PRIVACY POLICY

This Privacy Notice explains how SALUS ONLINE, a product of Cura Communication LTD a company registered in Scotland (company number SC399518) with its registered office at 6 Luggie Avenue Lenzie Glasgow G66 3JX (SALUS ONLINE, we, our, us), processes personal data and your rights in relation to the personal data we hold.

For the purposes of any applicable data protection laws in Scotland, including from 25 May the Data Protection Act 2018 and the EU General Data Protection Regulation 2016/679 (GDPR), SALUS ONLINE is the data controller of your personal data.

If you have any questions about these rights or how your personal data is used by us, you should contact the Data Protection Officer Lead using the details below:

Post – SALUS ONLINE Data Protection Officer Lead

Address – SALUS ONLINE, 6 Luggie Avenue Lenzie Glasgow G66 3JX

Email – info@salusonline.org

How we use your personal data will depend upon how you use our services. We have included separate sections in section part 1 of this Notice for distinct products and services we offer to help you identify how this Notice is relevant to you. This Notice has the following parts:

1. What personal data we collect, how we use your data, who we share your data with and our legal basis for processing your data.

A. General processing (e.g. marketing and market research, running competitions, administering websites and Apps )

How your personal data is collected

SALUS ONLINE collects your personal data from the following sources:

From you, when you:

1.1 Fill in forms on our website websites or our apps, for example to order products or services, to sign up to a mailing list, or to register to use our website websites and apps

1.2 Participate in a SALUS ONLINE discussion forum or interact on our social media accounts

1.3 Communicate with us by post, telephone, fax, email, social media, webinars, online customer services, or in person

From third parties such as software providers including those:

1.4 Who analyse your use of our websites and apps

1.5 That provide our e-commerce solution; as well as those solutions

1.6 Who process Open Access fees on our behalf; as well as those

Service providers we appoint to host discussion forums, webinars and online chat, or administer surveys and market research on our behalf

B. What categories of personal data are collected?

We collect the following categories of personal data:

Identification and contact details

1. Biographical information such as your name, title, date of birth, age and gender

2. Your contact details including address, email address, phone number and social media identifiers

Online and transactional

1. When you visit our website or use our apps we collect details of your Internet Protocol (IP) address, location (including institution), browser type and version, and operating system

2. Details about how you use our website and apps including the content you accessed, any searches you conducted, your length of visit, login details, time and date of visit and what method you used to browse away from our website

3. Content and links you accessed in our marketing emails

Special categories of personal data

1. Where appropriate, we may obtain diversity and background information including ethnic origin, race, religious and political beliefs, health data or information concerning your sex life and sexual orientation, that you provide to us in our surveys or for our market research. We may also collect details of trade union membership, for example, where membership (such as membership of the BMA) entitles you to access to, or a discount on, our products.

How we use your data, the basis for processing your data and with whom we share it

As part of a contractual relationship

We may process your personal data because it is necessary for the performance of a contract to deliver products you have engaged us for, or in order to take steps at your request prior to entering into a contract. In this respect, we use your personal data to provide products that you (or your organisation) have requested from us and to communicate with you in relation to these products.

We will provide your data to the following (but only for purposes connected with our fulfilling contracts with you):

1. To the sponsor company only

Legitimate interests

Your personal data will also be processed because it is necessary for SALUS ONLINE's legitimate interests or the legitimate interests of a third party. This will always be weighed against your rights, interests and expectations. Examples of where we process data for purposes that fall under legitimate interests include:

1. Marketing SALUS ONLINE and its products (and third party products) online, or by post, telephone, SMS, social media and email (except where we provide communications under contract, or in situations where it is required or appropriate to seek your consent)

2. Researching, identifying and contacting business contacts for marketing SALUS ONLINE products and services on a business to business basis

3. Carrying out market research

4. Improving our products and services

5. Measuring and understanding the effectiveness of products and our advertising and to allow us (and third parties who advertise on our website and apps) to deliver relevant advertising to you (including ensuring that we do not advertise medical products that are not licensed in your country)

6. Processing technical information about your use of our website and apps to ensure that content is presented in the most effective manner and to allow you to use interactive features of our website and apps

7. Processing enquiries, complaints and analysing our services

8. Consulting our professional advisers (including legal) where it is necessary for us to obtain their advice or assistance

9. Providing your data to a buyer or prospective buyer of the whole or a part of our business (except in circumstances where this is necessary for the performance of a contract to which you are a party)

10. Dealing with enquiries and investigations by authorities where a statutory or regulatory obligation does not exist (for example, cooperating with the Advertising Standards Agency).

In this respect, in addition to those parties named above, we will provide your data to the following:

sponsors or other organisations who have provided prizes for competitions you have won or who are involved in the delivery of a grant award. We may also share your name and contact details with sponsors where you have entered a competition and provided consent for your details to be shared for this purpose; for this purpose.

SALUS ONLINE's Legal Obligations

Your personal data will also be processed by SALUS ONLINE for compliance with its legal and regulatory obligations such as:

1. The detection and prevention of crime and in order to assist the police and other competent authorities with investigations

2. To comply with tax legislation and subject access requests of others; and

3. To comply with any regulatory obligations to which we are, or may become, subject. In this respect, we may in specific circumstances need to share your personal data with third parties who have made legitimate requests under data protection law; the police and other law enforcement agencies; HMRC and SALUS ONLINE's external auditors.

Consent

In some circumstances SALUS ONLINE may seek your explicit consent to process your personal data: for example, if we wish to use your likeness or an attributed quote in our materials or where it is otherwise appropriate.

Special categories of personal data

Where we process special categories of personal data, we do so under the following bases:

1. To protect your vital interests; for example, to inform an emergency contact, the NHS or emergency services in the event of your illness or other emergency

2. With your explicit consent, for example if you provide information about your health, ethnicity, sexual orientation or religious beliefs, etc in a survey for our market research or information about your BMA membership where this is relevant to access to (or a discount on) a product

3. Where processing is necessary for the establishment, exercise or defence of a legal claim.

Profiling and automated decision making

We use personal characteristics such as age, gender, address, role, your expressed interests, your previous interactions with SALUS ONLINE or geographical location to target our communications to a specific audience.

SALUS ONLINE also uses a range of advertising technologies like pixels, ad tags, cookies and mobile identifiers as well as specific services used by some websites and social media networks, such as Facebook, to present SALUS ONLINE adverts to you when you are on other websites and apps. These adverts will be based on information we hold about you about your previous use of SALUS ONLINE sites (for example, your SALUS ONLINE search history, the content you accessed and the adverts you clicked on)

International transfers of data

SALUS ONLINE will, in limited circumstances, disclose personal data to third parties, or allow personal data to be stored or handled, in countries outside the European Economic Area. In these circumstances, your personal data will only be transferred on one of the following bases:

1. Where the transfer is subject to one or more of the "appropriate safeguards" for international transfers prescribed by applicable law (e.g. standard data protection clauses adopted by the European Commission under Article 46(2)(c) GDPR). If you wish to obtain a copy of the standard clauses we use, please contact us

2. Under an approved certification mechanism such as Privacy Shield (Article 42 GDPR)

3. European Commission decision provides that the country or territory to which the transfer is made ensures an adequate level of protection (Article 45 GDPR)

There exists another situation where the transfer is permitted under applicable law (for example, where we have your explicit consent).

How long we retain your information

We retain your data for as long as is required to provide our products to you or is as necessary for our legal purposes or our legitimate interests. In particular, we generally retain data in relation to:

1. Products provided by us for ten years after the product has been provided, unless our relationship with you continues for a longer period

2. Information gained from the cookies we use on our website and apps for 30 days

3. Marketing purposes until you inform us that you no longer wish to hear from us (for example, through clicking ‘unsubscribe’ on an email communication). If you express this preference we may retain your contact details on a suppression list so that you no longer receive communications from us.