Introduction
1.1 Future Health Technologies Limited (“we”, “us” and “our”) is committed to safeguarding the privacy of our website visitors and service users. In this policy we explain how we will handle your personal data.
1.2 This privacy policy (together with any other documents referred to in it) sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us. Please read the following carefully to understand our practices regarding your personal data and how we will treat it. By visiting www.futurehealthbiobank.com, a website owned and operated by Future Health Technologies Limited, you are accepting and consenting to the practices described in this privacy policy.
1.3 For the purposes of applicable data protection laws, legislation and regulations, the data controller is Future Health Technologies Limited. We are registered in England and Wales under company number 04431145 and have our registered office at 10 Faraday Building, Nottingham Science and Technology Park, University Boulevard, Nottingham NG7 2QP, United Kingdom. Our VAT number is GB 84746 3203.
1.4 We are accredited by the UK Medicines and Healthcare products Regulatory Agency. Our certificate number is 0083/00/00/0-04.
1.5 We are regulated by the Human Tissue Authority. Our licence reference numbers is 22503. How we use your personal data
2.1 In this Section 2 we have set out:
(a) the general categories of personal data that we may process;
(b) the purposes for which we may process personal data; and
(c) the legal basis of the processing.
2.2 We may process data about your use of our website and services (“usage data”). The usage data may include your IP address, geographical location, browser type and version, operating system, referral source, length of visit, page views and the website navigation paths, as well as information about the timing, frequency and pattern of your service use. The source of the usage data is our analytics tracking system. This usage data may be processed for the purposes of analysing the use of the website and services. The legal basis for this processing is our legitimate interests, namely monitoring and improving our website and services.
2.3 We may process your account data (“account data”). The account data may include your name, address, telephone number, email address, gender, marital status and dependants. The account data may be processed for the purposes of operating our website, providing our services, ensuring the security of our website and services, maintaining back-ups of our databases and communicating with you (including for the purposes of offering and marketing products and/or services to you relating to our stem cells storage services). The legal basis for this processing is our legitimate interests, namely the proper administration of our website and business, and the performance of a contract between you and us at your request, to enter into such a contract.
2.4 We may process your information included in your personal profile on our website (“profile data”). The profile data may include your name, address, telephone number, email address, gender, marital status and dependants. The profile data may be processed for the purposes of enabling and monitoring your use of our website and services. The legal basis for this processing is our legitimate interests, namely the proper administration of our website and business, and the performance of a contract between you and us, at your request, to enter into such a contract.
2.5 We may process your personal data provided in the course of the use of our services (“service data”). The service data may include your IP address, geographical location, browser type and version, operating system, referral source, length of visit, page views and the website navigation paths, as well as information about the timing, frequency and pattern of your service use. The service data may be processed for the purposes of operating our website, providing our services, ensuring the security of our website and services, maintaining back-ups of our databases and communicating with you. The legal basis for this processing is our legitimate interests, namely the proper administration of our website and business.
2.6 We may process information contained in any enquiry you submit to us regarding products and/or services (“enquiry data”). The enquiry data may be processed for the purposes of offering, marketing and selling relevant products and/or services to you. The legal basis for this processing is our legitimate interests, namely the proper administration of our website and business and communications with users.
2.7 We may process information relating to transactions, including purchases of goods and services, that you enter into with us and/or through our website (“transaction data”). The transaction data may include your contact details, your card details and the transaction details. The transaction data may be processed for the purpose of supplying the purchased goods and services and keeping proper records of those transactions. The legal basis for this processing is the performance of a contract between you and us, at your request, to enter into such a contract and our legitimate interests, namely our interest in the proper administration of our website and business.
2.8 We may process information that you provide to us for the purpose of subscribing to our email notifications and/or newsletters (“notification data”). The notification data may be processed for the purposes of sending you the relevant notifications and/or newsletters. The legal basis for this processing is our legitimate interests, namely our interest in the proper administration of our website and business and communications with users.
2.9 We may process information contained in or relating to any communication that you send to us (“correspondence data”). The correspondence data may include the communication content and metadata associated with the communication. Our website will generate the metadata associated with communications made using the website contact forms. The correspondence data may be processed for the purposes of communicating with you and record-keeping. The legal basis for this processing is our legitimate interest, namely the proper administration of our website and business and communications with users.
2.10 In addition to the specific purposes for which we may process your personal data set out in this Section 2, we may also process any of your personal data where such processing is necessary for the compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.
2.11 Please do not supply any other person’s personal data to us, unless we prompt you to do so. Providing your personal data to others
3.1 We may disclose your personal data to any member of our group of companies (this means our subsidiaries, our ultimate holding company and all its subsidiaries) insofar as reasonably necessary for the purposes set out in this policy.
3.2 We may disclose your personal data to our insurers and/or professional advisers insofar as reasonably necessary for the purposes of obtaining and maintaining insurance coverage, managing risks, obtaining professional advice and managing legal disputes.
3.3 We may disclose your personal data to our suppliers or subcontractors insofar as reasonably necessary for the purposes of providing stem cell storage services and/or related products or services.
3.4 Financial transactions relating to our website and services may be handled by our payment services providers. We will share transaction data with our payment services providers only to the extent necessary for the purposes of processing your payments, refunding such payments and dealing with complaints and queries relating to such payments and refunds. You can find information about such payment services providers’ privacy policies and practices at on their respective websites.
3.5 In addition to the specific disclosures of personal data set out in this Section 3, we may also disclose your personal data where such disclosure is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person. International transfers of your personal data
4.1 In this Section 4, we provide information about the circumstances in which your personal data may be transferred to countries outside the European Economic Area (EEA).
4.2 Some of our other group companies, suppliers and subcontractors to whom we may disclose your personal data under Section 3 above have offices and facilities situated outside the EEA. Transfers of your personal data to any such office or facility will be protected by appropriate safeguards.
4.3 Some of the hosting facilities for our website are situated outside the EEA. Transfers of your personal data to any such facility will be protected by appropriate safeguards. Retaining and deleting personal data
5.1 This Section 5 sets out our data retention policies and procedures, which are designed to help ensure that we comply with our legal obligations in relation to the retention and deletion of personal data.
5.2 Personal data that we process for any purpose or purposes shall not be kept for longer than is necessary for that purpose or those purposes.
5.3 Notwithstanding the other provisions of this Section 5, we may retain your personal data where such retention is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person. Amendments
6.1 We may update this policy from time to time by publishing a new version on our website.
6.2 You should check this page occasionally to ensure you are happy with any changes to this policy.
6.3 We may notify you of changes to this policy by email or through the private messaging system on our website. Your rights
7.1 In this Section 7, we have summarised the rights that you have under data protection law. Some of the rights are complex, and not all of the details have been included in our summaries. Accordingly, you should read the relevant laws and guidance from the regulatory authorities for a full explanation of these rights.
7.2 Your principal rights under data protection law are:
(a)the right to access;
(b)the right to reflection;
(c)the right to erasure;
(d)the right to restrict processing;
(e)the right to object to processing;
(f)the right to complain to a supervisory authority; and
(g)the right to withdraw consent.
7.3 You have the right to confirmation as to whether or not we process your personal data and, where we do, access to the personal data, together with certain additional information. That additional information includes details of the purposes of the processing, the categories of personal data concerned and the recipients of the personal data. Providing the rights and freedoms of others are not affected, we will supply to you a copy of your personal data. The first copy will be provided free of charge, but additional copies may be subject to a reasonable fee.
7.4 You have the right to have any inaccurate personal data about you rectified and, taking into account the purposes of the processing, to have any incomplete personal data about you completed.
7.5 In some circumstances you have the right to the erasure of your personal data without undue delay. Those circumstances include where the personal data is no longer necessary in relation to the purposes for which they were collected or otherwise processed. However, there are certain general exclusions of the right to erasure. Those general exclusions include where processing is necessary for compliance with a legal obligation or for the establishment, exercise or defence of legal claims.
7.6 In some circumstances you have the right to restrict the processing of your personal data. Those circumstances include where you contest or wish for us to establish the accuracy of the personal data or the ongoing need for the personal data for the purposes of our processing. Where processing has been restricted on this basis, we may continue to store your personal data. However, we will only otherwise process it with your consent, for the establishment, exercise or defence of legal claims, for the protection of the rights of another natural or legal person or for reasons of important public interest.
7.7 You have the right to object to our processing of your personal data on grounds relating to your particular situation but only to the extent that the legal basis for the processing is that the processing is necessary for the performance of a task carried out in the public interest or for legitimate interests pursued by us or by a third party. If you make such objection, we will cease to process the personal information unless we can demonstrate compelling legitimate grounds for the processing that override your interests, rights and freedoms, or the processing is for the establishment, exercise or defence of legal claims.
7.8 You have the right to object to our processing of your personal data for any direct marketing purpose (including profiling for direct marketing purposes). If you make such an objection, we will cease to process your personal data for this purpose.
7.9 You have the right to object to our processing of your personal data for scientific or historical research purposes or statistical purposes on grounds relating to your particular situation, unless the processing is necessary for the performance of a task carried out for reasons of public interest.
7.10 If you consider that our processing of your personal information infringes data protection laws, you have a legal right to lodge a complaint with a supervisory authority responsible for data protection. You may do so in the EU member state of your habitual residence, your place of work or the place of the alleged infringement.
7.11 To the extent that the legal basis for our processing of your personal information is consent, you have the right to withdraw that consent at any time. Withdrawal will not affect the lawfulness of processing before the withdrawal.
7.12 You may exercise any of your rights in relation to your personal data by written notice to us. About cookies
8.1 A cookie is a file containing an identifier (a string of letters and numbers) that is sent by a web server to a web browser and is stored by the browser. The identifier is then sent back to the server each time the browser requests a page from the server.
8.2 Cookies may be either “persistent” cookies or “session” cookies: a persistent cookie will be stored by a web browser and will remain valid until its set expiry date, unless deleted by the user before the expiry date; a session cookie, on the other hand, will expire at the end of the user session, when the web browser is closed.
8.3 Cookies do not typically contain any information that personally identifies a user, but personal information that we store about you may be linked to the information stored in and obtained from cookies. Cookies that we use
9.1 We use cookies for the following purposes:
(a) authentication – we use cookies to identify you when you visit our website and as you navigate our website (cookies used for this purpose are: [identify cookies]);
(b) status – we use cookies to help us to determine if you are logged into our website (cookies used for this purpose are: [identify cookies]);
(c) personalisation – we use cookies to store information about your preferences and to personalise the website for you (cookies used for this purpose are: [identify cookies]); and
(d) security – we use cookies as an element of the security measures used to protect user accounts, including preventing fraudulent use of login credentials, and to protect our website and services generally (cookies used for this purpose are: [identify cookies]). Cookies used by our service providers
10.1 Our service providers use cookies and those cookies may be stored on your computer when you visit our website.
10.2 We use Google Analytics to analyse the use of our website. Google Analytics gathers information about website use by means of cookies. The information gathered relating to our website is used to create reports about the use of our website. Google’s privacy policy is available at: https:/www.google.com/policies/privacy/. The relevant cookies are: [identify cookies].
