Privacy Policy | L&R Medical UK

L&R Medical UK Ltd is the controller and responsible for your personal data (collectively referred to as "L&R", "we", "us" or "our" in this privacy policy).

This privacy policy sets out how L&R uses and protects information that you give, when using our website, webshop, webchat, mobile apps, Facebook, Twitter, Instagram, Linkedin, YouTube or attend an event. L&R complies with its obligations under the GDPR by keeping personal data up to date; by storing and destroying it securely; by not collecting or retaining excessive amounts of data; by protecting personal data from loss, misuse, unauthorised access and disclosure and by ensuring that appropriate technical measures are in place to protect personal data.

It is important that you read this privacy policy together with any other privacy policy, or fair processing policy 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 policy supplements other notices and privacy policies and is not intended to override them.

We have appointed a data privacy manager who is responsible for overseeing questions in relation to this privacy policy. If you have any questions about this privacy policy, including any requests to exercise your legal rights, please contact the data privacy manager using the details set out below.

Full name of legal entity: L&R Medical UK Ltd
Postal address: 1 Wellington Court, Lancaster Park, Needwood, Burton upon Trent, Staffordshire DE13 9PS
Telephone: 08450 606 707 / +44 (0)1283 576800
Email address: customersolutions@uk.LRMed.com

You have the right to make a complaint at any time to the Information Commissioner's Office (ICO), the UK regulator for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.

Links to other websites

Our website may contain links to other websites of interest. However, once you have used these links to leave our site, you should note that we do not have any control over that other website. Therefore, we cannot be responsible for the protection and privacy of any information which you provide whilst visiting such sites and such sites are not governed by this privacy policy. You should exercise caution and look at the privacy policy applicable to the website in question.

The data we collect 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). We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:

Identity Data: first name, maiden name, last name, username or similar identifier, marital status, title, gender, date of birth, job role.
Contact Data: billing address, delivery address, work address (HCP’s), email address and telephone numbers.
Financial Data: bank account and payment card details.
Transaction Data: details about payments to and from you and other details of products you have purchased from us.
Technical Data: internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access this website.
Profile Data: your username and password, purchases or orders made by you, your interests, preferences, feedback and survey responses, compression and product use.
Usage Data: information about how you use our website, products.
Marketing and Communications Data: your preferences in receiving marketing from us and our third parties and your communication preferences.

We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy policy.

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.

Where we need to collect personal data by law, or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with goods). In this case, we may have to cancel a product you have with us but we will notify you if this is the case at the time.

How is your personal data collected?

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

Direct interactions. You may give us your Identity, Contact and Financial Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:

purchase our products
create an account on our website
subscribe to our newsletter
request marketing to be sent to you
enter a competition, promotion or survey
give us feedback or contact us

Automated technologies or interactions. As you interact with our website, we will automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies and other similar technologies. Please see our cookie policy for further details.
Third parties. We will receive personal data about you from various third parties as set out below:

Technical Data from analytics providers such as Google based outside the UK;
Contact, Financial and Transaction Data from providers of technical, payment and delivery services such as Barclays based [inside OR outside] the UK.

What we do with the information we collect

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data for the following purposes:

Where we need to perform the contract we are about to enter into or have entered into with you.
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. This would include the interest of our business in conducting and managing our business to enable us to give you the best service / product and the best and most secure experience.
Where we need to comply with a legal obligation.

Generally, we do not rely on consent as a legal basis for processing your personal data although we will get your consent before sending third party direct marketing communications to you via email or text message.

Purposes for which we will use your personal data

We have set out below a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate. Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data.

Purpose / Activity	Purpose / Activity	Activity Lawful basis for processing including basis of legitimate interest
To register you as a new customer	a) Identity b) Contact	Performance of a contract with you
To process and deliver your order including: a) Manage payments/fees/charges b) Collect and recover money owed to us c) Contacting you to arrange meetings and training on our products	a) Identity b) Contact c) Financial d) Transaction e) Marketing & Communications	a) Performance of a contract with you b) Necessary for our legitimate interests (to recover debts due to us)
To manage our relationship with you which will include: a) Notifying you about changes to our terms or privacy policy b) Asking you to leave a review or take a survey	a) Identity b) Contact c) Profile d) Marketing & Communications	a) Performance of a contract with you b) Necessary to comply with a legal obligation c) Necessary for our legitimate interests (to keep our records updated and to study how customers use our products
To send promotional emails/newsletters about our products	a) Identity b) Contact c) Profile d) Usage e) Marketing & Communications	a) Performance of a contract with you b) Necessary for our legitimate interests (to study how customers use our products, to develop them and grow our business)
To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)	a) Identity b) Contact c) Technical	a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise) b) Necessary to comply with a legal obligation
To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you	a) Identity b) Contact c) Profile d) Usage e) Marketing & Communications f) Technical	Necessary for our legitimate interests (to study how customers use our products, to develop them, to grow our business and to inform our marketing strategy)
To use data analytics to improve our website, products, marketing, customer relationships and experiences	a) Technical b) Usage	Necessary for our legitimate interests (to define types of customers for our products, to keep our website updated and relevant, to develop our business and to inform our marketing strategy)
To make suggestions and recommendations to you about goods that may be of interest to you	a) Identity b) Contact c) Technical d) Usage e) Profile f) Marketing & Communications	Necessary for our legitimate interests (to develop our products and grow our business)

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 using one of the methods listed above.

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.

How we use cookies

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. For more information about the cookies we use, please see our cookie policy.

Marketing

We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising.

We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products and offers may be relevant for you (we call this marketing).

You will receive marketing communications from us if you have requested information from us or purchased goods from us and you have not opted out of receiving that marketing.

Third-party marketing

We will get your express opt-in consent before we share your personal data with any third party for marketing purposes.

Opting out

You can opt out of marketing communications at any time by logging into the website and checking or unchecking relevant boxes to adjust your marketing preferences or by following the opt-out links on any marketing message sent to you.

You can update your details or opt-out of our emails at any time using the ‘Unsubscribe’ links found at the bottom of every email we send via Connectiv or Redeye. If you unsubscribe Connectiv or Redeye will retain your email address for the purposes of a suppression list to ensure that no further marketing messages can be sent unless you actively choose to opt-in again.

Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a purchase, product / service experience or other transactions.

Third Party Data Processors

Like most businesses, we rely on third-party providers to support our day-to-day operations, for example in areas such as email delivery, web chat and website analytics. We may also hire third parties to operate, maintain or improve our website and other digital services. Some of these service providers will by necessity have access to or be directly involved in processing or storing personal information you share with us. All our third-party data providers have been carefully chosen as service suppliers who also practice responsible data handling. We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

Internal Third Parties such as other companies in the Group acting as joint controllers or processors and who are based in Germany and provide IT and system administration services and undertake leadership reporting.
External Third Parties such as:

Service providers acting as processors based in the UK who provide IT and system administration services.
Professional advisers acting as processors or joint controllers including lawyers, bankers, auditors and insurers based in the United Kingdom who provide consultancy, banking, legal, insurance and accounting services.
HM Revenue & Customs, regulators and other authorities acting as processors or joint controllers based in the United Kingdom who require reporting of processing activities in certain circumstances.
Web analytics providers acting as processors based in the United States who provide web analysis.
Email distributors acting as processors based in the United States who distribute newsletters.
Event registration platform acting as processors based in the United States who manage events and ticketing.
Online survey tool acting as processors based in the United States who distribute and collate surveys.
Web chat service acting as processors based in the United States who support customer interaction.

Third parties to whom we may choose to sell, transfer or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy policy.

Data security

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

We will never contact you via SMS or email requesting that you confirm or amend your personal (such as bank/payment details or passwords).

How long we keep your data for

L&R retains your personal data for no longer than necessary for the purpose it was obtained. L&R ensures personal data is securely disposed of when no longer needed to reduce the risk that it will become inaccurate, out of date or irrelevant.

The following criteria are used to determine data retention periods for your personal data:

Retention in case of queries: L&R will retain your personal data as long as necessary to deal with your queries.
Retention for legitimate interests: L&R will retain your personal data as long as necessary for our legitimate interests.
Retention of consent: L&R will retain your personal data until you unsubscribe or we receive notification of a change of profession or an email delivery failure.
Retention in the event of a complaint: L&R will retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.
Retention in compliance with the law: By law L&R will retain basic information about our customers (including Contact, Identity, Financial and Transaction Data) for six years after they cease being customers for tax purposes.

In some circumstances we will anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.

Controlling your personal information

You have the following rights with respect to your personal data:

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:

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.

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.

No fee usually required: You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances.

What we may need from you: We may need to request specific information from you to help us confirm your identity and ensure your 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.

Time limit to respond: We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

Changes to the privacy policy and your duty to inform us of changes

We keep our privacy policy under regular review. This version was last updated on 25 January 2021. Historic versions can be obtained by contacting us via one of the methods above.

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.