Edition Date April 8, 2020
This is the Cleveland Clinic London Ltd Privacy Notice. It describes the types of personal data that we collect, how we collect and process that information, who we share such information with, and your options in connection with your information.
1. Important information and who we are
Purpose of this Privacy Notice
This Privacy Notice aims to give you information on how Cleveland Clinic London Ltd collects and processes your personal data through your use of the website or mobile application associated with this Privacy Notice (each a “Site” and collectively, the “Sites”), including any data you may provide through our Sites.
This Site is not intended for children and we do not knowingly collect data relating to children who are under 13 years of age.
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.
Cleveland Clinic London Ltd is the controller and responsible for your personal data (also referred to as “we”, “us” or “our” in this Privacy Notice).
If you have any questions about this Privacy Notice, including any requests to exercise your legal rights, please contact us using the details set out below.
Please direct any questions, comments, or complaints regarding this Privacy Notice to us using the contact information below.
Full name of legal entity: Cleveland Clinic London Ltd
Email address: [email protected]
Postal address: 33 Grosvenor Place, London SW1X 7HY
Further guidance on your rights is available from the Information Commissioner’s Office (https://.ico.org.uk/). You have the right to complain to the UK’s supervisory office for data protection, the Information Commissioner’s Office at https://ico.org.uk/concerns/ if you believe that your data has been processed unlawfully. We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.
This Privacy Notice does not override any applicable national data privacy laws and regulations applicable to Cleveland Clinic London Ltd.
Changes to the Privacy Notice
We reserve the right to update this Privacy Notice because of changes in the law or our business operations. We will post any changes to this Privacy Notice on the applicable Sites and, where appropriate, will notify you of changes by email. Please check the Site periodically for changes to the Privacy Notice.
Changes to Your information
We can most effectively communicate with you when we have information that is accurate and current. Please contact us to update your contact information as it changes.
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. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the Privacy Notice of every website you visit.
2. The data we collect about you
We collect the following categories of personal data about individuals who visit the Site and other third parties.
- Identity Data: first name, last name, username or similar identifier, organization, title, job responsibilities, phone number, email address, date of birth and gender.
- Registration Data: Newsletter requests and event and seminar registrations.
- Marketing Data: Data about individual participation in conferences and seminars and attending webinars.
- Technical Data includes 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.
Personal data does not include data where the identity has been removed (anonymous data).
We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose that are anonymous. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. 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 Notice.
3. 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 Data by filling in forms or by corresponding with us by phone, email or otherwise. We do not knowingly collect health data through this Site. If we learn that you have provided health data through this Site, we will delete it.
Automated technologies or interactions. As you interact with our website, we may automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using Cookies. We may also receive Technical Data about you if you visit other websites employing our Cookies.
Third parties or publicly available sources. We may receive personal data about you from various third parties and public sources as set out below:
- Technical Data from the following parties:
- analytics providers;
- advertising networks; and
- search information providers.
- Identity Data from publicly availably sources.
4. How we use your personal data
Below we describe the purposes that we use personal data and our lawful bases for using such data.
- To protect the information security systems of the Sites we use Technical Data. We have a legitimate interest to maintain the security of the Site for the protection of those who use the Site, to reduce the risk of malicious attacks on or through the Site, and to maintain the availability and integrity of the content of the Site.
- To improve the experiences related to the Sites we use Technical Data. It is in our legitimate interest to understand how the Site is used to improve the accessibility, functions, and content of the Site.
- To provide relevant marketing and educational materials we use Identity Data, Registration Data, and Marketing Data. It is in our legitimate interest to provide Site users interested in information about us with newsletters and other communications related to events, safety, nutrition, healthcare and related to our operations and in some circumstances we may send you such materials based on your consent.
- To communicate with Site users about the Sites we use Identity Data. It is in our legitimate interest to be able to communicate changes to the Sites to you, including related to changes to the Privacy Notice.
- To engage with our vendors we use Identity Data. It is in our legitimate interest to be able to communicate and otherwise conduct business with our vendors.
You are not required to submit your personal details to us through the Sites but if you choose not to do so, we may not be able to address your request or respond to any query that you wish to submit.
You have control regarding our use of personal data for direct marketing. You can elect not to receive particular marketing communications at any time by clicking on the unsubscribe link of those marketing emails. You may also contact us with the information set forth below specifying what marketing communications you no longer wish to receive.
Please see our Cookies Policy for information about our use of third-party cookies, web beacons, and other similar tracking technologies.
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.
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.
5. Disclosures of your personal data
We may have to share your personal data with the parties set out below for the purposes set out in the table in Section 4 above.
- Affiliates: Cleveland Clinic London Ltd is a subsidiary of The Cleveland Clinic Foundation, which has other subsidiaries throughout the world. We may share personal data with The Cleveland Clinic Foundation or any one or more of its direct or indirect affiliates for the purposes set forth in this Privacy Notice. In certain circumstances, we may act as joint controllers with The Cleveland Clinic Foundation, including to respond to some requests by data subjects to exercise their rights under GDPR, as set out in Section 9 below.
- Service Providers: We engage third parties to perform tasks on our behalf that include the use and processing of personal data, including information technology providers, payroll processors, contractors performing work on our behalf, marketing consultants and providers, credit card processors, lawyers, consultants, accountants, and financial institutions that process or manage payments.
- Transaction Parties: 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 Notice.
- Recipients Through Legal Proceedings: We will share personal data to the extent required by any applicable court order, subpoena, or legal process or to comply with a request from a regulator or other government entity and as otherwise legally required. We will also share your applicable personal data with recipients as part of, and to the extent consistent with, any proceeding in which we need to engage in or assert and defend our legal rights.
6. International transfers
We may transfer your data outside the European Economic Area (EEA) to countries that do not have the same level of data protection as your country. Unless the recipients are located in countries that have been deemed acceptable the European Commission (or are certified under a standard such as the EU-US Privacy Shield Framework), we make such transfers pursuant to standard contractual clauses approved by the European Commission. You may contact us for more information about such transfers and the specific mechanism used to transfer your personal data outside the EEA.
7. Data security
We have put in place security measures designed 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.
Although we have implemented measures designed to protect personal data and the Sites, there is no way of ensuring that personal data is always protected while it is in transmission or being stored.
8. Data retention
We will only retain your personal data for as long as necessary to fulfill the purposes we collected it for, including for the purposes of satisfying any legal, accounting, 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 you can ask us to delete your data: see your legal rights below for further information.
In some circumstances we may 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.
9. Your legal rights
Under certain circumstances, you have rights under data protection laws in relation to your personal data.
- Access: Subject to certain exceptions, you have the right 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.
- Correcting: You have the right to 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.
- Deletion: You have the right to 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:You have the right to 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.
- Restrict:You have the right to 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.
- Portability: You have the right to 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: You have the right to 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.
If you wish to exercise any of the rights set out above, please contact us.
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 may 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 may 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.