Privacy Policy

1. Introduction

OMED Health is committed to protecting the privacy and security of your personal information. We take care to protect the privacy of actual and prospective customers and patients, as well as all other users or parties that otherwise interact with us or visit our website.

We have therefore developed this privacy notice to inform you of the data we collect, what we do with your information, what we do to keep it secure as well as the rights and choices you have over your personal information.

Throughout this document we refer to Data Protection Legislation, which means the Data Protection Act 2018 (DPA 2018), United Kingdom General Data Protection Regulation (UK GDPR), the Privacy and Electronic Communications (EC Directive) Regulations 2003 and any legislation implemented in connection with the aforementioned legislation. Where data is processed by a controller or processor established in the European Union or comprises the data of people in the European Union, it also includes the EU General Data Protection Regulation (EU GDPR). This includes any replacement legislation coming into effect from time to time.

Where data is processed on individuals based in the United States (US), OMED will process your Personal Data in accordance with Data Protection Legislation as defined above and in line with this privacy notice. Should there be any additional requirements from any US legislation that applies to our processing of your data, we will process your data in accordance with the relevant piece of legislation.

2. About us

Firstly, some information about us.  Owlstone Medical Limited (“OML”) (Company Number 04955647) has launched this OMED Health website (“OMED”) as a brand name for its digestive health related tests and activities.

OML remains the legal and beneficial owner of OMED.  OML is registered with the Information Commissioner’s Office (the ICO) with registration number ZB023504.

In this Privacy Notice, the terms “we”, “us”, and “our” (and other similar terms) refer to OML’s activities as Omed Health and no other part of its processing activities. The OML privacy notice can be found here: https://www.owlstonemedical.com/privacy-policy/

We are the controller for the personal information we process as identified in this privacy notice. In some circumstances, OMED may facilitate referrals  on behalf of other organisations. In such circumstances, the other organisation will be the controller and so you should refer to their privacy notices for details of how your data is processed.

We have appointed a Data Protection Officer to help us monitor internal compliance, inform, and advise on data protection obligations, and act as a point of contact for data subjects and the ICO.

Our Data Protection Officer is:

The DPO Centre Ltd.
50 Liverpool Street
London
EC2M 7PY
www.dpocentre.com

We have also appointed an EU Representative to act on our behalf for EU GDPR matters.

Our EU Representative is The DPO Centre Europe Ltd.

For further details on how you can contact us or our EU Representative, please see the contact us section below.

3. The information we collect and when.

We only collect personal information that we know we will genuinely use and in accordance with Data Protection Legislation. The type of personal information that we will collect on you depends on the nature of the relationship that we have with you. We may collect the following :

• Contact Data: Personal and contact information (such as name, job title and employer name, email address, mailing address, phone number, and emergency contact information).
• Online Data: Cookies and IP addresses. For more information, please see our cookie banner and Cookie Policy.
• Communications Data: Your communication preferences, subscriptions, feedback and any records of interactions with you.
• Market Research Data: Any data that you provide to us in response to market research or as part of a user group. This could include your opinion on our products and services, or answers to questions we have asked you, such as your age. The data processed for market research will be made clear to you when you participate in the research and could include Special Category Data.
• Health Data: Information that reveals or infers details about your health, which may include medical background, health symptoms or details relating to digestive health.
• Other Data: Information that we may collect that is not specifically listed here but that we will use in accordance with this privacy notice or as otherwise disclosed at the time of collection.

In most instances, you are under no statutory or contractual requirement or obligation to provide us with your personal information; however, we will often require elements of the information above in order to provide our services to you in an efficient and effective manner.

4. How we use your information

4.1 Collection

In most instances we collect personal information directly from you, for example from online forms, if you have provided your information to us at an event, by email, from clicking on one of our ads or as part of a market research survey.

In some instances, one of our partner organisations may refer you to us. In these instances, should you confirm your interest our partner organisation will be independent controllers of your information. Any processing of your information through OMED will be covered in this notice, or as part of other information provided to you.

There may be instances where we refer you to a partner organisation, in which case, the other organisation will be the data controller for any data submitted to them.

4.2 Lawful basis

We only process, store or transfer your personal information when we have a legal basis for doing so. The lawful bases we may rely on to process the information identified in this notice are as follows:

• Legitimate Interest: processing is necessary for the purposes of our legitimate interests (i.e., our business interests), except where such interests are overridden by your interests or fundamental rights and freedoms.
• Consent: You have given consent to the processing of your personal data for one or more specific purposes. You may withdraw this consent at any time, either through the channel in which you provided your consent, or by getting in touch via the contact us section below.
• Legal obligation: processing is necessary for compliance with our legal obligations.

4.4 Sensitive data

If you agree to take part in one of our user groups or market research activities, we may ask you for information relating to your health, which is sometimes called ‘special category data’. We will only process this data under limited circumstances and where you provide your explicit consent for us to do so. You may withdraw this consent at any time by contacting us via the contact us section below. Sensitive data will be managed in accordance with our usual high-standards of security.

4.3 Purpose

We may use your data in the following ways:

4.5 De-identified data

In addition, we may create anonymous, aggregated, or de-identified data from your personal information and other individuals whose personal information we collect. We do this by excluding information that makes the data personally identifiable to you.

5. Who we might share your information with

We may share your personal data with trusted third-party organisations, subject to written agreements, as follows:

• With third party companies or individuals (data processors) to perform services on our behalf. This could include data storage and analytics companies; technology support and communication services (email, web hosting, marketing, and advertising providers, etc.).

We only share your data with data processors that can provide sufficient guarantees that they will process your data securely and in accordance with Data Protection Legislation. Our data processors are not legally permitted to do anything with your personal information unless we have instructed them to do it. They have provided us with written agreements that they will not share your personal information with any organisation apart from us or further sub-processors (supporting an aspect of the same service, study, trial or otherwise) which must process your personal to the same high standards.

• With partners with whom we jointly process your data or otherwise process data as independent controllers.
• With professional advisors, such as lawyers, where necessary in the course of the professional services that they render to us.
• With government or law enforcement officials or private parties as required by law and disclose and use such information as we believe necessary or appropriate.

In some situations, we may have a separate agreement or relationship with you with respect to a specific type of processing of your data. These situations will be governed by specific terms, privacy notices, or consent forms that provide additional information about how we will use your information.  We will honour these additional terms with respect to your information and thus, strongly recommend you review the additional terms prior to participating.

6. International transfers of information

Whenever we transfer your personal information outside of the UK to countries not deemed by the ICO (and/or European Commission as relevant) to provide an adequate level of personal information protection, the transfer will be based on safeguards that allow us to conduct the transfer in accordance with the data protection legislation, such as the specific contracts approved by the ICO (or European Commission as relevant) providing adequate protection of personal information.

7. How we keep you updated on our services

As identified in 4.3 above, we may contact you for several purposes.

We may send you service messages that provide you with information that we legitimately have cause to send you as a user of our products and services or in order to help us improve our products and services (feedback requests, market research, etc.). Such messages will not contain promotional material.

We may separately send you information regarding our products and services where we believe such messages are relevant and will be of interest to you. In such instances, we will contact you if you have provided your consent for the processing or where you are an existing customer that has bought or negotiated to buy products and services from us in the past and have not opted out of receiving such communications. Each email communication will have an option to object to the processing, if you wish to amend your marketing preferences, you can do so by following the link in the email and updating your preferences or by calling us on the number displayed on our website.If you are a business contact, we may send you relevant news about our services or products if we have a legitimate interest to do so.

7.1 OMED Waitlist

You can sign up to the OMED Waitlist to receive information relating to our products prior to release in your location. As a subscriber to the Waitlist, we will send you release information, blog articles and other product information relevant to you.

Once products are live in your location, you may be contacted for up to a further 12 months, at which point your data will be deleted and you will not be contacted further unless you demonstrate renewed interest in our products. If we do not launch a product in your location within 24 months of you signing up to our Waitlist, your information will be deleted, and you will not be contacted further. You may withdraw your consent at any time.

8. Your rights over your information

8.1 The right to be informed about our collection and use of personal data

You have the right to be informed about the collection and use of your personal data. We ensure we do this with our internal data protection policies and through this and other privacy notices. These are regularly reviewed and updated to ensure these are accurate and reflect our data processing activities.

8.2 Right to access your personal information

You have the right to access the personal information that we hold about you in many circumstances, by making a request. This is referred to as a ‘Data Subject Access Request’. If we agree that we are obliged to provide personal information to you (or someone else on your behalf), we will typically provide it to you or them free of charge and aim to do so within one month from when your identity has been confirmed.

If you would like to exercise this right, please contact us as set out below.

8.3 Right to rectify your personal information

If any of the personal information we hold about you is inaccurate, incomplete, or out of date, you may ask us to correct it.

If you would like to exercise this right, please contact us as set out below.

8.4 Right to object or restrict our processing of your data

You have the right to object to us processing your personal information for particular purposes or have its processing restricted in certain circumstances.

If you would like to exercise this right, please contact us as set out below.

8.5 Right to erasure

You have the right to have personal data erased. This is also known as the ‘right to be forgotten’. The right is not absolute and only applies in certain circumstances.

If you would like to exercise this right, please contact us as set out below.

8.6 Right to portability

The right to portability gives you the right to receive personal data you have provided to a controller in a structured, commonly used, and machine-readable format. It also gives them you the right to request that a controller transmits this data directly to another controller.

This right is unlikely to apply to OMED’s use of your data, but if you would like to discuss this right, please contact us as set out below.

8.7 For more information about your privacy rights

The Information Commissioner’s Office (ICO) regulates data protection and privacy matters in the UK. They make a lot of information accessible to consumers on their website and they ensure that the registered details of all data controllers such as ourselves are available publicly. You can access them here https://ico.org.uk/for-the-public.

You can make a complaint to the ICO at any time about the way we use your information. However, we hope that you would consider raising any issue or complaint you have with us first. Your satisfaction is extremely important to us, and we will always do our very best to solve any problems you may have.

9. How long we keep your information for

We will retain your personal information in order to provide you with a high-quality service, in accordance with Data Protection Legislation and for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

To determine the appropriate retention period for personal information, we consider the amount, nature, and sensitivity of the personal information, the potential risk of harm from unauthorised use or disclosure of your personal information, the purposes for which we process your personal information and whether we can achieve those purposes through other means.

In some circumstances we may anonymise your personal information (so that it can no longer be associated with you).

10. Giving your reviews and sharing your thoughts

When using our websites, you may be able to share information through social networks like Facebook and Instagram. For example, when you ‘like’, ‘share’ or review our Services. When doing this, your personal information may be visible to the providers of those social networks and/or their other users. Please remember it is your responsibility to set appropriate privacy settings on your social network accounts, so you are comfortable with how your information is used and shared on them.

11. Security

Data security is of great importance to us and to protect your data we have put in place suitable physical, electronic, and managerial procedures to safeguard and secure your collected data.

We take security measures to protect your information including:

• Limiting access to our buildings to those that we have determined are entitled to be there (by use of passes, key card access and other related technologies).
• Implementing access controls to our information technology.
• We use appropriate procedures and technical security measures (including pseudonymisation, strict encryption and archiving techniques) to safeguard your information across all our computer systems, networks, websites, mobile apps, offices, and stores.

12. Changes to Our Privacy Notice

We may change this privacy notice from time to time (for example, if the law changes or we expand our processing). We recommend that you check this notice regularly to keep up to date.

13. How to contact us

If you would like to exercise one of your rights as set out above, or you have a question or a complaint about this notice, the way your personal information is processed, please contact us by one of the following means:

By email: Privacy@Owlstone.co.uk
By post: Owlstone Medical Limited, 183, Cambridge Science Park, Milton Road, Milton, Cambridge, CB4 0GJ
By phone: 01223 428200

If you are based in Europe, you can contact our EU Representative, The DPO Centre Europe Ltd: By email: EuRep@Owlstone.co.uk
By post: The DPO Centre Ltd, Rue des Poissonniers 13, 1000 Brussels, Belgium
By phone: +32 2 786 19 61

Please note, if you are exercising one of your data subject rights, we may need to ask for proof of identity and sufficient information about your interactions with us, as permitted by Data Protection Legislation.

Thank you for taking the time to read our privacy notice.

This notice was last updated on 2nd August 2023