Privacy Policy

Last updated April, 2024

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Thank you for choosing to be part of our community at ELECTRONRX LIMITED ("Company", "we", "us", "our"). We are committed to protecting your personal information and your right to privacy. If you have any questions or concerns about this privacy notice, or our practices with regards to your personal information, please contact us at admin@electronrx.com.

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When you visit our website http://www.electronrx.com (the "Website"), and more generally, use any of our services (the "Services", which include the Website), we appreciate that you are trusting us with your personal information. We take your privacy very seriously. In this privacy notice, we seek to explain to you in the clearest way possible what information we collect, how we use it and what rights you have in relation to it. We hope you take some time to read through it carefully, as it is important. If there are any terms in this privacy notice that you do not agree with, please discontinue use of our Services immediately.

This privacy notice applies to all information collected through our Services (which, as described above, includes our Website), as well as, any related services, sales, marketing or events.

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Please read this privacy notice carefully as it will help you understand what we do with the information that we collect.

 

GLOSSARY

The meaning of some terms that we use in this privacy notice: 

 

Automated decision making means a process where we make decisions about you, such as your suitability for a product, using a computer based and automated system without a person being involved in making that decision (at least first time around). 

 

Legitimate interests is mentioned in our privacy notice because data protection laws allow the processing of personal information where the purpose is legitimate and is not outweighed by your interests, fundamental rights and freedoms. Those laws call this the legitimate interests legal ground for personal data processing. 

 

Process or processing includes everything we do with your personal information from its collection, right through to its destruction or deletion when we no longer need it. This includes for instance collecting it (from you), obtaining it (from other organisations), using, sharing, storing, retaining, deleting, destroying, and transferring it outside the UK. 

 

Profiling means any form of automated processing of your personal information to evaluate certain personal aspects about you, such as to analyse or predict aspects concerning your health, personal preferences, interests, behaviour, location or movements. 

 

WHO WE ARE AND HOW TO CONTACT US AND OUR DATA PROTECTION OFFICER 

electronRx Limited of 28 Chesterton Road, Cambridge, CB4 3AZ is a data controller of your personal information. This Privacy Notice describes how we deal with your personal information, which is information that is about you or from which we can identify you. We are the data controller of this information under relevant data protection laws because in the context of our business relationship with you we decide how and why it is processed in the ways explained in this Privacy Notice. When we use terms such as we, us and our in this notice, we mean electronRx Limited. 

 

Our Data Protection Officer can be contacted at any time if you have queries about this privacy notice or wish to exercise any of the rights mentioned in it, by email to admin@electronrx.com 

 

This Privacy Notice may be updated from time to time. This means we may send you an updated copy (depending on whether we are required to do so). 

 

PERSONAL INFORMATION THAT WE GENERALLY PROCESS IN CONNECTION WITH ALL OUR PRODUCTS AND SERVICES 

 

This includes: 

• Your nationality, if this is necessary for us to comply with our legal and regulatory requirements; 

• Your contact email address;

• Records of how you have contacted us and, if you get in touch with us online, details such as your IP address; 

• Anonymised video of your finger and face, and raw chest data will be captured, which will not be linked to any personally identifiable information, note all data is anonymised prior to storage;

• Pseudonymised data from any participants of clinical investigations, where patient ID will link to your health record, and reconcile video recordings of your finger, face and chest.

 

We will generally collect your personal information from you directly.

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WHAT ARE THE LEGAL GROUNDS FOR OUR PROCESSING OF YOUR PERSONAL INFORMATION? 

1. Data protection laws require us to explain what legal grounds justify our processing of your personal information (this includes sharing it with other organisations). For some processing more than one legal ground may be relevant (except where we rely on a consent). Here are the legal grounds that are relevant to us: 

• All stages and activities relevant to managing your account; and 

• For some of our profiling and other automated decision making. We may use automated decision making in assessing you meet the criteria for this product.

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2. Where we consider that, on balance, it is appropriate for us do so, processing necessary for the following legitimate interests which apply to us and in some cases other organisations (who we list below) are: 

• Managing your account and services relating to that, 

• To test the performance of our products, services and internal processes; 

• To adhere to regulatory rules, guidance and best practice under the regimes of governmental and regulatory bodies such BSI, MHRA, FDA; 

• For management and audit of our business operations; 

• For market research and analysis and developing statistics; 

• For direct marketing communications; 

• For some of our profiling and other automated decision making, in particular where this does not have a legal effect or otherwise significantly affect you; we use profiling 

  • to identify appropriate products and services from your customer profile and relationship with us, 

  • Inform business strategy and support product governance to maintain customer outcome standards; and 

  • Complete general management information gathering and trend analysis. 

• When we share your personal information with these other people or organisations; 

  • Members of our Group; 

  • Our legal and other professional advisers, auditors and actuaries; 

  • Governmental and regulatory bodies such as BSI, MHRA, FDA; 

  • Other organisations and businesses who provide services to us such as back up and server hosting providers, IT software and maintenance providers, document storage providers and suppliers of other back office functions; 

  • Buyers and their professional representatives as part of any restructuring or sale of our business or assets; 

  • Market research organisations who help us to develop and improve our products and services

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3. Processing necessary to comply with our legal obligations: 

• For compliance with laws that apply to us; 

• For establishment, defense and enforcement of our legal rights or those of any other member of our Group; 

• To carry out monitoring and to keep records

• To deal with requests from you to exercise your rights under data protection laws; and 

• When we share your personal information with these other people or organisations: 

  • Law enforcement agencies and governmental and regulatory bodies such as BSI, MHRA, FDA; and 

  • Courts and to other organisations where that is necessary for the administration of justice, to protect vital interests and to protect the security or integrity of our business operations. 

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4. Processing with your consent:

• When you request that we share your personal information with someone else and consent to that; 

• For direct marketing communications; 

• For some of our processing of special categories of personal data such as about your health

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HOW AND WHEN CAN YOU WITHDRAW YOUR CONSENT? 

Much of what we do with your personal information is not based on your consent, instead it is based on other legal grounds. For processing that is based on your consent, you have the right to take back that consent for future processing at any time. You can do this by contacting us using the details in the section ‘Who we are and how to contact us and our Data Protection Officer’ above. The consequence might be that we cannot send you some marketing communications or that we cannot take into account special categories of personal data such as about your health (but these outcomes will be relevant only in cases where we rely on explicit consent for this). 

 

IS YOUR PERSONAL INFORMATION TRANSFERRED OUTSIDE THE UK OR THE EEA? 

We are based in the UK but sometimes your personal information may be transferred outside the UK or the European Economic Area (EEA). If it is processed within Europe or other parts of the EEA then it is protected by European data protection standards in accordance with the General Data Protection Regulation. Some countries outside the EEA do have adequate protection for personal information under laws that apply to us. We will make sure that suitable safeguards are in place before we transfer your personal information to countries outside the EEA which do not have adequate protection under laws that apply to us. 

Safeguards include contractual obligations imposed on the recipients of your personal information. Those obligations require the recipient to protect your personal information to the standard required in the EEA. Safeguards also include requiring the recipient to subscribe to ‘international frameworks’ intended to enable secure data sharing and where the framework is the means of protection for the personal information.

 

MONITORING INVOLVING PROCESSING OF YOUR PERSONAL INFORMATION 

Monitoring means any listening to, recording of, viewing of, intercepting of, or taking and keeping records (as the case may be) of calls, email, text messages, social media messages, in person face to face meetings and other communications. 

 

Some of our monitoring may be to comply with regulatory rules, self-regulatory practices or procedures relevant to our business, in the interests of protecting the security of our communications systems and procedures, to have a record of what we have discussed with you and actions agreed with you, to protect you and to provide security for you and for quality control and staff training purposes. Some of our monitoring may check for obscene or profane content in communications. 

 

PROFILING AND OTHER AUTOMATED DECISION MAKING 

This section is relevant where we make decisions about you using only technology, and where none of our employees or any other individuals have been involved in the process. We may do this to decide what marketing communications are suitable for you and to analyse statistics. 

 

We can do this activity based on our legitimate interests (and they are listed in the section about legal grounds above) only where the profiling and other automated decision making does not have a legal or other significant effect on you. In all other cases, we can do this activity only where it is necessary for entering into or performing the relevant contract, is authorised by laws that apply to us, or is based on your explicit consent. In those cases you have the right to obtain human intervention to contest the decision (see ‘rights in relation to automated decision making which has a legal effect or otherwise significantly affects you’ below). Profiling for direct marketing can mean there is a separate right to object.

 

HOW LONG IS YOUR PERSONAL INFORMATION RETAINED BY US?

 Unless we explain otherwise to you, we will hold your personal information for the following periods: 

• Retention in case of queries. We will retain the personal information that we need to keep in case of queries from you for 1 year, unless we have to keep it for a longer period (see directly below)

• Retention in accordance with legal and regulatory requirements. We will retain the personal information that we need to keep even after the relevant account you have with us has come to an end for a period 5 years after the end of the relationship, (where this is not required within the retention in case of claims period) and this will be to satisfy our legal and regulatory requirements. 

 

If you would like further information about our data retention practices, please contact our Data Protection Officer.

 

WHAT ARE YOUR RIGHTS UNDER DATA PROTECTION LAWS? 

Here is a list of the rights that all individuals have under data protection laws. They do not apply in all circumstances. If you wish to exercise any of them we will explain at that time if they are engaged or not. 
 

• The right to be informed about the processing of your personal information;

• The right to have your personal information corrected if it is inaccurate and to have incomplete personal information completed; 

• The right to object to processing of your personal information; 

• The right to restrict processing of your personal information; 

• The right to have your personal information erased (the “right to be forgotten”); 

• The right to request access to your personal information and to obtain information about how we process it; 

• The right to move, copy or transfer your personal information (“data portability”); and 

• Rights in relation to automated decision making which has a legal effect or otherwise significantly affects you. 

 

You have the right to complain to the Information Commissioner’s Office which enforces data protection laws: https://ico.org.uk/. 
 

DATA ANONYMISATION AND USE OF AGGREGATED INFORMATION 

Your personal information may be converted into statistical or aggregated data which cannot be used to re-identify you. It may then be used to produce statistical research and reports. This aggregated data may be shared and used in all the ways described in this Privacy Notice.

 

YOUR MARKETING PREFERENCES AND WHAT THIS MEANS 

We may use your phone numbers, email address and social media (e.g. Facebook, Google and message facilities in other platforms) to contact you according to your marketing preferences. We will only do this if we have a legal ground which allows it under data protection laws. You can stop our marketing at any time by email or by following the instructions on how to do that in the marketing email or other communication. 

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