Effective date: 29 Sept 22
Purpose of This Document
PartitionBio Ltd are committed to protecting the privacy and security of your personal information.
This Website Privacy Notice Policy describes how we collect and use personal information about you during and after your working relationship with The Company in accordance with the General Data Protection Regulation (GDRP). This policy applies to any website user of partitionbio.co.uk
Our company, PartitionBio Ltd is a “data controller”. Our nominated representative is the Chief Operations Officer. This means that we are responsible for deciding how we hold and use personal information about you. We are required under data protection legislation to notify you of the information contained in this privacy notice.
This notice applies to our website. We may update this privacy notice at any time without consultation or prior notice. You are not required to sign this privacy notice.
It is important that you read this notice, together with any other privacy notice we may provide on specific occasions when we are collecting or processing personal information about you, so that you are aware of how and why we are using such information. The lists in this notice are not exhaustive.
Purpose of This Document
We will comply with data protection law. This says that the personal information we hold about you must be;
- Used lawfully, fairly and in a transparent way
- Collected only for valid purposes that we have clearly explained to you and not used in a way that is incompatible with those purposes
- Relevant to the purposes we have told you about and limited to those purposes
- Accurate and kept up-to-date
- Kept only as long as necessary for the purposes we have told you about
C/O Lakin Rose Limited Pioneer House, Vision Park, Histon, Cambridge, England, CB24 9NL
Company Registration Number
GB 401 7411 45
The kind of information we hold about you;
- Personal data or personal information 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).
- There are ‘special categories’ of more sensitive personal data which require a higher level of protection
- We will collect, store, transfer, circulate to intended parties and use the following categories of personal information about you;
- Personal contact details such as name, title, addresses, telephone numbers, and personal email (IP) addresses.
IP Addresses and Cookies
We may collect information about your computer, including where available your IP address, operating system and browser type, for system administration and to report aggregate information to our site administrators. This is statistical data about our users browsing actions and patterns and does not identity any individual.
A cookie is a small data text file, which our site places on your computer’s hard drive (if you web browser permits) that can later be retrieved to identify you to us. Cookies were designed to help a web site recognise a user as a previous visitor and thus save and remember any preferences that may have been set while the user was browsing the site.
Cookies help us to improve our site and to deliver a better and more personalised service. They enable us to;
- Store information about your preferences, and so allows us to customise our site according to your individual interests
- Speed up your searches
- Recognise you when you return to our website
Collection of Personal Information
We may also collect, transfer, circulate to intended parties, store and use the personal information in order to improve our services and website.
How we will use Information
We will only use your personal information when the law allows us to. Most commonly, we will use your personal information in the following circumstances;
- Where we need to perform a contract, we have entered into with you
- Where we need to comply with a legal obligation
- Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests
Situations in which we will use your information
We need all the categories of information stated above primarily to allow us to perform our contract with you and to enable us to comply with legal obligations. In some cases, we may use your personal information to pursue legitimate interests of our own or those of third parties, provided your interests and fundamental rights do not override those interests. The situations in which we will process your personal information are listed below.
- To ensure network and information security, including preventing unauthorised access to our computer and electronic communications systems and preventing malicious software distribution
- To conduct data analytics studies to review and better understand website users retention and attrition rates
- Equal opportunities monitoring
- You may be asked to complete surveys that we use for research purposes, although you do not have to respond to them
- If you contact us, we may keep a record of that correspondence. We may ask you for information if you report a problem with our site
- Information that you provide by filling in forms our website including contact information; name, job title, profession, company name, telephone, fax and email addresses
Some of the above grounds for processing will overlap and there may be several grounds which justify our use of your information. By submitting your personal data you agree tio this transfer, storing and processing. We will take all reasonable and necessary steps to ensure your data is treated securely and in accordance with this policy.
Change of Purpose
We will only use your personal information 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 we need to use your personal information 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 information without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
Automated Decision Making (ADM)
Automated Decision Making (ADM) takes place when an electronic system uses personal information to make a decision without human intervention. We are allowed to use ADM in the following circumstances;
- Where we have notified you of the decision and given you 21 days to request a reconsideration
- Where it is necessary to perform the contract with you and appropriate measures are in place to safeguard your rights
- In limited circumstances, with your explicit written consent and where appropriate measures are in place to safeguard your rights.
If we make an automated decision on the basis of any particularly sensitive personal information, we must have either your explicit written consent or it must be justified in the public interest and we must also put in place appropriate measures to safeguard your rights.
You will not be subject to decisions that will have a significant impact on you based solely on automated decision-making, unless we have a lawful basis for doing so and we have notified you.
We do not envisage that any decisions will be taken about you using automated means, however we will notify you in writing if this position changes.
We may have to share your data with third parties, including third-party service providers and other entities in the group;
- We require third parties to respect the security of your data and to treat it in accordance with the law.
- We may transfer your personal information outside the EU including the USA
- If personal data is transferred outside of the EU, The Company will endeavor to protect your personal information in line with GDPR where it is within its control to do so. Other countries may have other regulations and where these exist the company shall comply with these where it is within its control to do so
Sharing Personal Information
We will share your personal information with third parties where required by law, where it is necessary to administer the working relationship with you or where we have another legitimate interest in doing so.
Third Party Service Providers Process and Personal Information
Third Parties includes third party service providers (including contractors and designated agents) and other entities within our group. The following activities are carried out by third party service providers including website developers.
Security and Third-Party Service Providers
All our third-party service providers and other entities in the group are required to take appropriate security measures to protect your personal information in line with our policies.
We do not allow our third-party service providers to use your personal data for their own purposes. We only permit them to process your personal data for specified purposes and in accordance with our instructions.
Sharing Information with Other Entities
We will share your information with other entities in our group as part of our regular reporting activities on company performance, in the context of a business re-organisation or restructuring exercise, for system maintenance, support and hosting of data.
Other Third Parties
We may share your information with other third parties, for example in the context of the possible sale or restructuring of the business… We may also need to share your personal information with a regulator to otherwise comply with the law.
Transferring Information Outside the EEA
It may be necessary to transfer and store the personal information that we collect from you to other group companies or service providers located in a destination outside the European Economic Area (“EEA”). The information may also be processed by staff operating outside the EEA who work for us or for one of our suppliers.
Where viable we shall encrypt or randomize the data. If you require further information about these protective measures, you can request it from the Chief Operations Officer.
We have put in place measures to protect the security of your information. Third parties will only process your personal information on our instructions and where they have agreed to treat the information confidentially and to keep it secure. Unfortunately, the transmission of information via the internet is not always completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our site; any transmission is at your own risk. Once we have received your information, we will use reasonable procedures and security features to try to prevent unauthorised access.
We have put in place appropriate security measures to prevent your personal information from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed.
In addition, we limit access to your personal information to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal information on our instructions, and they are subject to a duty of confidentiality. Details of these measures may be obtained from the Chief Operations Officer.
We have put in place procedures to deal with any suspected data security breach and will notify you and any applicable regulator of a suspected breach where we are legally required to do so.
We will only retain your personal information for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, marketing, 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.
In some circumstances we may anonymise your personal information so that it can no longer be associated with you, in which case we may use such information without further notice to you.
The Company, we will retain and securely destroy your personal information in accordance with applicable laws and regulations.
Under certain circumstances, by law you have the right to;
- Request access to your personal information (commonly known as a data subject access request). This enables you to receive a copy of the personal information we hold about you and to check that we are lawfully processing it
- Request correction of the personal information that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected.
- Request erasure of your personal information. This enables you to ask us to delete or remove personal information 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 information where you have exercised your right to object to processing. This is your ‘opt out right’. You can exercise this right to prevent processing by checking certain boxes on forms we use to collect your data.
- Object to processing of your personal information 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. You also have the right to object where we are processing your personal information for direct marketing purposes
- Request the restriction of processing of your personal information. This enables you to ask us to suspend the processing of personal information about you, for example if you want us to establish its accuracy or the reason for processing it
- Request the transfer of your personal information to another party
If you want to review, verify, correct or request erasure of your personal information, object to the processing of your personal data, or request that we transfer a copy of your personal information to another party, please contact the Chief Operations Officer in writing.
Our site may, from time to time, contain links from other partner networks, associations or affiliates. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for those policies. Please check those polcies before you submit any information.
No Fee Required
You will not have to pay a fee to access your personal information (or to exercise any of the other rights). However, we may charge a reasonable fee if your request for access is clearly unfounded or excessive. Alternatively, we may refuse to comply with the request in such circumstances.
We may need to request specific information from you to help us confirm your identity and ensure your right to access the information (or to exercise any of your other rights). This is another appropriate security measure to ensure that personal information is not disclosed to any person who has no right to receive it.
Right to Withdraw Consent
In circumstances where you may have provided your consent to the collection, processing and transfer of your personal information, you have the right to withdraw your consent for that specific processing at any time. To withdraw your consent, please contact the Chief Operations Officer. Once we have received notification that you have withdrawn your consent, we will no longer process your information for the purpose or purposes you originally agreed to, unless we have another legitimate basis for doing so in law.
Data Protection Officer
The Chief Operations Officer acts as the data protection officer (DPO) to oversee compliance with this privacy notice. If you have any questions about this privacy notice or how we handle your personal information, please contact the DPO.
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.
Changes to this Privacy Notice
We reserve the right to update this privacy notice at any time, without prior consultation or notice and we will provide you with a new privacy notice when we make any substantial updates. We may also notify you in other ways from time to time about the processing of your personal information.
If you have any questions about this privacy notice, please contact the Chief Operations Officer.