Cupris Website Privacy Policy

This policy and any dispute or claim arising out of or in connection with it or its subject matter (including non-contractual disputes or claims) shall be governed by and construed in accordance with English law. In the event there is a discrepancy between this English language version and any translated copies of the Privacy Policy, the English version shall prevail.

This privacy notice tells you about the information we collect from you when you use our website. In collecting this information, we are acting as a data controller and, by law, we are required to provide you with information about us, about why and how we use your data, and about the rights you have over your data.

We have tried to write this Privacy Policy in a way that is clear, simple and free of legal language. However, if you still have questions about anything in our Privacy Policy, just contact us at dataprotection@cupris.com

When you access or use our Service you agree to our Privacy Policy and you consent to our collection, storage, use and disclosure of your personal information in the way that we have set out in this Privacy Policy.

IF YOU DO NOT ACCEPT AND AGREE WITH OUR PRIVACY POLICY THEN YOU MUST NOT ACCESS OR USE THE SERVICE.

Who are we?

We are Cupris Ltd. Our address is The Busworks, United House, North Road, London N7 9DP. You can contact us by post at the above address, by email at dataprotection@cupris.com.

We are not required to have a data protection officer, so any enquiries about our use of your personal data should be addressed to the contact details above.

How we use your information:

When you use our website

Like most other websites, we use cookies to distinguish you from other users of the Service and to improve your overall experience. When you use the Service, certain information may be stored locally on your device using 'cookies' or similar technologies such as objects stored in the device’s local storage. A cookie is a small text file used to store limited information about the user of the device. They help us to identify how our users use the Service, and so that we can continue to develop and improve it.

Cookies do this by storing information about your preferences on your device, including the device model, manufacturer, screen resolution, device capabilities, service provider, country and city location data.

We use certain cookies, which we have set out below:

Cookies which are strictly necessary and enable the Service to function correctly and deliver content. These cookies do not gather information about users that could be used for marketing or remembering sites that users have visited on the internet.

Cookies which ensure Performance & Functionality and understand user preferences.

Cookies which are Analytical in nature and help us to analyse how the Service is used, in particular we use Google analytics cookies. The cookies collect information in an anonymous form, including the number of visitors to the site, where visitors have come to the site from and the pages they visited.

For more information about Google’s privacy policy, please visit http://www.google.com/intl/en/policies/. If you do not wish to allow the use of Google Analytics cookies at all, Google provides an opt-out plug-in for most common website browsers http://tools.google.com/dlpage/gaoptout.

For more information about what cookies are and your rights to control cookies, please don’t hesitate to visit this great third party educational resource www.allaboutcookies.org.

 

Using & Sharing your information

We collect your information because it helps us better understand what you need from us and our Service. The main uses of your personal information are to register you in order for you to use the Service, to enable you to use the content and make purchases, to enable us to process any sales transaction and to provide you with updates about the Service.

Sometimes, we may use your personal information to contact you with newsletters, marketing or promotional materials and other information that may be of interest to you. We will ask your consent to do this. You may opt out of receiving any, or all, of these communications from us by following the unsubscribe link or instructions provided in any email we send.

Using your health information

As set out in our Terms of Sale.

We retain health records in line with the NHS Records Management Code of Practice for Health and Social Care 2016  which can be downloaded here. In summary, standard adult health records are kept for 8 years after discharge or when patient last seen.

Sharing your information

We aim to provide you with choices regarding the information you provide to us. There may be some circumstances in which we disclose your personal information:

We will let you share information with others (e.g. a photo of yourself). Where you upload information such as a profile photo this will be viewable by all other users of the Service.

Information you share with medical professionals

Where you upload information about your health this will be viewable only by other users of the Service that you have permitted to access it, or to be granted access to it by such users. In all other circumstances information about your health is not publically available and will be kept secure and confidential.

By default, when you send information about your health to medical professionals, they are (subject to their own professional obligations relating to patient confidentiality) able to forward that information to their colleagues in order to seek their professional input (such as a second opinion, or the input of a specialist expert). However, if you do not want medical professionals to do this you can change your privacy settings so that medical professionals must ask for your permission each time they wish to forward your information.

Circumstances in which we will disclose personal information

We may disclose your personal information to third parties in the following circumstances: (a) as required as a matter of law; (b) in the reasonable enforcement of our rights; (c) to identify or resolve technical problems arising from the use of the Service; (d) to deal with complaints from any party regarding the operation of the Service; (e) as otherwise set out in this Privacy Policy; (f) where we have your permission; or (g) where the business is sold to a third party.

 

Protecting your information

Where do we keep your personal information?

Our Service is hosted with a third party provider that complies with the EU GDPR. They provide us with the online e-commerce platform that allows us to provide our products and services to you.

How do we protect your personal information?

We endeavour to look after your data in the best way we can, but sometimes this means that your data may need to be moved outside of the European Economic Area (“EEA”). By submitting your personal data, you agree to this transfer, storing or processing. We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this Privacy Policy.

Please note that where we provide you (or where you have chosen) a password which enables you to access certain parts of the Service, you are responsible for keeping this password confidential. Please do not share a password with anyone. When we transmit confidential information, (such as a username and/or password) over the internet, we protect it through the use of encryption, such as the Secure Socket Layer (“SSL”) and AES-256.

Unfortunately, the transmission of information via the internet is not completely secure. Whilst, we follow and implement generally accepted industry standards, we cannot guarantee the security of your data transmitted to the Service; any transmission is at your own risk.

How can you help to keep your information secure?

You may not disclose your password to any third parties or share it with any third parties. If you lose your password or give it out, your personal information may be compromised. If that happens, please report it to Support at support@cupris.com. You must change your password immediately via your “Settings” page. We cannot be held responsible for your failure to keep your password secure and failure to do so may violate our Terms of Sale.

 

When you submit an enquiry via our website

When you submit an enquiry via our website, we ask you for your name, contact telephone number and email address.

We use this information to respond to your query, including providing you with any requested information about our products and services. We may also email you several times after your enquiry in order to follow up on your interest and ensure that we have answered it to your satisfaction. We will do this based on our legitimate interest in providing accurate information prior to a sale.

Your enquiry is stored and processed as an email which is hosted by Google with whom we have reviewed and accepted EU Model Contract Clauses and a Data Processing Amendment for G Suite to comply with the GDPR. Information about Google Data Centers can be found here. It is also logged on a CRM system on a cloud server with whom we also have a Data Processing Agreement in place, which can be viewed here.

We do not use the information you provide to make any automated decisions that might affect you.

We keep enquiry emails for two years, after which they are securely archived and kept for five years, when we delete them. CRM records are kept for five years after the last contact with you.

 

When you purchase a product from our website

When you purchase products from us online, we ask you for your name, address, contact telephone number, email address and credit card information. We also record your IP (Internet Protocol) address, which is the address of your computer on the Internet.

We will use your information to verify your credit card details for your purchase, process your order and to send you your products. We will also send you a receipt via email and we may use your telephone number to contact you regarding your purchase.

We require this information in order to process your payment, deliver your products or services and fulfil our contract with you. We record your IP address in order to show that the correct tax was applied to the sale, which we are required to do by law.

Your information is stored on our website and on our cloud server, with companies that comply with the EU GDPR. Your credit card details are passed to a third-party payment processor which is based in the USA and is certified to the EU-US Privacy Shield (which requires effective safeguards for your information). We do not retain your credit card information.

We do not use the information you provide to make any automated decisions that might affect you.

We keep your order information for an indefinite period, as the licenses we sell for our products do not expire.

 

When you sign up to receive our newsletter

When you sign up to receive our newsletter, we ask for your name and your email address.

We will ask for your consent to use your name and email address to email you our newsletter which contains information about our products and other information which we feel might be of interest to you.

You can withdraw your consent at any time and we will stop sending you the newsletter.

Your name and email address are shared with a third party mailing system which is based in the United States. This company has contractually committed to providing appropriate safeguards for your personal data which means it will be protected in line with the legal requirements of the European Union.

We do not use the information you provide to make any automated decisions that might affect you.

We keep your personal data for as long as we produce and distribute our newsletter. If you withdraw your consent, we will mark your details so that they are not used and delete them after two years.

 

When you submit a review about us

When you submit a review about us we record your name, your email address and your IP (Internet Protocol) address, which is the address of your computer on the Internet.

We use this information to provide verified independent views about our products and services to potential customers. Your name and the content of your review (but not your email address or IP address) may be publicly displayed on our website. We will do this based on our legitimate interest in marketing our products and services.

Your details are shared with a third party reviews system which is based within the European Economic Area (EEA).

We do not use the information you provide to make any automated decisions that might affect you.

Your personal data is stored for as long as we are marketing the product or services that the review refers to, after which it is deleted. You may ask us to remove your review at any time.

 

When you take part in our feedback survey

When you take part in our feedback survey, we record your name, your email address, your organisation name, your job role and your answers to questions we ask about your opinion of, and use of, our products and services.

We use this information to develop and improve our products and services and our customer relationships. Your job role, organisation and some or all of your comments may be publicly displayed on our website as a testimonial. We will do this based on our legitimate interest in marketing our products and services.

Your details are shared with a third party surveys system which is based within the European Economic Area (EEA).

We do not use the information you provide to make any automated decisions that might affect you.

Your personal data is stored for two years, or for as long as we are marketing the product or services that the review refers to, whichever is shorter. You may ask us to remove a testimonial that is based on your feedback from our website at any time.

 

Your rights as a data subject

By law, you can ask us what information we hold about you, and you can ask us to correct it if it is inaccurate. If we have asked for your consent to process your personal data, you may withdraw that consent at any time.

If we are processing your personal data for reasons of consent or to fulfil a contract, you can ask us to give you a copy of the information in a machine-readable format so that you can transfer it to another provider.

If we are processing your personal data for reasons of consent or legitimate interest, you can request that your data be erased.

You have the right to ask us to stop using your information for a period of time if you believe we are not doing so lawfully.

Finally, in some circumstances you can ask us not to reach decisions affecting you using automated processing or profiling.

To submit a request regarding your personal data by email, post or telephone, please use the contact information provided above in the Who Are We section of this policy.

 

Your right to complain

If you have a complaint about our use of your information, we would prefer you to contact us directly in the first instance so that we can address your complaint at dataprotection@cupris.com. However, you can also contact the Information Commissioner’s Office via their website at www.ico.org.uk/concerns or write to them at:

Information Commissioner's Office
Wycliffe House
Water Lane
Wilmslow
Cheshire
SK9 5AF

 

Updates to this privacy policy

We regularly review and, if appropriate, update this privacy policy from time to time, and as our services and use of personal data evolves. If we want to make use of your personal data in a way that we haven’t previously identified, we will contact you to provide information about this and, if necessary, to ask for your consent.

We will update the version number and date of this document each time it is changed.

v2.0

23/05/2018