Except as provided in this policy, we will not provide your personal information to third parties and, for the avoidance of doubt, we will only use and store your personal information in the circumstances described in this policy.
It is important that you read this privacy notice together with any other privacy notice or fair processing notice 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 notice supplements the other notices and is not intended to override them.
Collecting personal information
We may collect, store and use the following kinds of personal data about you which we have grouped together as follows:
- Communication Data: includes information contained in or relating to any communications that you send to us or send through our website any other personal information that you choose to send to us.
- Service Data: includes information that you provide to us when using our Services, or that is generated in the course of the use thereof;
- 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.
- Transaction Data: includes details about payments to and from you and other details and products and services you have purchased using our Services.
- We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data). Nor do we collect your credit or debit card details.
- How is your personal data collected
- We use different methods to collect data from and about you including through:
- Automated technologies or interactions: as you interact with our website or our Services (used by content providers) we may 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.
- Third parties or publicly available sources: We may receive your personal data from third party content providers using our Services.
How we use your personal data
We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:
- to administer our Services and business (including troubleshooting, testing, system maintenance, support, reporting and hosting of data);
- to personalise our Services for you (including delivering relevant website content and advertisements);
- to use data analytics to improve our website, products/Services, marketing, customer relationships and experiences.
We will only use your personal data for the purposes for which it was collected, 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 on email@example.com.
Disclosure of your personal data
We may disclose your personal data to any of our employees, officers, insurers, service providers, professional advisers, HM Revenue & Customs insofar as reasonably necessary for the purposes set out in paragraph 4 above.
In particular we may share your personal data with our chosen email provider, Mailchimp – for example if you sign up to receive updates from us regarding developments in medical cannabis. Mailchimp is an online marketing platform operated by The Rocket Science Group LLC, a US company. The Rocket Science Group LLC is registered under the EU-US Privacy Shield framework – see the paragraph on ‘International data transfer’ below.
Use of Mailchimp’s services allows us to manage email campaigns and view real-time data analytics. You can find out more about how Mailchimp collects and stores personal information at https://mailchimp.com/legal/privacy/
We may disclose personal data to our subsidiaries insofar as reasonably necessary for the purposes of paragraph 4 above.
Except as provided in this policy, we will not provide your personal information to third parties.
International data transfer
Whenever we transfer your personal data out of the European Economic Area (EEA), we will 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 by the European Commission. For further details, see European Commission: Adequacy of the protection of personal data in non-EU countries;
- Where we use providers based in the US, we may transfer data to them if they are part of the Privacy Shield which requires them to provide similar protection to personal data shared between the Europe and the US. For further details, see European Commission: EU-US Privacy Shield.
We will only retain your personal data 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 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 requirements.
Securing your personal information
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.
We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
We may update this policy from time to time by publishing a new version on our website.
It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.
You have the right to:
- Request access to your personal data.
- Request a correction of the personal data that we hold about you.
- Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us to continuing to process it. You also have the right to delete or remove data where you have successfully exercised your right t object to processing (see below). Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
- Object to processing of your personal data where we are relying on legitimate interest (or those of a third party) and there is something about your particular situation which makes you object to processing.
- Request restriction of processing of your personal data. You may instruct us at any time not to process your personal information for marketing purposes.
- Request the transfer of your personal data to you or to a third party.
- Withdraw consent at any time where we are relying on consent to process your personal data.
Third party services
We rely on third party services to provide you with our Services. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy notice of every website you visit.
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.
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.
We use session and persistent cookies on our website as well as the local storage capabilities of your browser.
Blocking or deleting any or all cookies may have a negative impact upon the usability of our Services or may practically exclude you from using them completely.
The Services are owned and operated by EMMAC. EMMAC is registered in England and Wales under company number 11253633, with its registered offices at Hill Dickinson LLP The Broadgate Tower, 20 Primrose Street, London, United Kingdom, EC2A 2EW and principal place of business at Gilmoora House, 57-61 Mortimer Street, London, W1W 8HS. You can contact us by writing to the business address given above or by email to firstname.lastname@example.org.