Privacy Policy

Overview

The pages on the Creo Pioneers Community website and the Connected Community app are published by Higher Logic, LLC ("Higher Logic"), a Delaware limited liability company, on behalf of Creo Medical Limited, a company registered in England and Wales with a company registration number 04658880, whose registered address is at Creo House, Unit 2, Beaufort Park Way, Chepstow, Gwent, NP16 5UH ("Creo Medical") (collectively referred to as "we", "us" or "our"). All references in this policy to the "website" refer to the Creo Pioneers Community website owned www.creopioneers.com and all references in this policy to the "app" refer to the Connected Community app (collectively referred to as the "Platform").

We value your privacy and want to be accountable and fair to you as well as transparent with you in the way that we collect and use your personal information. We also want you to know your legal rights in relation to your information.

In line with these values, this privacy policy tells you what to expect when we collect and use personal information about you.

This policy applies to users of the Platform.

The policy sets out the following topics in relation to your information:

How we obtain your personal information
How we collect and use your personal information
Legal basis for use of your personal information
Disclosures of your personal information
International transfers
Data security
Data retention
Your legal rights
Children
Marketing
Links to other websites
Changes to our privacy policy
Further questions and how to make a complaint

Please read this privacy policy carefully to understand how we handle your personal information. By engaging with us in the ways set out in this privacy policy, you confirm that you have read and understood the entirety of this privacy policy, as it applies to you.

How we obtain your personal information
1. You may provide us with your personal information voluntarily. We may also receive information about you from third parties such as marketing agencies, market research companies, our suppliers, contractors and consultants, group companies, public websites and public agencies, which we refer to as "third party sources" or "suppliers" throughout this policy.
2. You may give us personal information about yourself by using the online forms provided on our website, setting up an account with us, using forums on the Platform, or by contacting us by phone, email or other means.
How we collect and use your personal information
We will only collect, use, store and transfer personal information about you that we need, in accordance with this policy.
1. We, or third parties on our behalf, may collect and use any of the following information about you:
  1. your name including your title;
  2. your postal address;
  3. your email address;
  4. your age;
  5. your gender;
  6. your medical qualification;
  7. your professional registration number;
  8. the name of the clinic you practice at;
  9. your telephone number;
  10. information provided when you correspond with us;
  11. any updates to information provided to us;
  12. personal information we collect about you or that we obtain from our third party sources; and
  13. the technical information created and recorded automatically when you visit the Platform, including your Internet Protocol (IP) address, the country from which you access information, browser type and version, browser plug-in types and versions, operating system and platform. We use this personal information to administer the Platform, to measure the efficiency of our systems and to undertake an analysis on the locations from which people access our webpages.
2. We will collect, use and store the personal information listed above for the following reasons:
  1. to allow you to access and use the Platform;
  2. to receive enquiries from you through the Platform;
  3. for improvement and maintenance of the Platform and to provide technical support for the Platform;
  4. to ensure the security of the Platform;
  5. to recognise you when you return to the Platform, to store information about your preferences, and to allow us to customise the Platform according to your individual interests; and
  6. to evaluate your visit to the Platform and prepare reports or compile statistics to understand the type of people who use the Platform, how they use the Platform and to make the Platform more intuitive. Such details will be anonymised as far as reasonably possible and you will not be identifiable from the information collected.
3. A word about cookies
  1. Some pages on the Platform use cookies, which are small files placed on your internet browser when you visit the Platform. Creo Medical and Higher Logic use cookies in order to offer you a more tailored experience in the future, by understanding and remembering your particular browsing preferences.
  2. Where we use cookies on the Platform, you may block these at any time. To do so, you can activate 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 the Platform or to use all the functionality provided through the Platform.
  3. For detailed information on the cookies we use and the purposes for which we use them, please refer to our Cookies Settings.
4. Special categories of data. Some of the personal information that we collect about you or which you provide to us about you may be special categories of data. Special categories of data include information about physical and mental health, sexual orientation, racial or ethnic origin, and biometric data.
5. Information we need to provide services to you. We need certain types of personal information so that we can provide services to you and perform contractual and other legal obligations that we have to you.
6. We may also collect, use and store your personal information for the following additional reasons:
  1. to deal with any enquiries or issues you have about how we collect, store and use your personal information, or any requests made by you for a copy of the information we hold about you. If we do not have a contract with you, we may process your personal information for these purposes where it is in our legitimate interests for customer services purposes;
  2. for internal corporate reporting, business administration, ensuring adequate insurance coverage for our business, ensuring the security of company facilities, research and development, and to identify and implement business efficiencies. We may process your personal information for these purposes where it is in our legitimate interests to do so;
  3. to comply with any procedures, laws and regulations which apply to us – this may include where we reasonably consider it is in our legitimate interests or the legitimate interests of others to comply, as well as where we are legally required to do so;
  4. to make suggestions or recommendations to you about products or services which may be of interest to you. We may process your personal information for these purposes where it is in our legitimate interests to do so, in accordance with section 10 of this policy; and
  5. to establish, exercise or defend our legal rights – this may include where we reasonably consider it is in our legitimate interests or the legitimate interests of others, as well as where we are legally required to do so.
7. Further processing
  Before using your personal information for any purposes which fall outside those set out above, we will undertake an analysis to establish if our new use of your personal information is compatible with the purposes set out above.
Legal basis for use of your personal information
1. We consider that the legal bases for using your personal information as set out in this privacy policy are as follows:
  1. our use of your personal information is necessary to perform our obligations under any contract with you (for example, to comply with the acceptable use policy of the Platform which you accept by browsing the Platform); or
  2. our use of your personal information is necessary for complying with our legal obligations; or
  3. our use of your personal information is necessary for our legitimate interests or the legitimate interests of others (for example, to ensure the security of the Platform). Our legitimate interests are to:
    1. run, grow and develop our business;
    2. operate the Platform;
    3. carry out marketing, market research and business development;
    4. product safety and recall information; and
    5. for internal group administrative purposes.
2. If we rely on our (or a third party's) legitimate interests for using your personal information, we will undertake a balancing test to ensure that our (or the third party's) legitimate interests are not outweighed by your interests or fundamental rights and freedoms which require protection of the personal information.
3. We may use your special categories of data (such as health and wellbeing information) where you have provided your consent (which you may withdraw at any time after giving it, as described below).
4. We may process your personal information in some cases for marketing purposes on the basis of your consent (which you may withdraw at any time after giving it, as described below).
5. If we rely on your consent for us to use your personal information in a particular way, but you later change your mind, you may withdraw your consent by contacting us via email at data@creomedical.com and we will stop doing so. However, if you withdraw your consent, this may impact the ability for us to be able to provide services to you.
Disclosures of your personal information
1. We may share your personal information with our group companies where it is in our legitimate interests to do so for internal administrative purposes (for example, for corporate strategy, compliance, auditing and monitoring, research and development and quality assurance).
2. Creo Medical may share your personal information with the following third parties:
  - Monday.com
  - Hubspot.com
  - Higher Logic LLC
  - Apple Appstore / Google Play
3. Any third parties with whom we share your personal information are limited (by law and by contract) in their ability to use your personal information for any purpose other than to provide services for us. We will always ensure that any third parties with whom we share your personal information are subject to privacy and security obligations consistent with this privacy policy and applicable laws.
4. We will also disclose your personal information to third parties:
  1. where it is in our legitimate interests to do so to run, grow and develop our business;
  2. if we sell or buy any business or assets, we may disclose your personal information to the prospective seller or buyer of such business or assets;
  3. if substantially all of our or any of our affiliates' assets are acquired by a third party, in which case personal information held by us will be one of the transferred assets;
  4. if we are under a duty to disclose or share your personal information in order to comply with any legal obligation, any lawful request from government or law enforcement officials and as may be required to meet national security or law enforcement requirements or prevent illegal activity;
  5. in order to enforce or apply our acceptable use policy, our terms and conditions for customers or any other agreement or to respond to any claims, to protect our rights or the rights of a third party, to protect the safety of any person or to prevent any illegal activity.
5. We may also disclose and use anonymised, aggregated reporting and statistics about users of the Platform or our products and services for the purpose of internal reporting or reporting to our group or other third parties, and for our marketing and promotion purposes. None of these anonymised, aggregated reports or statistics will enable our users to be personally identified.
6. Save as expressly detailed above, we will never share, sell or rent any of your personal information to any third party without notifying you and, where necessary, obtaining your consent. If you have given your consent for us to use your personal information in a particular way, but later change your mind, you should contact us via email at data@creomedical.com and we will stop doing so.
International transfers
1. Your personal information may be used, stored and/or accessed by staff operating outside the UK or the EEA working for us, other members of our group or suppliers.
2. If we provide any personal information about you to any such non-UK and non-EEA members of our group or suppliers, we will take appropriate measures to ensure that the recipient protects your personal information adequately in accordance with this privacy policy. These measures may include the following:
  1. ensuring that there is an adequacy decision by the UK Government in the case of transfers out of the UK, or by the European Commission in the case of transfers out of the EEA, which means that the recipient country is deemed to provide adequate protection for such personal information;
  2. where the transfer of personal information is to a member of our group, and we have in place binding corporate rules with such member which safeguard the personal information and which have been validated by the ICO or the relevant supervisory authority; or
  3. where we have in place standard model contractual arrangements with the recipient which have been approved by the European Commission (or the UK Government for transfers out of the UK in due course). These model contractual clauses include certain safeguards to protect the personal information;
3. Further details on the steps we take to protect your personal information, in these cases is available from us on request by contacting us via email at data@creomedical.com at any time.
Data security
1. The main risk of our processing of your personal information is if it is lost, stolen or misused. This could lead to your personal information being in the hands of someone else who may use it fraudulently or make public, information that you would prefer to keep private.
2. For this reason, we are committed to protecting your personal information from loss, theft and misuse. We take all reasonable precautions to safeguard the confidentiality of your personal information, including through use of appropriate organisational and technical measures.
3. In the course of provision of your personal information to us, your personal information may be transferred over the internet. Although we make every effort to protect the personal information which you provide to us, the transmission of information over the internet is not completely secure. As such, you acknowledge and accept that we cannot guarantee the security of your personal information transmitted to the Platform and that any such transmission is at your own risk. Once we have received your personal information, we will use strict procedures and security features to prevent unauthorised access to it.
4. Where we have given you (or where you have chosen) a password which enables you to access your online account, you are responsible for keeping this password confidential. You must not share your user account log-in details with any third party to enable them to access the Platform.
Data retention
We keep your personal information for no longer than necessary for the purposes for which the personal information is processed. The length of time for which we retain personal information depends on the purposes for which we collect and use it and/or as required to comply with applicable laws and to establish, exercise or defend our legal rights.
Your legal rights
1. You have the following rights:
  1. Right of access. You have a right of access to any personal information we hold about you. You can ask us for a copy of your personal information; confirmation as to whether your personal information is being used by us; details about how and why it is being used; and details of the safeguards which are in place if we transfer your information outside of the United Kingdom or the European Economic Area ("EEA").
  2. Right to update your information. You have a right to request an update to any of your personal information which is out of date or incorrect.
  3. Right to delete your information. You have a right to ask us to delete any personal information which we are holding about you in certain specific circumstances. We will pass your request onto other recipients of your personal information unless that is impossible or involves disproportionate effort.
  4. Right to restrict use of your information. You have a right to ask us to restrict the way that we process your personal information in certain specific circumstances. We will pass your request onto other recipients of your personal information unless that is impossible or involves disproportionate effort.
  5. Right to stop marketing. You have a right to ask us to stop using your personal information for direct marketing purposes. If you exercise this right, we will stop using your personal information for this purpose.
  6. Right to data portability. You have a right to ask us to provide your personal information to a third party provider of services. This right only applies where we use your personal information on the basis of your consent or performance of a contract; and where our use of your information is carried out by automated means.
  7. Right to object. You have a right to ask us to consider any valid objections which you have to our use of your personal information where we process your personal information on the basis of our or another person's legitimate interest.
2. We will consider all such requests and provide our response within a reasonable period (and in any event within one month of your request unless we tell you we are entitled to a longer period under applicable law). Please note, however, that certain personal information may be exempt from such requests in certain circumstances, for example if we need to keep using the information to comply with our own legal obligations or to establish, exercise or defend legal claims.
3. If an exception applies, we will tell you this when responding to your request. We may request you provide us with information necessary to confirm your identity before responding to any request you make.
4. If you would like further information in relation to these or would like to exercise any of them, please contact us via email at data@creomedical.com at any time.
Children
1. You must be aged 18 or over to access services from us. The Platform and services are not directed at children and we do not knowingly collect any personal information from children.
2. If you are a child and we learn that we have inadvertently obtained personal information from you from our websites, or from any other source, then we will delete that information as soon as possible.
3. Please contact us via email at data@creomedical.com if you are aware that we may have inadvertently collected personal information from a child.
Marketing
1. We may collect and use your personal information for undertaking marketing by email, telephone and post.
2. We may send you certain marketing communications (including electronic marketing communications) if it is in our legitimate interests to do so for marketing and business development purposes or, if you are a sole trader or a non-limited liability partnership if you have consented to receive such electronic marketing information.
3. However, we will always obtain your consent to direct marketing communications where we are required to do so by law and if we intend to disclose your personal information to any third party for such marketing.
4. We shall ensure that any marketing communications that we or any third party send to you comply with the Human Medicines Regulations, the Business Protection from Misleading Marketing Regulations, the Medicines and Medical Devices Act and the Health Insurance Portability and Accountability Act (HIPAA), or any similar other applicable laws or regulations in your country.
5. If you wish to stop receiving marketing communications, you can contact us via email at data@creomedical.com.
Links to other websites
The Platform may contain hyperlinks to websites that are not operated by us, including third party hyperlinks to websites shared by other users of the Creo Pioneers website. These hyperlinks are provided for your reference and convenience only and do not imply any endorsement of the activities of such third party websites or any association with their operators. This privacy policy only applies to the personal information that we collect or which we receive from third party sources, and we cannot be responsible for personal information about you that is collected and stored by third parties. Third party websites have their own terms and conditions and privacy policies, and you should read these carefully before you submit any personal information to these websites. We do not endorse or otherwise accept any responsibility or liability for the content of such third party websites or third party terms and conditions or policies.
Changes to our privacy policy
We may update our privacy policy from time to time. Any changes we make to our privacy policy in the future will be posted on this page and, where appropriate, notified to you by post or email. Please check back frequently to see any updates or changes to our privacy policy.
Further questions and how to make a complaint
1. If you have any queries or complaints about our collection, use or storage of your personal information, or if you wish to exercise any of your rights in relation to your personal information, please contact via email at data@creomedical.com. We will investigate and attempt to resolve any such complaint or dispute regarding the use or disclosure of your personal information.
2. You may also make a complaint to the Information Commissioner's Office, or the data protection regulator in the country where you usually live or work, or where an alleged infringement of applicable data protection laws has taken place. Alternatively, you may seek a remedy through the courts if you believe your rights have been breached.
3. The practices described in this privacy policy statement are current as of July 7th, 2022.