Privacy Policy.

SANOME LIMITED GENERAL PRIVACY NOTICE

Contents

1 Introduction

2 Data Controller

3 The information we collect and when.

4 How we use your information

5 Who we might share your information with

6 International transfers of information

7 How we keep you updated on our services

8 Your rights over your information

9 How long we keep your information for

10 Giving your reviews and sharing your thoughts

11 Security

12 What happens if our business changes hands?

13 Changes to Our Privacy Notice

14 Other links

15 How to contact us

  1. Introduction

Sanome Limited (referred to as “Sanome”, “We, “Our” or “Us”), is committed to protecting the privacy and security of your personal information. We take care to protect the privacy of research study participants, clinical trial volunteers, our customers and their staff, our suppliers/partners and their staff, investors, patients, health care professionals, professional advisors, researchers, physicians, prospective employees and all other users or parties that otherwise interact with us or use our website.

We have therefore developed this privacy notice to inform you of the data we collect, what we do with your information, what we do to keep it secure as well as the rights and choices you have over your personal information.

We may provide additional privacy notices to you at the time we collect your data. For example, we provide additional privacy information to clinical trial participants to describe our privacy practices in connection with conducting clinical trials and we also provide additional privacy information to prospective job applicants when they apply for a job with us. Such notices will govern how we process the information you provide at that time.

Throughout this document we refer to Data Protection Legislation, which means the Data Protection Act 2018 (DPA 2018), United Kingdom General Data Protection Regulation (UK GDPR), the Privacy and Electronic Communications (EC Directive) Regulations 2003 and any legislation implemented in connection with the aforementioned legislation. Where data is processed by a controller or processor established in the European Union or comprises the data of people in the European Union, it also includes the EU General Data Protection Regulation (EU GDPR). This includes any replacement legislation coming into effect from time to time.

We are further committed to compliance with the Health Insurance Portability and Accountability Act (HIPAA), the Medical Devices Regulation and related legislation, requirements and guidance, as applicable to Sanome and you.

2. Data Controller

Sanome is the controller for the personal information we process as identified in this privacy notice. In some circumstances, Sanome will process data on behalf of other organisations (e.g assisting a partner organisation with their own clinical research). In such circumstances, the other organisation will be the controller and so you should refer to their privacy notices for details of how your data is processed.

Occasionally, Sanome may be a joint controller with one of our partner organisations. Such processing may be communicated to you in a separate privacy notice.

We are registered with the Information Commissioner’s Office (the ICO) with registration number ZB272622.

We have appointed a Data Protection Officer (DPO) to help us monitor internal compliance, inform, and advise on data protection obligations, and act as a point of contact for you (data subjects) and the ICO.

Our Data Protection Officer is: 

The DPO Centre Ltd.50 Liverpool StreetLondonEC2M 7PY

For further details on how you can contact us and our DPO, please see the contact us section below.

3. The information we collect and when.

We only collect personal information that we know we will genuinely use and in accordance with the Data Protection Legislation. The type of personal information that we will collect depends on the nature of the relationship that we have with you. We may collect the following:

  • Personal and business contact information (such as name, job title and employer name, email address, mailing address, phone number, and emergency contact information).

  • Physical, biophysical, or digital data, which may include:

  • Health and medical information (such as information about physical and mental health conditions, diagnoses or symptoms, treatments for medical conditions, family medical history, medications) in connection with clinical trials and conducting research.

  • Physical samples provided by you when participating in a trial and data obtained from studying these samples (i.e. biomarker data).

  • Biographical and demographic information (such as date of birth, ethnicity, gender).

  • Photos, videos and audio recordings. 

  • Digital information provided when using the Sanome Research Platform.

  • Cookies and IP addresses. For more information, please see our Cookie Policy.

  • Professional credentials, educational and professional history, and institutional affiliations.

  • Where you are one of our investors, your investor profile information, and interactions.

  • We may, in further dealings with you, extend this personal information to include services used, and subscriptions, records of conversations and agreements and payment transactions.

  • Other information that we may collect that is not specifically listed here but that we will use in accordance with this privacy notice or as otherwise disclosed at the time of collection.

In most instances, you are under no statutory or contractual requirement or obligation to provide us with your personal information; however, we will often require elements of the information above in order to provide our services to you in an efficient and effective manner.

4. How we use your information

4.1 Data collection

In most instances we collect personal information directly from you, for example through online forms, the Sanome research platform, questionnaires, phone conversations, emails, in person (at clinical sites, conferences, workshops, seminars or events), our at home tests, medical devices, and so on. In other instances, we may collect personal information from our website, public forums (e.g., social media), when you have or intend to attend an event to which we are affiliated, from contract research organisations, hospitals, healthcare professionals, partners and so on.

4.2 Lawful basis

We only process, store or transfer your personal information when we have a lawful basis for doing so. The legal basis we rely on to process the information identified in this notice are as follows:

  • Legitimate Interest: processing is necessary for the purposes of our legitimate interests (i.e., our business interests), except where such interests are overridden by your interests or fundamental rights and freedoms. 

  • Consent: You have given consent to the processing of your personal data for one or more specific purposes.

  • Legal obligation: processing is necessary for compliance with our legal obligations.

  • Vital interests: processing is necessary in order to protect the vital interests of the data subject or of another natural person.

  • Contractual obligation: processing is necessary for the performance of a contract to which you are a party or in order to take steps at your request prior to entering into a contract.

4.3 Processing activities 

We may use your data to:

Processing activity

Lawful basis

Contact you, following your enquiry, reply to any questions, suggestions, issues, or complaints you have contacted us about.

Legitimate Interest

Communicate with you and send B2B marketing communications, including where you have attended events or webinars. See also section 7 of this notice.

Determine whether you are eligible to take part in a clinical trial or research. 

Perform and administer clinical trials and research.

Identify and combine biomarkers to develop engaging, useful and accurate diagnostic products (IVD’s) that enable early detection and prevention of disease.

Optimise our product for clinical studies/ research.

Meet our high security standards in managing your personal data, our systems and our website.

Register you as a user on the Sanome Research Platform (our app), enable you to use the app, and enable us to make improvements to the app.

To send you push notifications through the Sanome Research Platform, if you have started, but not completed, the sign-up process.

Consent

Generate marketing/analytics from our website using cookies. This includes the monitoring, development and improvement of the website and your experience. For full details on our use of cookies please see our Cookie Policy.

Consent

To be contacted regarding participation in future Sanome studies or with a copy of our newsletter, providing you have opted in.

Negotiate and/or enter into and/or fulfil a contract with you, or the organisation for which you work.

Contractual Obligation (when the contract is with you) or Legitimate Interest (when the contract is with the organisation for which you work)

Fulfil pre-contractual steps, such as supplier questionnaires, as part of our onboarding process.

Comply with applicable laws, lawful requests, and legal process, where appropriate/necessary.

Legal Obligation

Comply with regulatory monitoring and reporting obligations, where appropriate/necessary.

Share your data with healthcare professionals if you are taken ill or involved in an accident while visiting our office or sites, and are unable to provide your consent.

Vital Interest

4.4 Sensitive information

As well as the lawful bases identified above, when the data we are processing is considered ‘special category data’, such as your ethnicity, health or genetic information, we ensure that we have your explicit consent or the processing is necessary for one of the following: 

  • Purposes of preventive or occupational medicine, for the assessment of the working capacity of the employee, medical diagnosis, the provision of health or social care or treatment or the management of health or social care systems and services.

  • Public interest in the area of public health, such as protecting against serious cross-border threats to health or ensuring high standards of quality and safety of health care and of medicinal products or medical devices.

  • Archiving purposes in the public interest, scientific or historical research purposes or statistical purposes. 

4.5 Anonymous information

In addition, we may create anonymous, aggregated, or de-identified data from your personal information and other individuals whose personal information we collect. We do this by excluding information that makes the data personally identifiable to you and use that anonymous data for research purposes.

4.6 Automated processing

In some instances, the Sanome Research Platform uses automated algorithms in order to help us achieve our processing activities. These algorithms will not be used to make automated decisions on users and outcomes will be verified by our team of data scientists.

5. Who we might share your information with

We may share your personal data with trusted third-party organisations as follows:

  • With business partners and corporate affiliates to support our services, as outlined in this notice.

  • With third party companies or individuals (data processors) to perform services on our behalf. This would include biomarker companies, contract research organisations; data storage and analytics companies; technology support and services (email, web hosting, marketing, and advertising providers, etc.). We only share your data with data processors that can provide sufficient guarantees that they will process your data securely and in accordance with Data Protection Legislation. Our data processors cannot do anything with your personal information unless we have instructed them to do it. They will not share your personal information with any organisation apart from us or further sub-processors which must process your personal to the same high standards.

  • With partners with whom we jointly process your data. We may also share your personal information with health care professionals, researchers, academics, public health organisations, and publishers for purposes consistent with this privacy notice.

  • With professional advisors, such as lawyers, bankers, auditors, and insurers, where necessary in the course of the professional services that they render to us.

  • With government or law enforcement officials or private parties as required by law and disclose and use such information as we believe necessary or appropriate.

In some situations, we may have a separate agreement or relationship with you with respect to a specific type of processing of your data, such as if you participate in a trial/research. These situations will be governed by specific terms, privacy notices, or consent forms that provide additional information about how we will use your information and how it is shared. We will honour these additional terms with respect to your information and thus, strongly recommend you review the additional terms prior to participating.

6. International transfers of information

Whenever we transfer your personal information outside of the UK to countries not deemed by the ICO (and/or European Commission as relevant) to provide an adequate level of personal information protection, the transfer will be based on safeguards that allow us to conduct the transfer in accordance with the data protection legislation, such as the specific contracts approved by the ICO (or European Commission as relevant) providing adequate protection of personal information. 

For more information regarding these transfers please contact us using the details below.

7. How we keep you updated on our services

As a business contact, we will send you relevant news about our services in a number of ways including by email, but only if we have a legitimate interest to do so. Marketing communications will be sent from our own domain.

Each email communication will have an option to object to the processing, if you wish to amend your marketing preferences, you can do so by following the link in the email and updating your preferences or by contacting us using the details below.

We make every effort to ensure that we only send such communications to those acting in a business capacity and do not send such materials to consumers via personal email addresses if it is clear they are not acting in such a capacity. 

An exception to this will be where you have provided your consent to be contacted about future clinical trials or have signed up to our newsletter. In such cases you can withdraw this consent by contacting us using the details provided in this notice.

8. Your rights over your information

We would ask for proof of identity and sufficient information about your interactions with us so that we can locate your personal information.

8.1 The right to be informed about our collection and use of personal data

You have the right to be informed about the collection and use of your personal data. We ensure we do this with our internal data protection policies and through this and other privacy notices. These are regularly reviewed and updated to ensure these are accurate and reflect our data processing activities.

8.2 Right to access your personal information

You have the right to access the personal information that we hold about you by making a request. This is referred to as a ‘Data Subject Access Request’. If we agree that we are obliged to provide personal information to you (or someone else on your behalf), we will provide it to you or them free of charge and aim to do so within one month from when your identity has been confirmed.

If you would like to exercise this right, please contact us as set out below.

8.3 Right to rectify your personal information

If any of the personal information we hold about you is inaccurate, incomplete, or out of date, you may ask us to correct it.

If you would like to exercise this right, please contact us as set out below.

8.4 Right to object or restrict our processing of your data

You have the right to object to us processing your personal information for particular purposes or have its processing restricted in certain circumstances.

If you would like to exercise this right, please contact us as set out below.

8.5 Right to erasure

You have the right to have personal data erased. This is also known as the ‘right to be forgotten’. The right is not absolute and only applies in certain circumstances. 

If you would like to exercise this right, please contact us as set out below.

8.6 Right to portability

The right to portability gives you the right to receive personal data you have provided to a controller in a structured, commonly used, and machine-readable format. It also gives them you the right to request that a controller transmits this data directly to another controller. 

This right is unlikely to apply to Sanome’s use of your data, but if you would like to discuss this right, please contact us as set out below.

8.7 Rights in relation to automated processing

An automated decision is one that is made by our systems rather than a person. Under Data Protection Legislation, you have the right to express your concerns and object to a decision taken by purely automated means. You also have a right to request that a person review that decision.

This right is unlikely to apply to Sanome’s use of your data, as our automated processing does not make decisions and includes human intervention (see 4.6 above) but if you would like to discuss this in further detail, please contact us as set out below.

8.8 For more information about your privacy rights

The Information Commissioner’s Office (ICO) regulates data protection and privacy matters in the UK. They make a lot of information accessible to consumers on their website and they ensure that the registered details of all data controllers such as ourselves are available publicly. You can access them here https://ico.org.uk/for-the-public.

You can make a complaint to the ICO at any time about the way we use your information. However, we hope that you would consider raising any issue or complaint you have with us first (using the contact details below). Your satisfaction is extremely important to us, and we will always do our very best to solve any problems you may have. 

9. How long we keep your information for

We will retain your personal information in order to provide you with a high-quality service, in accordance with Data Protection Legislation and for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

To determine the appropriate retention period for personal information, we consider the amount, nature, and sensitivity of the personal information, the potential risk of harm from unauthorised use or disclosure of your personal information, the purposes for which we process your personal information and whether we can achieve those purposes through other means.

In some circumstances we may anonymise your personal information (so that it can no longer be associated with you).

10. Giving your reviews and sharing your thoughts

When using our websites, you may be able to share information through social networks like Facebook and Twitter. For example, when you ‘like’, ‘share’ or review our Services. When doing this, your personal information may be visible to the providers of those social networks and/or their other users. Please remember it is your responsibility to set appropriate privacy settings on your social network accounts, so you are comfortable with how your information is used and shared on them.

11. Security

Data security is of great importance to Sanome and to protect your data we have put in place suitable physical, electronic, and managerial procedures to safeguard and secure your collected data.  

We take security measures to protect your information including:

  • Limiting access to our buildings to those that we have determined are entitled to be there (by use of passes, key card access and other related technologies).

  • Implementing access controls to our information technology.

  • We use appropriate procedures and technical security measures (including strict encryption, pseudonymisation and archiving techniques) to safeguard your information across all our computer systems, networks, websites, mobile apps, offices, and stores. 

    12. What happens if our business changes hands?

We may, from time to time, expand or reduce our business and this may involve the sale and/or the transfer of control of all or part of our business. Any personal data that you have provided will, where it is relevant to any part of our business that is being transferred, be transferred along with that part and the new owner or newly controlling party will, under the terms of this privacy notice, be permitted to use that data only for the purposes for which it was originally collected by us.

13. Changes to Our Privacy Notice

We may change this privacy notice from time to time (for example, if the law changes). We recommend that you check this notice regularly to keep up to date.

14. Other links

Please be aware that the website may link to other websites that may be accessed by you. We are not responsible for the data policies, content or security of such sites. We do not have any control over any use of your data by third parties when you visit such sites or otherwise provide your data through these channels. 

15. How to contact us 

If you would like to exercise one of your rights as set out above, or you have a question or a complaint about this notice, the way your personal information is processed, please contact us by one of the following means:

By email: dpo@sanome.com

By post: Sanome Limited, 8 Devonshire Square, London, EC2M 4YJ

By phone: +44 (0)7985 696803 

Thank you for taking the time to read our privacy notice.

This notice was last updated on 13th January 2022