2. LEGAL BASIS FOR DATA COLLECTION
3. HOW WE USE YOUR PERSONAL DATA
7. HOW LONG WE RETAIN YOUR DATA
8. NOTIFICATION OF CHANGES & ACCEPTANCE OF POLICY
1. INTRODUCTION
Welcome to Clinical IT Ltd’s Privacy Policy (“Privacy Policy”).
At Clinical IT Ltd (“we”, “us”, or “our”), we are committed to protecting and respecting your privacy and personal data in accordance with the United Kingdom General Data Protection Regulation (“UK GDPR”), the Data Protection Act 2018 and all other applicable laws and regulations of the United Kingdom.
This Privacy Policy explains how we collect, use, store and protect personal data when you:
- visit our website;
- contact us;
- request information about our products and services; or
- interact with us as a customer, prospective customer or business contact.
This Privacy Policy does not apply to the processing of user or patient data within the EKORA® platform when deployed by hospitals and healthcare organisations.
When EKORA is used within a healthcare organisation, the healthcare organisation acts as the Data Controller and Clinical IT Ltd acts as the Data Processor. Product-specific privacy information, including details of the categories of data processed and the responsibilities of each party, is available in the EKORA Product Privacy Notice, which can be supplied to customers on request.
Your Data Controller
Clinical IT Ltd is the Data Controller for the personal data covered by this Privacy Policy and is responsible for your personal data.
Any enquiries about your data should be sent to us by email at legal@ekora.io or by post to:
Clinical IT Ltd
5 South Charlotte Street
Edinburgh
EH2 4AN
United Kingdom
You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the opportunity to address your concerns before you contact the ICO, so please contact us in the first instance
2. LEGAL BASIS FOR DATA COLLECTION
Types of data/Privacy Policy scope
“Personal Data” means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data). We may collect, use, store and transfer different kinds of Personal Data about you which we have grouped together below. Not all the following types of data will necessarily be collected from you, but this is the full scope of data that we collect and when we collect it from you:
- Profile/Identity Data: This is data relating to your first name, last name, gender, date of birth.
- Contact Data: This is data relating to your phone number, addresses, email addresses, phone numbers.
- Technical Data: This is your IP address, browser type and version, time zone setting and location, operating system and platform, and other technology on the devices you use to engage with us.
- Customer Support Data: This includes feedback and survey responses.
- Usage Data: information about how you use our website, products and 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 any information about criminal convictions and offences.
The legal basis for collecting that data
There are several justifiable reasons under the GDPR that allow collection and processing of Personal Data. The main avenues we rely on are:
- “Consent”: Certain situations allow us to collect your Personal Data, such as when you tick a box that confirms you are happy to receive email newsletters from us, or ‘opt in’ to a service.
- “Contractual Obligations”: We may require certain information from you to fulfil our contractual obligations and provide you with the promised service.
- “Legal Compliance”: We’re required by law to collect and process certain types of data, such as fraudulent activity or other illegal actions.
- “Legitimate Interest”: We might need to collect certain information from you to be able to meet our legitimate interests – these covers aspects that can be reasonably expected as part of running our business, that will not have a material impact on your rights, freedom or interests. Examples could be your address, so that we know where to deliver something to, or your name, so that we have a record of who to contact moving forwards.
3. HOW WE USE YOUR PERSONAL DATA
Our data uses
We use your Personal Data for the following purposes, where permitted by applicable data protection legislation:
EKORA Education
As part of our training services, we provide the EKORA Education learning platform to deliver online learning, assessments and course administration.
When you use EKORA Education, we process personal information including your name, email address, organisation, country, username, course enrolments, course progress, assessment grades and course completion records.
We use this information to register and manage your learner account, provide access to training courses, record your learning progress and assessment results, issue certificates of completion, and provide learner support where required.
Marketing and content updates
If you create an account on our website or EKORA Education, we may send you communications about new training courses, learning opportunities, product updates, services and other information that we believe may be relevant to you.
You may opt out of receiving marketing communications at any time by emailing sales@ekora.io. We will process your request promptly and remove you from future marketing communications. Opting out of marketing communications will not affect our ability to send you essential service communications relating to your EKORA Education account or the training services we provide.
Change of purpose
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.
4. YOUR RIGHTS AND HOW YOU ARE PROTECTED BY US
Your legal rights
Under certain circumstances, you have the following rights under data protection laws in relation to your personal data:
- Right to be informed. You have a right to be informed about our purposes for processing your personal data, how long we store it for, and who it will be shared with. We have provided this information to you in this policy.
- Right of access. This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it (also known as a “data subject access request”). See section 4.4 below for more details on how you can make a data subject access request.
- Right to rectification. You have a right to request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
- Right to erasure. You have the right to ask us to delete or remove personal data where there is no good reason for us continuing to process it, where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. 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.
- Right to object. You can object to the processing of personal data we hold about you. This effectively allows you to stop or prevent us from processing your personal data. Note that this is not an absolute right, and it only applies in certain circumstances, for example:
- Where we are processing your personal data for direct marketing purposes.
- Where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground, as you feel it impacts your fundamental rights and freedoms.
- In some cases, we may continue processing your data if we can demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
- Right to restrict processing. You have the right to request the restriction or suppression of their personal data. Note that this is not an absolute right and it only applies in certain circumstances:
- If you want us to establish the data’s accuracy.
- Where our use of the data is unlawful, but you do not want us to erase it.
- Where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims.
- You have objected to our use of your data, but we need to verify whether we have overriding legitimate grounds to use it.
- Right to data portability. You have the right to request the transfer of your personal data to you or to a third party. If you make such a request, we will provide you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
If you wish to make a request under any of these rights, please contact us at legal@ekora.io.
How Clinical IT Ltd protects customers’ Personal Data
We are concerned with keeping your data secure and protecting it from inappropriate disclosure. Any Personal Data collected by us is only accessible by a limited number of employees who have special access rights to such systems and are bound by obligations of confidentiality. If and when we use subcontractors to store your data, we will not relinquish control of your Personal Data or expose it to security risks that would not have arisen had the data remained in our possession. However, unfortunately no transmission of data over the internet is guaranteed to be completely secure. It may be possible for third parties not under the control of Clinical IT Ltd to intercept or access transmissions or private communications unlawfully. While we strive to protect your Personal Data, we cannot ensure or warrant the security of any Personal Data you transmit to us. Any such transmission is done at your own risk. If you believe that your interaction with us is no longer secure, please contact us.
Opting out of marketing promotions
You can ask us to stop sending you marketing messages at any time by emailing legal@ekora.io. Where you opt out of receiving these marketing messages, we will continue to retain other Personal Data provided to us as a result of interactions with us not related to your marketing preferences.
How to request your data and the process for obtaining it
You will not have to pay a fee to access your Personal Data (or to exercise any of the other rights). However, if your request is clearly unfounded, we could refuse to comply with your request. We may need to request specific information from you to help us confirm your identity and ensure you have the 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.
5. INFORMATION ABOUT OUR USE OF COOKIES
Our website uses cookies to distinguish you from other users of our website. This helps us to provide you with a good experience when you browse our website and allows us to improve our site. A cookie is a small file of letters and numbers that we store on your browser or the hard drive of your computer if you agree. Cookies contain information that is transferred to your computer’s hard drive.
Strictly Necessary Cookies
These are cookies that are required to enable the basic features of this site. They include, for example, cookies that enable you to log into secure areas of our website or adjusting your consent preferences. These cookies do not store any personally identifiable data.
Analytical Cookies
Analytical cookies are used to understand how visitors interact with the website. These cookies help provide information on metrics such as the number of visitors, bounce rate, traffic source, etc.
Performance Cookies
Performance cookies are used to understand and analyse the key performance indexes of the website which helps in delivering a better user experience for the visitors
Functional Cookies
Functional cookies are used to recognise you when you return to our website enabling us to personalise our content for you. These cookies help perform certain functionalities like sharing the content of the website on social media platforms, collecting feedback, and other third-party features.
Advertising/Targeting Cookies
These cookies are used to provide visitors with customised advertisements based on the pages you visited previously and to analyse the effectiveness of our advertising campaigns. We will use this information to make our website, and the advertising displayed on it more relevant to your interests. We may also share this information with third parties for this purpose.
The table below explains the cookies we use and why.
| Cookie Used | Purpose |
| Analytics/ Performance | Google Analytics 4 Performance Cookies gathers data on user interactions, helping analyze website traffic and behavior. This data is anonymous and focuses on site performance rather than user targeting. The main cookie used by Google Analytics enables the service to distinguish one visitor from another and lasts for 2 years. |
| Targeted/ Advertising | LinkedIn Insight uses targeting cookies for ad tracking and audience retargeting. These cookies collect data to show targeted LinkedIn ads to users based on site activity. The LinkedIn Insight Tag enables the collection of data regarding members’ visits to our website, including the URL, referrer, IP address, device and browser characteristics (User Agent), and timestamp. The IP addresses are truncated or hashed (when used for reaching members across devices), and members’ direct identifiers are removed within seven days in order to make the data pseudonymous. This remaining pseudonymized data is then deleted within 180 days. LinkedIn don’t share the personal data of members with EKORA; they only provide reports and alerts (which do not identify members) about our website audience and ad performance. Data provided, Job title, company name and industry. Direct identifiers are removed from this data within seven days, and the data is deleted at 180 days. For details on how LinkedIn Insight Tags work, please see LinkedIn https://www.linkedin.com/help/lms/answer/a427660/ |
Cookies can be blocked by activating the setting on your browser that allows you to refuse the setting of all or some cookies. However, if you use your browser settings to block all cookies (including essential cookies) you may not be able to access all or parts of our site. If you have any questions or concerns about our use of Cookies, please send an email to legal@ekora.io.
6. YOUR DATA AND THIRD PARTIES
Sharing your data with third parties
We may also share Personal Data with interested parties in the event that Clinical IT Ltd anticipates a change in control or the acquisition of all or part of our business or assets or with interested parties in connection with the licensing of our technology. If Clinical IT Ltd is sold or makes a sale or transfer, we may, in our sole discretion, transfer, sell or assign your Personal Data to a third party as part of or in connection with that transaction. Upon such transfer, the Privacy Policy of the acquiring entity may govern the further use of your Personal Data. In all other situations your data will still remain protected in accordance with this Privacy Policy (as amended from time to time). We may share your Personal Data at any time if required for legal reasons or in order to enforce our terms or this Privacy Policy.
7. HOW LONG WE RETAIN YOUR DATA
We will only retain your Personal Data for as long as reasonably necessary to fulfil the purposes we collected it for. We may retain your Personal Data for a longer period than usual in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.
8. NOTIFICATION OF CHANGES AND ACCEPTANCE OF POLICY
We keep our Privacy Policy under review and will place any updates here. This version is dated 26 June 2024. By using Clinical IT Ltd, you consent to the collection and use of data by us as set out in this Privacy Policy. Continued access or use of Clinical IT Ltd will constitute your express acceptance of any modifications to this Privacy Policy.
9. INTERPRETATION
All uses of the word “including” mean “including but not limited to” and the enumerated examples are not intended to in any way limit the term which they serve to illustrate. Any email addresses set out in this policy may be used solely for the purpose for which they are stated to be provided, and any unrelated correspondence will be ignored. Unless otherwise required by law, we reserve the right to not respond to emails, even if they relate to a legitimate subject matter for which we have provided an email address. You are more likely to get a reply if your request or question is polite, reasonable and there is no relatively obvious other way to deal with or answer your concern or question (e.g. FAQs, other areas of our website, etc.). Our staff are not authorised to contract on behalf of Clinical IT Ltd, waive rights or make representations (whether contractual or otherwise). If anything contained in an email from a Clinical IT Ltd address contradicts anything in this policy, our terms or any official public announcement on our website, or is inconsistent with or amounts to a waiver of any Clinical IT Ltd rights, the email content will be read down to grant precedence to the latter. The only exception to this is genuine correspondence expressed to be from the Clinical IT Ltd legal department.