UK Limited
24 Overlea Road
London
E8 9BG

12.2       In most cases we will ask that you put your request in writing to us. We will investigate your complaint and will use reasonable endeavours to respond to you in writing within 30 days of receiving the written complaint. If we fail to respond to your complaint or if you are dissatisfied with the response that you receive from us, you should be aware that you might also have the right to make a complaint to the applicable privacy authorities.

13.        Future changes

13.1       We operate in a dynamic business environment. Over time, aspects of our business may change as we respond to changing market conditions. This may require our policies to be reviewed and revised. We reserve the right to change this Privacy Policy at any time and notify you by posting an updated version of the policy on the Emend websites and the App. If at any point we decide to use personal information in a manner materially different from that stated at the time it was collected we will notify users by email or via a prominent notice on our website.

Cookie Policy

We sometimes use cookie and similar tracking technology on Emend websites and the App to provide information and services to site visitors and improve your experience on our websites and the App. Cookies are pieces of information that a website transfers to your computer’s hard disk for record keeping purposes and are a necessary part of facilitating online transactions, and include standard internet log information and visitor behaviour information. Most web browsers are set to accept cookies. Cookies are useful to keep you signed in, remember your preferences, estimate our number of members and determine overall traffic patterns through our sites.

6.2          If you do not wish to receive any cookies you may set your browser to refuse cookies. This may mean you will not be able to take full advantage of the services on the websites and the App.