CEUTA HEALTHCARE PRIVACY STATEMENT
Welcome to our privacy statement.
Summary
We respect your privacy, and we are committed to protecting your personal data. This privacy statement will explain how we use and look after your personal data when you are a customer or you:
- https://www.ceutahealthcare.com (regardless of where you visit it from) or our social media pages, including:
- https://www.linkedin.com/company/ceuta-healthcare
- https://twitter.com/ceutagroup
- https://www.facebook.com/CeutaGroup.
Together, our website and our pages on social media platforms that we operate are referred to as “our sites” in this privacy statement.
This privacy statement does not apply to you if you work for us or are applying to work for us. In that case, we will provide separate privacy statements that set out that relationship with you. For example, if you use our job application forms via the links on our site.
This privacy statement also tells you about your privacy rights and how the law protects you.
When we say “we”, “us”, “Ceuta Healthcare”, or “Ceuta”, that means the company Ceuta Healthcare Ltd. Ceuta Healthcare is part of The Ceuta Group of Companies which is made up of different companies, details of which can be found here.
This privacy statement is issued on behalf of Ceuta Healthcare Ltd. If your communications with us relate to other Ceuta group companies, we will pass your personal data to them so that they can handle your enquiry. Their privacy statement will also apply to how they process your data.
Where we collect information about you, if that information is about you, or can be used by us or organisations with which we work to find out about you, it is known as “personal data”.
In line with the law, this privacy statement tells you what types of personal data we hold about you, what we use it for, why we are allowed to use it in that way and what your legal rights are.
The rules about personal data are complex. If you need help understanding anything in this privacy statement, please contact us at dataprotection@ceutagroup.com.
The simple version is this:
- We collect information about you, including contact details (like your email address), when you give us that information on our website, when you call us or communicate with us, and when you interact with us on pages on social media platforms that we operate. We also collect other information, for example, via cameras at our offices to make sure that our premises are safe places
- We treat the information that we hold about you very carefully. We do our best to make sure that information about you does not go to the wrong people or to people who might not look after that information properly.
- If you ask us to do certain things with the information that we hold about you, we must usually do what you ask and you do not usually have to pay for this. Those things include:
- Giving you a copy of the information that we hold about you.
- Putting right any mistakes in the information that we hold about you.
- Stopping using information about you or deleting it.
If you want to ask us to do any of these things, or you have any questions or concerns, you can contact us at dataprotection@ceutagroup.com. If you still have concerns, you can also contact the Information Commissioner’s Office (“ICO”). This is the organisation in charge of making sure that we do the right things with your personal data.
BACKGROUND
This privacy statement is addressed to individuals who visit the premises, websites or pages on social media platforms that are operated by Ceuta Healthcare Limited (“Ceuta”, “Ceuta Healthcare”, “we”, “our” or “us”); to our customers; and to other individuals who may deal with us, including individuals at our suppliers. In this privacy statement, we collectively refer to these categories of individuals as “you”.
If you are applying to work for us, or you are one of our staff members or workers, a different privacy statement will apply. In that case, we will provide a separate privacy statement that sets out that relationship with you.
Our privacy statement is split into linked sections so that you can quickly go to a specific section. Alternatively, if you prefer, you can contact us to request a hard copy of the whole privacy statement.
You can check the meaning of some of the terms used in this privacy statement by using the Glossary in the final section.
1. IMPORTANT INFORMATION AND WHO WE ARE
2. THE DATA WE COLLECT ABOUT YOU
3. HOW YOUR PERSONAL DATA IS COLLECTED
4. HOW WE USE YOUR PERSONAL DATA
5. DISCLOSURES OF YOUR PERSONAL DATA
6. INTERNATIONAL DATA TRANSFERS
1. Important information and who we are
Purpose of this privacy statement
This privacy statement details how Ceuta Healthcare collects and processes your personal data when you are a customer or you:
- Visit our website: https://www.ceutahealthcare.com (regardless of where you visit it from) or our social media pages, including:
- LinkedIn: https://www.linkedin.com/company/ceuta-healthcare
- Twitter: https://twitter.com/ceutagroup
- Facebook: https://www.facebook.com/CeutaGroup.
Together, our website and our pages on social media platforms that we operate are referred to as “our sites” in this privacy statement.
- Call us, write to us or communicate with us in any way.
- Visit our premises.
This privacy statement does not apply to you if you work for us or are applying to work for us. In that case, we will provide separate privacy statements that set out that relationship with you. For example, if you use our job application forms via the links on our site.
This website is not intended for children and we do not knowingly collect data relating to children. We may, however, collect information about children when a parent or guardian communicates with us in other ways about our products.
To ensure that you are fully aware of how and why we are using your data, it is important that you read this privacy statement together with any other data protection or privacy statement that we may provide on specific occasions when we are collecting or processing personal data about you. This privacy statement supplements other such statements and privacy policies and is not intended to override them.
Controller
Ceuta Healthcare Limited (referred to as “Ceuta”, “Ceuta Healthcare”, “we”, “us” or “our” in this privacy statement), a limited company registered in England and Wales with registered company number 2974951 and whose registered head office is at Hill House, 41 Richmond Hill, Bournemouth, Dorset BH2 6HS, is the controller and is responsible for your personal data.
In any situations where we are acting as a joint controller, this will be detailed at the point of contact on the relevant product website or will otherwise be communicated to you via a separate privacy notice.
Ceuta Healthcare is part of The Ceuta Group of Companies which is made up of different companies and brands, details of which can be found here.
This privacy statement is issued on behalf of Ceuta. If your communications with us relate to other Ceuta group companies or Ceuta Group brands, then we will, where appropriate, pass your personal data to them so that they can handle your enquiry. The relevant group company or Ceuta brand privacy statement will also apply to how we or they process your data.
Contact details
If you have any questions about this privacy statement (including any requests to exercise your legal rights) or about our privacy practices, please contact our Data Privacy Manager in the following ways:
Email address: dataprotection@ceutagroup.com
Postal address: Ceuta Healthcare Ltd, Hill House, 41 Richmond Hill, Bournemouth, Dorset BH2 6HS
Telephone number: 01202 449781
You have the right to make a complaint at any time to the Information Commissioner’s Office (“ICO”), the UK supervisory authority for data protection issues. We would, however, appreciate the chance to deal with your concerns before you approach the ICO, so we would encourage you to contact us first to discuss these.
Changes to the privacy statement and your duty to inform us of changes
We keep our privacy statement under regular review. This version was last updated on 1st April 2021. Historic versions can be obtained by contacting us.
Any changes that we make to this privacy statement in the future will be posted on this page and, where appropriate, notified to you by email. Please check back frequently to see any updates or changes to our privacy statement.
It is important that the personal data that we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.
Third-party links
Our sites may include links to third-party websites, plug-ins and applications, for your convenience and information. Clicking these links or enabling these connections means that you may leave our sites and may allow third parties to collect or share data about you.
We do not control these third-party websites, the social media platforms themselves or third-party social media accounts or apps. We are not responsible, or liable, for how they process your personal data or for their privacy statements. For example, they may send their own cookies to users, collect data or solicit personal data from you. When you leave our sites, we encourage you to read the privacy statement of every website, app and social media account that you use or visit.
If you are applying to work for us, you may be asked to complete an online application form. This form is provided by a recruitment software provider. All personal data that you provide via that form is stored on our systems, and the provider does not access or otherwise process that information.
2. The data we collect about you
When you contact us through our sites, communicate with us or visit our premises, you may provide us with personal data about you.
Personal data means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).
We may collect, use, store and transfer the following kinds of personal data about you:
- includes your first name, last name, title and company name.
- includes as relevant your business billing address and delivery address, email address and telephone numbers.
- includes bank account and payment card details.
- includes details about payments to and from you, and other details of products and services that you have purchased from us.
- includes credit check information, companies house information, VAT information and bank details confirmation searches.
- includes details about products you have purchased from us, our suppliers or distributors or supplied on our behalf; and details about any adverse events or incidents, product complaints or enquiries in relation to our products (whether that is reported by you as the product user, or you have treated someone in relation to use of our product (e.g. you are a pharmacist, doctor, nurse or similar practitioner). This will include:
- Technical data includes your IP address, login data, browser type and version, time-zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices that you use to access our sites.
- Profile data includes your interests, preferences and feedback.
- Usage data includes information about how you use our sites, products and services.
- Image data includes individual images or general location images in which you might be visible.
- CCTV data includes Image Data and video recordings that may contain personal data that have been collected by our CCTV systems at our premises.
- Accident data includes details about accidents or incidents that have occurred on our premises.
- includes your preferences in receiving marketing from us and our third parties, and your communication preferences.
- Social media data includes communications data via the relevant social media channel and limited identity data where you engage with our social media accounts.
- Communications data includes personal data that is included in your communications with us.
We also collect, use and share aggregated data such as statistical or demographic data for any purpose. Aggregated data could be derived from your personal data but is not considered personal data in law because this data will not directly or indirectly reveal your identity. For example, we may aggregate your usage data to calculate the percentage of users who access a specific website feature. However, if we combine or connect aggregated data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data, which will be used in accordance with this privacy statement.
We do not collect any information about criminal convictions and offences.
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, or we are processing your personal data to fulfil a request you have made or incident you have reported to us in relation to the product, 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) or we may not be able to otherwise comply with your request or deal with that incident. In this case, we may have to cancel a product or service you have with us or we wouldn’t be able to handle your complaint or incident properly but we will use reasonable efforts to notify you if this is the case at the time.
3. How your personal data IS collected
We use different methods to collect data from and about you, including through:
- Direct interactions. You may give us your identity data, contact data, financial data, transaction data, incident data communications data and social media data by filling in forms or by corresponding with us by post, phone, email, social media or otherwise. This includes personal data that you provide when you:
- Enquire about our products or services.
- Provide us with transaction data and incident data.
- Agree to participate in market research.
- Create an account with us.
- Request marketing to be sent to you.
- Give us feedback or contact us.
- CCTV systems. We may collect CCTV data at our Head Office premises, which is operated and managed by Ceuta Healthcare.
- Automated technologies or interactions. As you interact with our sites, we will automatically collect technical data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies. Please see our cookie policy for further details.
- Third parties or publicly available sources. We will receive personal data about you from various third parties as set out below:
- New client data will be collected where we carry out a credit check in relation to you using a credit reference agency. The credit reference agency we normally use is set out below, along with how to find their ‘Credit Reference Agency Information Notice’ (CRAIN).
Experian
www.experian.co.uk/crain
Consumer Help Service
PO Box 8000
Nottingham NG1 5GX
You can see the information the agency holds about you, and read their Privacy Notices, on the website above. Contact them directly and they’ll explain how to make a request and how much it costs.
- Technical data from the following parties:
- Analytics providers such as Google.
- Marketing data. We collect your contact data if you make an enquiry about our products or services:
- By filling in online or offline forms or corresponding with us by post, phone, email, our sites, at national and international conferences and trade shows or otherwise.
- If you make an enquiry via one of our Ceuta Group companies and that enquiry is dealt with by or we need to pass you to another Ceuta Group company.
We do not buy in mailing lists.
- We collect your contact data and other data relevant to market research projects where you agree to participate in that research (described further below).
- Social media data. When you use our social media platforms to communicate with us, engage with us or share content with us:
- Those platforms may provide us with information about you, such as where you send us a message, or like or comment on us or our content.
- When contacting us through a social media platform, we suggest that you also familiarise yourself with the privacy information provided by the relevant platform, which is not controlled by us.
- If you wish to contact us via a social media platform, we suggest that you use direct messaging rather than public messaging if you wish to share any personal data with us. Any personal data shared in public on social platforms is shared at your own risk.
4. How we use your personal data
We will only use your personal data when the law allows us to do so. Most commonly, we will use your personal data in the following circumstances:
- Where we need to perform the contract that we are about to enter into or have entered into with you.
- Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
- Where we need to comply with a legal obligation.
To find out more about the types of lawful basis that we will rely on to process your personal data, see the Glossary.
Generally, we do not rely on consent as a legal basis for processing your personal data. However, we will request your consent before sending third-party direct-marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us.
Purposes for which we will use your personal data
The following table describes all the ways in which we plan to use your personal data, and which of the legal bases we rely on to do so. Where appropriate, we have also identified what our legitimate interests are.
Note that we may process your personal data on more than one lawful basis depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal basis on which we are relying to process your personal data where more than one basis has been set out in the table below.
| Purpose/activity | Type of data | Legal basis for processing (including the relevant legitimate interest basis where applicable) |
| To register you as a new customer | (a) Identity (b) Contact | Performance of a contract with you |
| New Client checks | (a) Identity (b) Contact (c) Financial (d) New client | (a) Performance of a contract with you (b) Necessary to comply with a legal obligation |
| To manage our relationship with you including notifying you about changes to our terms or privacy statement. | (a) Identity (b) Contact (c) Profile (d) Marketing (e) Communications (f) Social media | (a) Performance of a contract with you (b) Necessary to comply with a legal obligation (c) Necessary for our legitimate interests (to keep our records updated and to study how customers use our products and services) |
| Responding to an enquiry or complaint and managing reported product incidents (including completing incident reports which are reported to us) | (a) Identity (b) Contact (c) Transaction (d) Incident | (a) Performance of a contract with you (b) Necessary to comply with a legal obligation (c) Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services) (d) Consent |
| To enable you to complete a survey or market research | (a) Research (b) Identity (c) Usage (d) Communications | (a) Necessary for our legitimate interests (to study how customers use our products/services, to develop them and grow our business) |
| To administer and protect our business, our website and pages on social media platforms that we operate (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data) | (a) Identity (b) Contact (c) Technical (d) Communications (e) Social media | (a) Necessary for our legitimate interests (for running our business, for provision of administration and IT services, for network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise) (b) Necessary to comply with a legal obligation |
| To deliver relevant content and advertisements to you, and measure or understand the effectiveness of the advertising that we provide | (a) Identity (b) Contact (c) Profile (d) Usage (e) Marketing (f) Communications (g) Technical (h) Social media | Necessary for our legitimate interests (to study how Ceuta’s customers use our products and services, to develop them, to grow Ceuta’s business and to inform our marketing strategy) |
| To use data analytics to improve our sites, products and services, marketing and customer relationships and experiences | (a) Technical (b) Usage | Necessary for our legitimate interests (to define types of customers for our products and services, to keep our sites updated and relevant, to develop our business and to inform our marketing strategy) |
| To make suggestions and recommendations to you about goods or services that may be of interest to you | (a) Identity (b) Contact (c) Technical (d) Usage (e) Marketing (f) Communications (g) Social media | Necessary for our legitimate interests (to develop our products and services, and to grow our business) |
| CCTV | (a) CCTV | Necessary for our legitimate interests to manage the security of our premises, to manage health and safety at our premises, and to allow us to manage insurance claims |
| To complete reports about accidents or incidents that are reported to us | IdentityContactAccident | Legitimate interest (to keep our records updated)Necessary to comply with a legal obligation |
| Responding to an enquiry or complaint, managing a reported product incident or completing incident reports which are reported to us | Identity Contact Transaction Incident | (a) Performance of a contract with you (b) Necessary to comply with a legal obligation (c) Necessary for our legitimate interests (to keep our records updated and to refer to on how customers use our products/services) (d) Consent |
Automated decision-making
We do not make any decisions that could have a legal effect, or other significant effect, on you, based solely on automated processing of your personal data.
Market research
We process Research Data (via reputable third-party research agencies acting on our behalf) where you agree to participate in customer feedback and market research activities such as customer surveys, questionnaires or focus groups. Where we do so, we share the very limited data required for that research in a safe and secure manner and we agree that when relevant data is shared back with Ceuta, it is done so in an anonymised form where possible.
You can decline to take part in any such research activities and opt-out of these types of communications from us by following the unsubscribe link in any of those relevant research communications.
Rest assured, we never sell your personal data to research companies and do not carry out sugging (selling under the guise of research).
Marketing
We hope that you enjoy and value our newsletter and updates, and our marketing material generally. We may send you this information by various means including email, text message, post, telephone or social media. We respect your right to choose what marketing messages you receive, and we will always try to provide you with choices regarding certain personal data uses, particularly around marketing and advertising.
You will receive marketing communications from us if you have requested information from us or purchased goods or services from us and you have not opted out of receiving that marketing.
Promotional offers from us
We may use your identity, contact, technical, usage and profile data 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 call this marketing).
You will receive marketing communications from us if you have requested information from us or purchased goods or services from us and you have not opted out of receiving that marketing.
Third-party marketing
Our site is designed to provide information about our organisation. If you make an enquiry with us about another Ceuta group company (see above), we will pass your enquiry to the appropriate group company so that they can contact you directly, including for their own marketing purposes. We do not otherwise share your personal data with any third party for marketing purposes.
Opting out
You can ask us to stop sending you marketing messages at any time by selecting or deselecting relevant boxes to adjust your marketing preferences. You can also follow the opt-out links on any marketing message that we email to you, unsubscribe from our pages on social media platforms that we operate or contact us at any time.
Cookies
You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of our website may become inaccessible or not function properly. For more information about the cookies that we use, please see our cookie policy.
Change of purpose
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.
If you would like to understand more about any of our purposes, or you wish us to explain how the processing for the new purpose is compatible with the original purpose, please contact us.
If we need to use your personal data for an unrelated purpose, we will notify you and explain the legal basis that allows us to do so.
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.
5. Disclosures of your personal data
We may share your personal data with the following parties for the purposes set out in the table in the previous section:
- Internal third parties as set out in the Glossary.
- External third parties as set out in the Glossary.
- Third parties to whom we may choose to sell, transfer or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, the new owners may use your personal data in the same way as set out in this privacy statement.
We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes. We only permit them to process your personal data for specified purposes and in accordance with our instructions.
6. International DATA transfers
We will only transfer your personal data to countries that the UK government or the European Commission have deemed to provide an adequate level of protection for personal data. For further details, see the information about adequacy decisions on the European Commission’s website and the UK ICO website.
Where we use certain service providers, we may use specific contracts approved by the European Commission that give personal data the same protection that it has in Europe. For further details, see the information about model contracts for the transfer of personal data to third countries on the European Commission’s website and the UK ICO website.
Currently, we transfer your personal data to the following jurisdictions:
- We transfer your personal data outside the United Kingdom or the European Economic Area (“EEA”) where your enquiry relates to one of our Internal Third Parties – our Ceuta group companies (see here) that are based outside the UK or the EEA (see below for details). Our intra group data transfer agreements incorporates the appropriate EU standard contractual clauses that have also been approved by the UK for use.
- We use an international supplier, Mimecast, as a service provider for cloud cybersecurity services, services for email security and data storage management. Your Personal Data may be transferred to Mimecast-controlled affiliates and properly vetted sub-processors throughout the world. Your Personal Data may also be transferred to Mimecast’s third-party service providers who are under contractual obligations to ensure the safety and confidentiality of such data. Personal Data collected within the UK and EEA may be transferred by Mimecast to countries outside of the EEA. Mimecast utilises a variety of mechanisms to ensure the security and legitimacy of these transfers. See more here about Mimecast’s sub-processors.
- Our logistics service provider is headquartered in the USA and so your personal data may be processed by them on our behalf in the USA.
- Where relevant to share Incident Data with product manufacturers based in the USA, Switzerland, the Netherlands, France, Malta, Ireland, Portugal, Spain, Germany, Belgium, Greece and with distributors based in Australia, New Zealand, Chile, Italy, Portugal, Netherlands, Austria, Denmark, Finland, Norway, Sweden, Turkey, Japan, Columbia, South Africa.
Please contact us if you would like further information about the specific mechanism that we use when we transfer your personal data out of the UK or the EEA.
Please note that we have no control over the routes that emails take, and even emails exchanged between two people in the UK could appear on equipment in countries outside the UK or the EEA, where they may not be protected by strong privacy or data protection laws.
7. Data security
We have a strong commitment to data security and are Cyber Essentials accredited as can be checked here.
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed.
In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions, and they are subject to a duty of confidentiality.
We take appropriate steps to communicate with and train our staff in relation to applicable data protection law.
We have put in place procedures to deal with any suspected personal data breach. We will notify you and any applicable regulator of a breach where we are legally required to do so.
Unfortunately, the transmission of information via the Internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to or via our sites or via any social media platforms. Any transmission is at your own risk.
Use of CCTV data is subject to additional specific rules and protections and is managed in line with our CCTV policy. It is usually retained for 30 days unless there is an incident that requires us to keep it for longer.
If you would like to know more about our data security measures, please contact us.
8. Data retention
We will only retain your personal data for as long as reasonably necessary to fulfil the purposes for which we collected it, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe that there is a prospect of litigation in respect to our relationship with you.
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 unauthorised 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, regulatory, tax, accounting or other requirements.
Details of retention periods for different aspects of your personal data are available in our retention policy, which you can request from us by contacting us.
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.
We also keep records in the event of an adverse event/ incident or product complaint for as long as the product is part of our current portfolio plus 10 years and could be asked to refer those details to the regulatory authorities in relation to adverse reaction.
In some circumstances, you can ask us to delete your data: see the following section for further information.
In some circumstances, we will anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.
9. Your legal rights
Under certain circumstances, you have rights under data protection laws in relation to your personal data, which we process as a controller. These rights are subject to specific requirements and limitations set out in the applicable data protection legislation and are summarised below:
- You can request access to the personal data that we hold about you and check that it is being lawfully processed (commonly known as a “data subject access request”).
- You can request correction of the personal data that we hold about you if it is wrong and ask us to complete it if it is incomplete.
- You can request erasure of your personal data, but we will retain your data for the purposes of dealing with any claims or where we have another legitimate reason to retain it.
- You can object to the processing of your personal data. For example, if we are processing it on the basis of a legitimate interest and that does not override your individual rights.
- You can request the restriction of processing of your personal data. You may, for example, want to do this while we consider your request to have it corrected.
- You can learn how and why we are processing your personal data, the legal basis for that processing, who we have disclosed it to and who we will disclose it to (which we have provided in this privacy statement).
- You can receive a copy of your personal data (or have it passed to a third party) in a common and structured electronic format (where the legal basis for our processing is your consent, or the processing is necessary for the performance of our contract with you).
- You can stop having your personal data used for direct marketing.
- You can withdraw your consent to the processing of your personal data at any time if the lawful basis of the processing is your consent.
If you wish to exercise any of the rights set out above, please contact us.
You also have the right to complain to the ICO about our processing or our response to your requests and objections. You can do this by visiting the ICO website or calling 0303 123 1113.
No fee 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, or refuse your request, if your request is clearly unfounded, repetitive or excessive.
What we may need from you
We may need to request proportionate 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 someone who has no right to receive it. To speed up our response, we may also contact you to ask you for further information in relation to your request.
Time limit to respond
We try to respond to all legitimate requests within one month. Occasionally, if your request is particularly complex or you have made several requests, it could take us longer than a month. In this case, we will notify you and keep you updated.
10. Glossary
LAWFUL BASIS
Legitimate interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best, most secure experience. We make sure that we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.
Performance of contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.
Complying with a legal obligation means processing your personal data where it is necessary for compliance with a legal obligation that we are subject to.
THIRD PARTIES
Internal third parties
Other companies in the Ceuta Group such as those based in the UK, Ireland, the USA, The Netherlands, Singapore and Thailand, which provide various products and services as well as internal IT and system administration services and leadership reporting.
External third parties include:
- Service providers acting as processors based in the UK who provide IT and system administration services including web hosting.
- Our email is hosted, and our files are stored using Microsoft 365, which is a cloud service provider based in Ireland. See above for more details.
- email security and data storage management. See above for more details.
- Our logistics service provider that is headquartered in the USA. See above for more details.
- Mailing houses, printers and delivery services such as couriers.
- Online, social media and marketing agencies.
- Market research agencies.
- Professional advisers including lawyers, bankers, auditors and insurers based in the UK who provide consultancy, banking, legal, insurance and accounting services.
- Payment providers.
- Credit Reference Agencies (CRAs) and fraud prevention agencies.
- HM Revenue & Customs, regulators and other authorities based in the UK who require reporting of processing activities in certain circumstances.
- Relevant product manufacturers and distributors based within the UK and in numerous other jurisdictions, where it is necessary for us and them to handle Incident Data. See above for more details.
- Healthcare professionals where it is necessary for us and them to handle Incident Data. See above for more details.
YOUR LEGAL RIGHTS
You have the right to:
- 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 that we hold about you and 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 that we hold about you corrected, although we may need to verify the accuracy of the new data that you give 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 that 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 that makes you want to object to processing on this basis because you feel that it affects 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 that override your rights and freedoms.
- Request the 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:
- If you want us to establish the data’s accuracy.
- Where our use of the data is unlawful, but you do not want us to erase it.
- Where you need us to hold the data even if we no longer require it because you need it to establish, exercise or defend legal claims.
- 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 whom you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information that 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.