1. Information Collection
"Personal Information" (also referred to as “Personal Data” in some jurisdictions) is any information that can be used to identify an individual or that we can link directly to an individual, such as name, address, email address, telephone number or credit card number, as applicable. Personal Information, in some jurisdictions, can even include information that indirectly identifies a person – such as a unique number assigned to a patient by a medical facility or healthcare professional, even absent other identifying information. Health and treatment information pertaining to an identified or identifiable individual is a form of Personal Information that, in this Policy, we call Special Personal Information ("Special Personal Information"). We will process any Special Personal Information and Personal Information we collect in accordance with applicable law and as explained in this Policy (unless, as explained above, one of our other policies governs). If you do not want to provide us with this information, certain products, services, or features of the Websites may be unavailable to you.
When you visit the Websites, we may also collect certain technical information relating to users, which your web browser automatically sends whenever you visit a website on the Internet or which is collected when you use a mobile application. Our servers automatically record this information, which may include Internet Protocol ("IP") address, browser type, browser language, device type, advertising IDs associated with your device (such as Apple’s Identifier for Advertising (IDFA) or Google’s Ad ID (AAID)), the date and time of your request, and Uniform Resource Locators, or URLs (i.e., website addresses) visited prior to visiting and after leaving our Websites. Depending on a user’s country and the specific information involved, this technical information may or may not be Personal Information.
Cookies and Similar Tools
Also when you visit the Websites, we, like many websites, may use "cookies," web beacons and other technologies on our Websites to help us serve users better, and to help us evaluate and improve the content or functions of our site. A cookie is a unique numeric code that we transfer to your computer so that we can keep track of your interests and/or preferences and, among other things, recognize you as a return visitor to our Websites. Web beacons are small pieces of code placed on our Websites that allow us to obtain information about website usage.
Common uses for cookies include:
- Identifying visitors who have signed into a protected website to avoid users having to submit a user name and password for every page;
- Keeping track of visitors' preferences regarding the content they would like to see and the format in which they would like to view it so they don't need to resubmit the preferences every time they visit the site;
- Keeping track of which pages visitors request to make improvements to site content and navigation;
- Engaging in analytics about how the Websites are used; and
- Collecting information about visitors’ online activities over time and across different websites when they use the Websites.
If you prefer not to receive cookies from this Website set your browser to refuse all cookies from this and other websites that you may visit. This will provide you with more control over the acceptance of cookies on your computer. However, it is possible that some portions of the Websites will not function properly or may perform more slowly if you choose to reject cookies. By using our Websites and not disabling cookies, you consent to their use. We may also provide additional options for your choices regarding cookies on the Websites.
Your browser may offer you a “Do Not Track” option, which allows you to signal to operators of websites and web applications and services (including behavioral advertising services) that you do not wish such operators to track certain of your online activities over time and across different websites. While we might engage in such tracking, our Websites do not support Do Not Track requests at this time.
2. Legal Bases for Using Your Personal Information
There are different legal bases that we rely on to use Personal Information, namely:
Performance of a Contract - The use of Personal Information may be necessary to perform the contract that you or your organization has with us or to take steps at your request prior to entering into a contract with you or your organization. For example, where you work for us either as an employee or a service provider or apply for a job with us, your Personal Information will be necessary in connection with your contract of employment or services agreement or for the possibility of entering into a contract with us. If you are a consumer or a user of our services we will use your Personal Information to carry out our obligations under the contract that we have with you. We similarly process patient-related Personal Information from our customers and employee and representative information from our customers, suppliers and business partners to perform our contracts with those organizations.
Consent – We will rely on consent, which, in some cases, may be implied, to use: (i) technical information, such as cookie data and geolocation data, as described in this Policy; and (ii) Personal Information for certain marketing purposes. Where we would like to use Special Personal Information, like health information that we collect from you, we will only do so with your explicit consent if required by law, unless we have an obligation under employment law. You may withdraw your consent at any time by contacting us at the addresses at the end of this Policy. We may obtain certain Personal Information and Special Personal Information about you from healthcare professionals (including hospitals, medical scanning facilities or similar healthcare providers or one of their representatives) that use our products and services, in which case they are responsible for obtaining and handling any required consents or for having another legitimate basis for processing such information.
Legitimate interests – It is in our legitimate interests to process Personal Information in order to improve our products, services, perform administrative tasks, communicate with you, including the delivery of marketing communications with users and patients (and where consent is not required by applicable law), customize and personalize content for users, identify and authenticate you, secure our systems and information, conduct research, and develop new products. It is also in our legitimate interests to protect the legal rights, safety, and security of FreeHand, our affiliates, and our business partners; to respond to and resolve claims or complaints; to prevent fraud; and to manage risks associated with our business. For more information about the balancing test that we carry out to process your Personal Information to meet our legitimate interests, please contact us using the details below.
Public interest – In limited circumstances, including, in some cases, complaint handling, we may process your information, including sensitive Personal Information, for reasons of public interest in the area of public health. In particular, FreeHand may process your information in connection with efforts to ensure high standards of quality and safety for medical devices.
Legal obligations – We may use Personal Information to comply with legal obligations to which we are subject. For example, we may disclose Personal Information for medical device regulatory reporting requirements or to law enforcement in accordance with legal process.
3. Interactive Features of our Websites
To the extent we offer any public or group forums on our Websites, such as newsfeeds, blogs, message boards or similar tools (“Interactive Features”), the posts or comments you make may be public and viewed by others. You should use care before posting information about yourself, including Personal Information, online. You acknowledge and understand that you have no expectation of privacy or confidentiality in the content you submit to Interactive Features over the Websites. Except when required to do so by applicable law, we assume no obligation to remove Personal Information from postings on our Websites and you disclose any Personal Information in your postings at your own risk.
4. Links to Other Websites
Our Websites may contain links to other websites that are not owned or operated by FreeHand, such as social media websites like Facebook, Twitter or through other mechanisms such as email. You should carefully review the privacy policies and practices of other websites, as we cannot control and are not responsible for privacy policies or practices of third-party websites.
5. Safeguarding Information
Consistent with applicable laws and requirements, FreeHand has put in place physical, electronic, and administrative safeguards to protect Personal Information from loss, misuse, alteration, theft, unauthorized access, or unauthorized disclosure, consistent with legal obligations and industry practices. We evaluate these safeguards on an ongoing basis to help minimize risks from new security threats as they become known. However, as is the case with all websites, we unfortunately are not able to guarantee security for data collected through our Websites.
If you are providing any Special Personal Information or sensitive personal information to us through our Websites, such as credit card details, please be sure that the computer you are using to do so has up-to-date anti-virus software in place, to minimize the risk of any access to the information before it reaches us. As is the case with all websites, we unfortunately are not able to guarantee security for information collected through our Websites.
6. Your Rights Regarding Your Personal Information
FreeHand takes reasonable steps to ensure that Personal Information is accurate and up-to-date for the purposes for which it was collected. We encourage you to contact us to update or correct your information if it changes or if you believe any information that we have collected about you is inaccurate. You can also ask us to erase, restrict, or port your Personal Information and you may tell us if you object to our use of your Personal Information. Consistent with legal requirements and limitations, FreeHand will comply with reasonable requests to obtain a copy of Personal Information that we hold about you where applicable law requires we do so.
To exercise your rights, please write to us at email@example.com or FreeHand, Attn: Global Privacy Officer, Freehand Ltd | Unit 2 Weyvern Park | Guildford, Surrey GU3 1NA UK. Please note that we will require sufficient information for us to identify records responsive to your request. We may, after receiving your request, require additional information from you in order to honor the request.
If you are concerned about how your Personal Information is used, please email us or contact us at the address below. Alternatively you may have a right to complain to your local data protection authority (if one exists in your country).
7. Right to Unsubscribe
You may unsubscribe from our marketing or promotional emails. To do so, please email us at firstname.lastname@example.org or use the unsubscribe mechanism offered in our marketing emails or other communications as applicable. Please note that if you already have requested our products or services when you decide to withdraw consent, there may be a short period of time for us to update your preferences and ensure that we honor your request.
8. How Long Your Personal Information Will Be Retained
We will retain your Personal Information for as long as we maintain a relationship with you, or provide a service for customers that serves you, and as long as is reasonably necessary thereafter for legitimate business purposes.
We may update this Policy from time to time without notice. As such, you should review this Policy periodically. Your continued interactions with us, use of the products and services, or our Websites subject to this Policy constitutes your agreement to this Policy.
10. Contact Us
If you have any questions, including how to access this policy in an alternative format, please email us at email@example.com or write to us at FreeHand, Attn: Global Privacy Officer, Freehand Ltd | Unit 2 Weyvern Park | Guildford, Surrey GU3 1NA UK.