3. PERSONAL INFORMATION WE COLLECT ABOUT YOU
We receive personal information about you that you give to us, from sources such as those included in Section 1. We only collect personal information which we need and that is relevant for the purposes for which we intend to use it. Outlined below are the points of data collection, the data we collect and why we collect this data.
3.1 PERSONAL INFORMATION THAT YOU GIVE TO US
We collect the following information if you choose to give it to us for example, when you contact us following a purchase of one of our products from a third-party store or via a contact form on one of our websites:
- the opinions and other information you provide when responding to customer surveys and/ or questionnaires;
- any information you include in correspondence with us or in forms you submit to us when using our website, apps or social media pages;
- any information you provide to us via telephone, email, letter or fax;
- any additional sensitive personal data that you choose to share with us, for example when contacting us in relation to usage of a Diomed Group product we manufacture or sell via Third Party websites;
- in respect of qualified healthcare professionals only, any information you include in correspondence you send to us in forms or if you return a Reply Paid Card to us;
- in respect of qualified healthcare professionals, when you access the ‘Healthcare Professionals Resources’ area of our websites, we will collect confirmation from you as to your qualification as a healthcare professional working in the UK
3.2 INFORMATION THAT WE COLLECT ABOUT YOU
When you visit one of our websites or use our apps, we automatically collect:
- the internet protocol (IP) address of your device and details regarding the type of device and browser software you use to access the website;
- details of your use of our websites and apps, namely traffic data, weblogs and statistical data, including where and when you clicked on certain parts of our website, including which of our products you have viewed, and details of the webpage from which you visited it;
- cookie, pixels and beacon identification information (for more information please see our Cookie Policy)
When you visit our social media pages, we collect:
- the information you post on those pages;
- information regarding your interactions with the content we post; and
- statistical information regarding all our followers’ activities (but from which we cannot identify you as we only have access to this information in aggregated form)
When you agree to take part in a research study, we collect:
- the minimum information identifying you needed for the purposes of the research project;
- information about your health, for example in a questionnaire or obtained as part of your clinical care while in the study. In other cases, the information may be copied from your health records. You will be given more precise information about this when you agree to take part in a study
4. HOW WE USE YOUR PERSONAL INFORMATION
We may process your personal information for a number of reasons. We will always ensure we have a valid legal ground to process your personal information. We use your personal information in the following ways:
4.1 WHERE YOU HAVE PROVIDED CONSENT
Where you have provided your consent, we may process your personal information in ways such as the following:
- to contact you via email or telephone (as you have indicated) with marketing information about our products and services (see Section 4.5 ‘Marketing’ for further details);
- to publish your information in line with relevant Codes of Practice such as those published by ABPI
- to respond to your enquiries
You may withdraw your consent for us to use your information at any time. Please see Section 10 ‘Your rights in relation to your personal information’ for further details.
4.2 WHERE NECESSARY TO COMPLY WITH OUR LEGAL OBLIGATIONS
We will use your personal information to comply with our legal obligations:
- to meet legal, regulatory, pharmacovigilance and compliance requirements, and in particular to respond to government authority requests for information;
- to handle and resolve any complaints we receive relating to the services we provide;
- to keep a record of your preferences relating to how we process your personal information
4.3 WHERE NECESSARY FOR US TO PURSUE A LEGITIMATE INTEREST
We use and process your personal information where it is necessary for us to pursue our legitimate interests as a business for the following purposes:
To promote our business, brands and products and measure the reach and effectiveness of our campaigns:
- for analysis and insight conducted to inform our marketing strategies, and to enhance and improve your website visitor experience;
- to tailor and personalise our marketing communications based on your attributes;
- to send you advertising which we believe will be appropriate and of interest to you based on the information we hold about you;
- to identify and record when you have received, opened or engaged with our website or electronic communications (please see our Cookie Policy for more information);
- to reply to correspondence you send to us and fulfil the requests you make to us;
- to respond to changing market conditions and the needs of our visitors to our website;
- to analyse, evaluate and improve our services so that your visit and use of our website, apps, social media pages are more useful and enjoyable (we will generally use data amalgamated from many people so that it does not identify you personally);
- for product development purposes
To operate the administrative and technical aspects of our business efficiently and effectively:
- to administer our website, apps and our social media pages and for internal operations, including troubleshooting, testing, statistical purposes;
- for the prevention of fraud and other criminal activities;
- to verify the accuracy of data that we hold about you and create a better understanding of you as an account holder or website visitor;
- for network and information security in order for us to take steps to protect your information against loss or damage, theft or unauthorised access;
- to comply with a request from you in connection with the exercise of your rights (for example where you have asked us not to contact you for marketing purposes, we will keep a record of this on our suppression lists in order to be able to comply with your request);
- for the purposes of corporate restructure or reorganisation or sale of our business or assets;
- for efficiency, accuracy or other improvements of our databases and systems, for example, by combining systems or consolidating records we hold about you;
- to enforce or protect our contractual or other legal rights or to bring or defend legal proceedings;
- to inform you of updates to our terms and conditions and policies; and
- for other general administration including managing your queries, complaints, or claims, and to send service messages to you
For research studies:
As a healthcare company we have a legitimate interest in performing health and care research in accordance with the UK Policy Framework for Health and Social Care Research:
- to improve individual care;
- to understand more about disease;
- to improve diagnosis;
- to develop new treatments; and
- to improve patient safety
4.4 WHERE PROCESSING IS IN YOUR VITAL INTERESTS
We will use your personal information where this is in your vital interests for the following purposes:
- to notify you of any product recall or product safety issues;
- to monitor the safety or quality of our products where you have raised a product safety or quality concern;
- where you have raised a concern regarding one of our products by letter, email, fax, telephone, through our websites, through our social media pages or by any other means and we need further information, we will contact you as appropriate via telephone, email, letter or by sending you a safety/quality questionnaire for your response to send us by email or post
4.5 MARKETING
We process your personal information for direct marketing purposes on the basis that it is necessary for us to pursue our legitimate interests as a business (see above in this section for further details). We try to tailor and personalise any marketing communications that we send to you, for example, by notifying you of products, services, offers or promotions that apply to your interests and/or location. If you do not wish to receive marketing communications from us, you can unsubscribe at any time by using the unsubscribe link inside the email or by sending an email to dataprivacy@diomed.co.uk or using your email settings (to unsubscribe from marketing emails).
If you unsubscribe from receiving marketing communications from us, we keep your email address on our suppression list for a defined period to ensure that we comply with your wishes. The periods for which we retain your personal information are shown in Section 6.
4.6 CHILDREN
We do not intend to collect data from minors under the age of 16 other than in accordance with our legal obligations or for research purposes or where it is in the child’s vital interests as detailed above, for example, where a concern has been raised regarding the safety of one of our products. We recognise that children’s use of the internet, email and social media raise special concerns regarding privacy and security of information. We remind and encourage all parents to help us protect the privacy of their children by ensuring that children never send or submit personal information to us without parental permission.
When there is a legitimate interest in including children in research studies, this will be explained when agreeing to take part in the study.
