Privacy Policy

Introduction

This Privacy Policy sets out the basis on which we will process the personally identifying information (personal data) that we collect and receive in the normal conduct of our business. 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.

Who we are?

Medannex Limited (“Medannex”, “we” or “us”) is the data controller (or joint data controller) in respect of personal data that you submit to us or that we collect from or about you. We are a limited company whose registered office is at 1 Lochrin Square, 92-98 Fountainbridge, Edinburgh EH3 9QA.

If you would like to know what information we hold about you or if you have any other queries or complaints in relation to this Privacy Notice, or our website, our contact details are as follows: Medannex Ltd, 1 Lochrin Square, 92-98 Fountainbridge, Edinburgh EH3 9QA / Tel: 0131 357 4251; email: info@medannex.org (Compliance Officer: jamesingham@medannex.org).

What data do we collect?

Personal data may be provided by you when using this Website subject to your prior consent to the use of cookies (see below). In the course of our business, we may also collect the following information from you:

• name;
• phone number;
• email address;
• postal address; and
• CV for job applicants.

You are responsible for any third-party personal data shared by you with us and you confirm that you have such third party’s consent to provide that personal data to Medannex.

Clinical trials

If you agree to take part in a research study for which Medannex is the data controller (or joint data controller), we will collect the minimum personal data needed for the purposes of the research project. Most information we receive for the purposes of our research studies is pseudonymised or anonymised and therefore does not constitute personal data. Information about you will be used in the ways needed to conduct and analyse the research study. We may keep a copy of the information collected about you. If you would like to find out more about why and how patient data is used in research, please visit the Understanding Patient Data website. If you have any questions regarding how Medannex handles your personal data, please email info@medannex.org.

In relation to any personal data which is used in a research study, when the study has finished, the relevant study team will be informed of the findings and will be encouraged to share a summary on their website and/or newsletters. In addition, the results may be reported on our website (https://medannex.org), on a publicly accessible database (eg.  https://www.clinicaltrials.gov, https://www.isrctn.com/ or https://www.clinicaltrialsregister.eu/ctr-search/search/), in medical journals and presented at scientific conferences. All results published will be anonymised, which means that no personal details will be revealed, and you will not be identifiable from them.

If you are participating in the ATTAINMENT study, the Liverpool Clinical Trials Centre (LCTC) Privacy Notice can be found at https://lctc.org.uk/privacy.

How is your personal data collected?

We use different methods to collect data from and about you including:

• Direct interactions. You may give us your identity and contact data by filling in forms or by corresponding with us by post, phone, email or otherwise.
• Automated technologies or interactions. We have also installed cookies, server logs and other similar technologies on this Website. As you interact with our website, we may automatically collect certain technical data about your equipment, browsing actions and patterns. You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly. Please see the section on cookies below for further details.

• Third parties or publicly available sources. We may receive personal data about you from various third parties and public sources including technical data from (i) analytics such as Google; and (ii) search information providers based inside or outside the EU.

How we use your personal data (Purpose); Lawful basis

We may process personal data if one of the Purposes set out below applies:

• You have given your specific consent for one or more specific purposes. In principle, in the context of our website and business services, we do not process personal data about you based on your consent. However, it may be that in a specific instance we do require your consent. In that case, you will be informed about this separately;
  • The provision of personal data is necessary for the performance of an agreement with the data subject and/or for any pre-contractual obligations thereof. We process some personal data about (contact persons of) our (prospective) clients, based on the performance of a contract with such client;
• The processing is necessary for compliance with a legal obligation to which we are subject. In the context of our website, this legal ground will not likely be applicable. However, under exceptional circumstances it could for example apply if a competent supervisory authority has started an investigation and we are required by law to provide information about you which we obtained via our website;
• The processing is necessary for the purposes of the legitimate interests pursued by Medannex or by a third party. Our legitimate interests are to achieve the aims of our research studies. We only process personal data based on our legitimate interests as far as such processing is necessary to achieve our purposes. Furthermore, we make a balance of interests on a case-by-case basis. Only if the legitimate interests prevail over your privacy interests or other interests or fundamental rights, will we base our processing on this legal ground. You can contact us for more information on the legitimate interests in relation to a specific processing operation.

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.

Data Security

For as long as we maintain records of your personal data, we will keep it up to date and protect it with appropriate security measures. We maintain technical and physical safeguards that are designed to protect the security and integrity of your personal data, and to guard it against accidental or unauthorised access, use, alteration or disclosure to unauthorised third parties. Where we keep personal data files on local devices, these devices are protected and accessible only to our authorised employees. We regularly review our security systems to ensure that your personal data remains safe and secure.

Data Sharing; International Transfers

We shall not sell your information. We shall not share your information with any third party except as required by law. We may share your personal information with technology suppliers both within and outside the European Economic Area (EEA) pursuant to contractual arrangements or regulatory obligations we have with or owe to them. On occasions we may need to share your personal data with regulatory authorities, government agencies and law enforcement agencies. If so, we will use reasonable endeavours to notify you before we do this, unless we are legally restricted from doing so.

The level of information protection in countries outside the EEA may be lower than that offered within the EEA. Where third parties with whom we share your personal information process it outside the EEA, our written agreement with them will include appropriate contractual clauses to ensure that your personal information remains protected and secure in accordance with applicable data protection laws.

Duration of Storage:

Our policy is that we will maintain records of your personal data for as long as (i) we are required for legal and/or regulatory purposes in relation to clinical trials and associated matters, (ii) you remain an employee, intern, contractor, consultant or have any other business relationship with our company and for up to 2 years afterwards, and (iii) legal or tax reasons require us to keep some data for periods longer than 2 years – if so, this will be made clear to you. The CVs of unsuccessful job applicants will be retained for no longer than 1 year after the position has been filled. At the end of these periods (or earlier if requested), our Compliance Officer will ensure that both digital and physical records of personal data are deleted.

Cookies

As you navigate through our website, certain information can be collected passively, without your actively providing the information, using various technologies and means, such as Internet Protocol (IP) addresses, cookies, Internet tags and navigational data collection.

• Web Server Logs/IP Addresses. An IP address is a number assigned to your computer whenever you access the Internet. All computer identification on the Internet is conducted with IP addresses, which allow computers and servers to recognise and communicate with each other. We may collect IP addresses to conduct system administration and report aggregate information to affiliates, business partners and/or vendors to conduct site analysis and performance review.

• Cookies. A cookie is a piece of information that is placed automatically on your computer’s hard drive when you access certain Web sites. The cookie uniquely identifies your browser to the server. Cookies allow us to store information on the server to help make the Web experience better for you and to conduct site analysis and performance review. Most Web browsers are set up to accept cookies, although you can reset your browser to refuse all cookies or to indicate when a cookie is being sent. Note, however, that some portions of our websites may not work properly if you refuse cookies.

• Web Beacons. On certain Web pages or e-mails, we may utilise a common internet technology called a “Web beacon” (also known as an “action tag” or “clear GIF technology”). Web beacons help analyse the effectiveness of websites by measuring, for example, the number of visitors to a site or how many visitors clicked on key elements of a site.

Web beacons, cookies and other tracking technologies do not automatically obtain personally identifiable information about you.

Third Party Links

This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. Medannex does not control these third-party websites and is not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy notice of every website you visit.

Your Rights

Under privacy regulations you have certain rights in relation to your personal data to:

• Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.

• 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.

• 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 continuing to process it. You also have the right to ask us to delete or remove your personal data 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.

• Object to processing of your personal data 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 on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.

• Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) 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; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.

• Request the transfer of your personal data to you or to a third party. We will provide to 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.

• Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.

You also have the right to make a complaint at any time and we would of course welcome the opportunity to deal with any issues first – please contact our Data Compliance Officer: jamesingham@medannex.org.

You are also free to make a complaint directly to the UK Information Commissioner’s Office (https://ico.org.uk).

Changes to our Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our business. All such changes will be posted to our website and if we consider it to be appropriate, we will notify subscribers of any material changes by e-mail.

Latest updated: 4 May 2023