Deep-medical Privacy Policy (Website)
Policy last updated 20th February 2024
Deep-medical (we) are committed to protecting your data and respecting your privacy.
Introduction
This policy applies to your use of our website at https://deep-medical.ai/ (website). This policy sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us. The website is not intended for children (persons under 18) and we do not knowingly collect data relating to children. Please read the following carefully to understand our practices regarding your data and how we will treat it. This policy should be read together with any other privacy policy that we may provide when we are collecting or processing personal data about you so that you’re fully aware of how and why we are using your data. This privacy policy supplements other notices and privacy policies and is not intended to override them.
This policy is provided in a layered format so you can click through to the specific areas set out below.
Important Information And Who We Are
Our full details are:
Full name of legal entity: Deep-medical Limited
Email address: privacy@deep-medical.ai
Postal address: Deep Medical, 80 Coleman Street, London, EC2R 5BJ
Changes To The Privacy Policy And Your Duty To Inform Us Of Changes
We keep our privacy policy under regular review.
This version was last updated on the date at the top of this policy. It may change and if it does, these changes will be posted on this page and, where appropriate, notified to you. The new policy may be displayed on-screen and you may be required to read and accept the changes to continue your use of the website.
The personal data we hold about you must be accurate and current. Please keep us informed if your data changes during our relationship with you.
Third-Party Links
This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy policy of every website you visit.
The Data We Collect About You
We may collect, use, store, and transfer different kinds of personal data about you as follows:
Identity Data
Contact Data
Transaction Data
Financial Data
Technical Data
Device Data
Log Data
Content Data
Profile Data
Usage Data
Marketing and Communications Data
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 as this data will not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific feature or page of our website. However, if we combine or connect aggregated data with your data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used by this privacy policy.
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, 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). In this case, we may have to cancel a product or service you have with us. We’ll notify you if this is the case at the time.
How Is Your Data Collected?
We will collect and process the following data about you:
Information you give us. This is information you give us about you by filling in forms on the website or by corresponding with us (for example, by email or chat). It includes information you provide when you register on our website, details of your marketing and communications preferences, information provided when you enter a competition, promotion, or survey, and when you report a problem or request support for our website, or any other services. If you contact us, we will keep a record of that correspondence. This may also include telephone calls, emails and posts. It may also include information we collect from you as a result of any monitoring which may take place. We may monitor (which may include recording) certain interactions between us to comply with any legal obligations, to detect fraud or criminal activity as well as for training purposes.
Information we collect about you and your device.
Each time you use our website we will automatically collect personal data including Device and Technical Data about your equipment, browsing actions and patterns, Content and Usage Data. We collect this data using cookies and other similar technologies.
Information we receive from other sources including third parties and publicly available sources.
Device Data and Technical Data from the following parties:
1. analytics providers such as Google and Apple based outside the EU;
2. search information providers such as Google based inside and outside the EU.
Cookies
Our website uses cookies to distinguish you from other users of our website and to remember your preferences. This helps us to provide you with a good experience when you use our website and also allows us to improve our website.
How We Use Your Data
We will only use your data when the law allows us to. Most commonly we’ll use your data in the following circumstances:
Where you have consented before the processing. We’ll usually only ask for your consent when we’d like to provide marketing information to you (including information about other products and services). Without your consent, in some circumstances, we may not be able to provide you with and you may not be able to benefit from some of our services.
When we process the data you provide to us based on your consent, you have the right to withdraw your consent at any time and to port the data you provide to us. To exercise your rights, see the How You Exercise Your Rights section of the Privacy Policy.
Where we need to perform a contract we are about to enter or have entered 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 or regulatory obligation.
Where we need to use your personal information to establish, exercise or defend our legal rights, for example when we are faced with any legal claim or where we want to pursue any legal claims ourselves
We will get your express opt-in consent before we share your data with any third party for marketing purposes.
How We Use Your Data
We have set out below, in a table format, a description of the ways we plan to use your data, and which of the legal bases we rely on to do so. We’ve also identified what our legitimate interests are where appropriate.
Note that we may process your data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we’re relying on to process your data where more than one ground has been set out in the table below.
Disclosures Of Your Data
We may disclose your data to third parties if we’re under a duty to disclose or share your data to comply with any legal or regulatory obligation or request, if you’ve consented to this, to protect our rights and property and the rights, safety and property of others (provided we comply with data protection law).
We may also transfer your data to a third party we’ve appointed to provide services to us on our instructions.
We may transfer your data in connection with a potential transfer of part or all of our organisation. In such circumstances, we may share information with prospective purchasers (for example as part of a controlled due diligence exercise). Alternatively, we may seek to acquire another organisation or merge with them. If a change happens to our organisation, then the new owners may use your data in the same way as set out in this privacy policy. If we reorganise our business, we may need to transfer information about you to another member of our group so that we can continue to provide the Service to you.
International Transfers
While we do not routinely transfer your data outside the European Economic Area (EEA) should we do so, we will only do this as permitted by data protection legislation.
Data Security
All information you provide to us is stored on secure cloud servers.
Once we have received your information, we will use strict procedures and security features to try to prevent your data from being accidentally lost, used or accessed in an unauthorised way.
We will collect and store personal data on your Device using application data caches browser web storage (including HTML5) and other technology.
We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator when we are legally required to do so.
Data Retention
We will only retain your data for as long as reasonably necessary to fulfil the purposes we collected it for, including to satisfy any legal, regulatory, tax, accounting or reporting requirements. We may retain your data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation concerning 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 data, the purposes for which we process your data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.
In most cases, we will keep your information for three years after our relationship with you ends but where we have a contract with you, we will keep it for at least 6 years. It will vary depending on what data we hold, why we hold it and what we are obliged to do by law.
We will not keep your personal information longer than is reasonably necessary to fulfil the relevant purposes set out in this Privacy Policy and to comply or demonstrate compliance with our legal and regulatory obligations. Where we can, and it is appropriate, we will minimise personal data or de-personalise data to use for statistical or analytical purposes. In some cases, such as if a dispute or a legal action is affecting the information we may need or be required to keep personal information for longer.
By law we have to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data for at least 6 years.
In some circumstances you can ask us to delete your data: see Your legal rights below for further information.
In some circumstances, we will anonymise your 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.
Your Legal Rights
Under certain circumstances, you have the following rights under GDPR (before 31 December 2020 and the Data Protection Act 2018 from 1 January 2021) about your data. You also have the right to ask us not to continue to process your data for marketing purposes.
You can exercise any of these rights at any time by contacting us at privacy@deep-medical.ai or Postal address: Deep Medical, 80 Coleman Street, London, EC2R 5BJ.
You have the right to:
Request access to your data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to 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 we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
Request erasure of your 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 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 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 which will be notified to you, if applicable, at the time of your request.
Object to processing of your data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
Request restriction of processing of your data. This enables you to ask us to suspend the processing of your data in the following scenarios:
A. if you want us to establish the data’s accuracy;
B. where our use of the data is unlawful but you do not want us to erase it;
C. where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or
D. 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 data to you or a third party. We will provide to you, or a third party you have chosen, your data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which 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 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’ll advise you if this is the case at the time you withdraw your consent.
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 please contact us in the first instance.
No Fee Usually Required
You will not have to pay a fee to access your data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances.
What We May Need From You
We may need to request specific 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 any person who has no right to receive it. We may also contact you to ask you for further information about your request to speed up our response.
Time Limit To Respond
We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made several requests. In this case, we will notify you and keep you updated.
Description Of Categories Of Personal Data
Identity Data: first name, last name, username or similar identifier, marital status, title, date of birth, gender, other biographical information you provide, and your photographs.
Contact Data: addresses, email addresses and telephone numbers.
Financial Data: bank account and payment card details.
Transaction Data: includes details about payments to and from you and details of donations.
Technical Data includes internet protocol (IP) address, your 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 you use to access this website. Where you use a mobile device to access the website, this includes Device Data.
Device Data: includes the type of mobile or other device you use, a unique device identifier (for example, your Device’s IMEI number, the MAC address of the Device’s wireless network interface, or the mobile phone number used by the Device), mobile network information, your device operating system, the type of mobile browser you use, and time zone setting.
Content Data: includes information stored on your Device, including friends’ lists, login information, photos, videos or other digital content.
Profile Data: includes your username and password, posts, body, purchase history, your interests, preferences, feedback and survey responses.
Usage Data: includes details of your use of the website including.
Log Information details of your use of the website.
Marketing and Communications Data: includes your preferences in receiving marketing from us and our third parties and your communication preferences.
Special Category Data includes information about your health, diagnosis, and current status, but it may include other data such as your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, and political opinions.
