Privacy Policy
PRIVACY POLICY
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Introduction
NeoVos respects the privacy of its customers and visitors to its website and is committed to protecting the privacy of the Personal Data (defined below) that you share with us.
This Privacy Policy explains how we handle the personal information that you provide to us on websites controlled by NeoVos, a brand of SureScreen Scientifics Ltd along with SureScreen Health (including its subsidiaries and affiliates) which link to this Privacy Policy (referred to as “NeoVos Websites”). The EU General Data Protection Regulation (“GDPR”) is in force from 25 May 2018. The GDPR amends and updates the rights you have in relation to your Personal Data. The GDPR also regulates what companies that process your Personal Data are permitted to do with it. This Privacy Policy provides you with information relating to the processing of your Personal Data. It also explains how you may exercise your data protection rights under the GDPR.
This website is not intended for children and we do not knowingly collect data relating to children.
This Privacy Policy does not apply to personal information collected from you offline, to NeoVos Websites that do not link to this Privacy Policy, or to third party websites to which NeoVos Websites may link. Your use of NeoVos Websites, which link to this Privacy Policy is subject to this Privacy Policy and the Terms of Use.
It is important that you read this privacy policy together with any other privacy policy or fair processing policy we may provide on specific occasions when we are collecting or processing personal data about you so that you are 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.
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What is Personal Data?
“Personal Data” is any information that identifies you or from which you could be identified, in particular by reference to an identifier such as a name, an identification number, location data, an online identified or one or more factors specific to the physical, psychological, genetic, mental, economic or social identity. Personal Data includes subsets of special categories of information that reveal information about your health, among other things.
SureScreen Scientifics Limited is the controller and responsible for your personal data (collectively referred to as “NeoVos”, “we”, “us” or “our” in this privacy policy).
We have appointed a data protection officer (DPO) who is responsible for overseeing questions in relation to this privacy policy. If you have any questions about this privacy policy, including any requests to exercise your legal rights, please contact the DPO by emailing [email protected]..
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The data we collect about you
We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:
- Identity Data includes [first name, surname, username or similar identifier, date of birth and sex].
- Contact Data includes [billing address, delivery address, email address and telephone numbers].
- Financial Data includes [bank account and payment card details].
- Transaction Data includes [details about payments to and from you and other details of products and services you have purchased from us].
- 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].
- Profile Data includes [your username and password, purchases or orders made by you, your interests, preferences, feedback and survey responses].
- Usage Data includes [information about how you use our website, products and services].
- Marketing and Communications Data includes [your preferences in receiving marketing from us and our third parties and your communication preferences].
- Relevant health, diet and lifestyle data [how often you exercise and how much fiber do you eat etc.]
- Laboratory results [raw results from samples you have provided]
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 website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy policy.
We do not collect information about criminal convictions and offences.
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How do NeoVos collect your data?
We use different methods to collect data from and about you including through:
- Direct interactions. You may give us your [Identity, Contact and Financial Data] by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
- apply for our products or services;
- create an account on our website;
- subscribe to our service or publications;
- request marketing to be sent to you;
- enter a competition, promotion or survey; or
- give us feedback or contact us.
- Automated technologies or interactions. As you interact with our website, we will automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies[server logs] and other similar technologies. [We may also receive Technical Data about you if you visit other websites employing our cookies.]
- Third parties or publicly available sources. We will receive personal data about you from various third parties [and public sources] as set out below:
Technical Data from the following parties:
- analytics providers [such as Google based outside the UK];
- advertising networks [based [inside OR outside] the UK]; and
- search information providers [based [inside OR outside] the UK].
- Contact, Financial and Transaction Data from providers of technical, payment and delivery services [based [inside OR outside] the UK].
- Identity and Contact Data from data brokers or aggregators [based [inside OR outside] the UK].
- Identity and Contact Data from publicly available sources [such as Companies House and the Electoral Register based inside the UK].
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Why does NeoVos process your Personal Data?
NeoVos processes your Personal Data in accordance with the details outlined below:
Purpose/activity
Type of data
Lawful basis
To process your data when you sign up or register for our services, or download and use one of our mobile apps
(a) Identity
(b) Contact
To perform a contract with you
To process and deliver your order including:
(a) Manage payments, fees and charges
(b) Collect and recover money owed to us
(a) Identity
(b) Contact
(c) Financial
(d) Transaction
(e) Marketing and Communications
(a) Performance of a contract with you
(b) Necessary for our legitimate interests (to recover debts due to us)
To process data from your results on our secure online portal when testing kits are bought through NeoVos or third parties.
(a) Identity
(b) Contact
(c) Heath, diet and lifestyle data to aid in results interpretation
(d) Laboratory results
Performance of our contract with you.
Necessary for our legitimate interests to third parties
To manage our relationship with you which will include:
(a) Notifying you about changes to our terms or privacy policy
(b) to provide information to you in relation to product safety
(a) Identity
(b) Contact
(c) Profile
(a) Performance of a contract with you
(b) To comply with a legal obligation
To provide medical care to you
(a) Identity
(b) Contact
(c) Heath, diet and lifestyle data to aid in results interpretation
(d) Laboratory results
The protection of your vital interests
For scientific research purposes
(a) Identity
(b) Contact
(c) Heath, diet and lifestyle data to aid in results interpretation
(d) Laboratory results
To act in the public interest
For national healthcare purposes
(a) Identity
(b) Contact
(c) Heath, diet and lifestyle data to aid in results interpretation
(d) Laboratory results
To act in the public interest
Marketing or testimonials
(a) Identity
(b) Contact
(c) Heath, diet and lifestyle data to aid in results interpretation
(d) Laboratory results
Where you have consented to the processing of your Personal Data
To collect health data about EU individuals who use NeoVos products
Sensitive Personal Data
Where you have explicitly consented to the processing of your Personal Data
To collect data for medical advice reporting , warranty and product support services
Sensitive Personal Data
Where you have explicitly consented to the processing of your Personal Data
We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.
If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
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Who does NeoVos share your Personal Data with?
NeoVos may share your Personal Data with its affiliate companies within its corporate group. Specifically, NeoVos may share your Personal Data with third party companies where you have originally bought the product from.
NeoVos may also share your Personal Data with vendors with whom NeoVos contracts to carry out business activities for NeoVos. If NeoVos provides your Personal Data to vendors to assist us with our business activities, it is NeoVos’ practice to require those vendors to keep your Personal Data confidential and to use your Personal Data only to perform functions for NeoVos.
NeoVos may share your Personal Data with a third party in connection with the sale or transfer of one of its product lines or divisions so that the buyer can continue to provide you with information and services.
NeoVos reserves the right to disclose your Personal Data to respond to authorized information requests from government authorities, to address national security situations, or when otherwise required by law.
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What is the Privacy Policy of Third Parties?
As stated above we may share your Personal Data with a third party in connection with the sale or transfer of one of its product lines or divisions so that the buyer can continue to provide you with information and services. This Privacy Policy only addresses the collection, processing and use of personal data by us and not by third parties. Other websites may have their own privacy policies, data collection, processing, use and disclosure practices. We would advise that you familiarise yourself with the privacy policy provided by these third party before providing them with information.
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Does NeoVos transfer your Personal Data outside of the United Kingdom?
Whenever we transfer your personal data out of the UK, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:
- We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data.
- Where we use certain service providers, we may use specific contracts approved for use in the UK which give personal data the same protection it has in the UK
Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the UK.
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How long does NeoVos store your Personal Data for?
Your Personal Data will be stored for as long as it is reasonably necessary to provide you with: (i) the NeoVos service or product that you have requested; and/or (ii) access to the NeoVos Websites. Alternatively, your Personal Data will also be stored for as long as we require it to respond to your queries and concerns or in accordance with any legal requirements, including those in relation to product or medical device safety. For further information please contact your local customer care or our UK data protection officer using the details below.
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 personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.
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What NeoVos does to keep Personal Data secure?
It is NeoVos’ practice to secure each web page that collects personal information however, the confidentiality of personal information transmitted over the Internet cannot be guaranteed. We urge you to exercise caution when transmitting personal information over the Internet, especially personal information related to your health. NeoVos cannot guarantee that unauthorized third parties will not gain access to your personal information; therefore, when submitting personal information to our website, you must weigh both the benefits and the risks. In addition, our website covered by this Privacy Policy will display a warning whenever you link to a website that is not controlled by NeoVos or subject to a NeoVos privacy policy; you should check the privacy policies of such third party websites before submitting personal information.
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What rights do you have in relation to your Personal Data?
You may have the following rights in relation to your Personal Data:
- The right to rectify, or erase any wrong or incomplete Personal Data that NeoVos holds about you;
- The right to access the Personal Data that NeoVos holds about you;
- The right, in some cases, to object to the processing of your Personal Data where we process it on the basis of our legitimate business interests;
- The right not to be subject to automated decision making intended to evaluate certain personal aspects relating to you, such as analytics based on conduct. Please refer to the cookies section of this Privacy Policy for more information on how to exercise this right if it is indicated that cookies are being used;
- Where you have provided your Personal Data to us with your consent or as part of a contract, the right to the portability of that Personal Data to another person or, if it’s technically feasible for us to do so, to another company;
- The right to lodge a complaint with your local data protection supervisory authority or to receive compensation for any damage you suffer; and
- The right to withdraw your consent to NeoVos’ processing of your Personal Data without detriment, where you have provided consent for NeoVos to process your Personal Data.
We may ask you for additional information to confirm your identity and for security purposes, before responding to any request you submit.
Where you have been asked to consent to the processing of your Personal Data, we will provide you with an opportunity to withdraw your consent. There may be several methods by which you can withdraw consent, such as by contacting us directly or by deleting an NeoVos mobile app from your smartphone. In each case you will be given information about how to withdraw consent. Any withdrawal of consent will not affect the lawfulness of the processing based on your consent before the withdrawal. Please also note that where you withdraw consent, NeoVos will only stop processing your Personal Data that relates to the withdrawal of consent.
NeoVos may still need to process Personal Data where: we are required to do so by law; we have a legitimate business interest to do so, such as in connection with the sale or transfer of our product lines or divisions; necessary to respond to authorized information requests from government authorities; necessary to address national security situations; or otherwise required by law to which we are subject.
No Fee
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances.
What we may need
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 in relation to your request to speed up our response.
Time Limit
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 a number of requests. In this case, we will notify you and keep you updated.
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Why do NeoVos Websites use “cookies” and other tracking technologies?
NeoVos may use “cookies” to collect other information during an individual’s visit to the NeoVos Websites, such as the particular site areas visited and the services utilized through our website. We collect this information to better tailor our site and our products to your interests and needs. Cookies may also be used to help speed up your future activities on our site. For example, a site can recognize that you have provided Personal Data to use and refrain from requesting the same information a second time. Most browsers are initially set to accept a cookie. Cookies may be disabled by the individual visitor, although refusal of cookies at the site may result in an inability to visit certain areas of the site or to receive personalized information when visiting the site.
In addition, we are constantly trying to improve how we promote our websites. To help us do this, we may measure the effectiveness of our web presence by determining when you accessed the NeoVos Websites, and what you clicked on within our site. Site measurement statistics may be used to personalize your website experience, as well as to evaluate – anonymously and on an aggregated basis – statistics about usage of the website. Information about your computer, such as your IP address (a number assigned to your computer whenever you surf the Internet), the type of Internet browser you are using and the type of operating system you are using may also be collected and linked to your Personal Data. This is to ensure that the NeoVos Websites presents the best web experience for visitors, and that they are effective information resources.
Some of the pages an individual visits may also collect information through the use of pixel tags (also called clear gifs) that may be shared with third parties which directly support NeoVos’ promotional activities and website development. For example, website usage information about visitors to the NeoVos Websites may be shared with our third party advertising agency in order to better target Internet banner advertisements on the NeoVos Websites. The information collected through the use of these pixel tags is not, however, personally identifiable, although it could be linked to an individual’s Personal Data.
For more details about the cookies used on the NeoVos Websites, please click here to see our Cookie Policy.
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What choices do I have about NeoVos’ use of cookies and other tracking technologies?
The specific choices you receive about NeoVos’ use of cookies and other tracking technologies vary by website.
On some NeoVos Websites, you will be asked to consent to the use cookies and/or other tracking technologies on that website. Cookies that are necessary to the operation of the site will continue to function regardless of whether you have provided consent. Other types of cookies and tracking technologies will be turned off until you provide consent. As a result, the functionality of the site may be reduced until you choose to provide consent.
On some NeoVos Websites, you may be provided with preference questions or boxes allowing you to indicate that you do not want that website to use cookies or other tracking technologies that are not necessary to the operation of the site. If you choose to exercise this opt-out option, the functionality of the site may be reduced as a result.
Some Internet browsers allow you to limit or disable the use of cookies and other tracking technologies. Please refer to the information provided by your Internet browser for instructions on how to do so (generally found under a “Help” menu).
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Do I have to provide my Personal Data to NeoVos?
The provision of Personal Data to NeoVos is required to fulfil the terms of a contract you have with NeoVos, to provide you with a product or service you have requested or to comply with local laws, such as those relating to product or medical device safety. Any failure to provide such Personal Data will mean that NeoVos cannot provide you with the product or service you have requested.
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Opting into Marketing
By accepting to ‘opt in’ you are agreeing to receive marketing communications from NeoVos about our products, services and other reasonable marketing materials. You will be able to unsubscribe from these communications at any time.
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Who can I contact?
To exercise any of your rights in connection with your Personal Data or if you have any questions or concerns as to the processing of your Personal Data, please contact our Information Security Officer at Morley Retreat | Church Lane | Morley | DE7 6DE | United Kingdom.
Call 01332 830990, where any-one can take your request and pass it to the Information Security Officer.
E-mail: [email protected]
You can expect to receive confirmation we have received your request within 3 days, and fulfilment of the request within 1 month. There is no charge for providing information; however, repeated requests for the same information may incur a fee.
You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK regulator for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.