Introduction

Nanosonics privacy statement applies to the personal data of consumers that is collected or used by Nanosonics or its affiliates or subsidiaries (“we”, “us”, or “our”). We appreciate the interest you have shown in our company, products and services by visiting our websites, (www.nanosonics.co.uk / www.nanosonics.eu / www.nanosonics.fr) or related communication channels, including, but not limited to, our social media channels, loyalty clubs and blogs. It applies to all personal data we collect when you visit our websites, when you use the products or services offered by Nanosonics, when you purchase our products or services, when you subscribe to newsletters, when you contact customer support, and when you interact with us as a business customer, supplier or business partner, etc. This privacy statement describes why and how we collect and use personal data and provides information about individuals’ rights.

We may use personal data provided to us for any of the purposes described in this privacy statement or as otherwise stated at the point of collection. Personal data is any information relating to an identified or identifiable living person. Nanosonics processes personal data for numerous purposes, and the means of collection, lawful basis of processing, use, disclosure, and retention periods for each purpose may differ. When collecting and using personal data, our policy is to be transparent about why and how we process personal data.

Business contacts

Collection of personal data
Nanosonics processes personal data about contacts (existing and potential Nanosonics clients and/or individuals associated with them) using a customer relationship management system (the “Nanosonics CRM”). The collection of personal data about contacts and the addition of that personal data to the Nanosonics CRM is initiated by a Nanosonics user and may include name, employer name, contact title, phone, email and other business contact details. In addition, the Nanosonics CRM may collect data from Nanosonics email (sender name, recipient name, date and time) and calendar (organiser name, participant name, date and time of event) systems concerning interactions between Nanosonics users and contacts or third parties.

Use of personal data
Personal data relating to business contacts may be visible to and used by Nanosonics users to learn more about an account, client or opportunity they have an interest in, and may be used for the following purposes:

• Administering, managing and developing our products and services
• Providing information about us and our products and services
• Making contact information available to Nanosonics users
• Identifying clients/contacts with similar needs
• Describing the nature of a contact’s relationship with Nanosonics
• Performing analytics, including producing metrics for Nanosonics such trends, relationship maps, sales intelligence and progress against business goals

Nanosonics does not sell or otherwise release personal data contained in the Nanosonics CRM to third parties for the purpose of allowing them to market their products and services without consent from individuals to do so.

Data retention
Personal data will be retained on the Nanosonics CRM for as long as it is necessary for the purposes set out above (e.g. for as long as we have, or need to keep a record of, a relationship with a business contact).

Customers

Collection of personal data
Our policy is to collect only the personal data necessary for agreed purposes and we ask our customers to only share personal data where it is strictly needed for those purposes. Where we need to process personal data to provide services, we ask our customers to provide the necessary information to the data subjects regarding its use. Our clients may use relevant sections of this privacy statement or refer data subjects to this privacy statement if they consider it appropriate to do so.

Use of personal data
We use personal data for the following purposes:

Providing customer support
We provide customer support e.g. training and technical services. Some of our services require us to process personal data in order to provide advice and deliverables

Administering, managing and developing our businesses and services
We process personal data in order to run our business, including:

– Managing our relationship with clients
– Developing our businesses and services (such as identifying client needs and improvements in service delivery)
– Maintaining and using IT systems
– Hosting or facilitating the hosting of events, and
– Administering and managing our website and systems and applications.

Security, quality and risk management activities
We have security measures in place to protect our and our clients’ information (including personal data), which involve detecting, investigating and resolving security threats. Personal data may be processed as part of the security monitoring that we undertake; for example, automated scans to identify harmful emails. We may monitor the services provided to clients for quality purposes, which may involve processing personal data stored on the relevant client file.

Providing our customers with information about us and our range of products and services
Unless we are asked not to, we use client business contact details to provide information that we think will be of interest about us and our services. For example, industry updates and insights, other services that may be relevant and invites to events.

Complying with any requirement of law, regulation or a professional body of which we are a member
As with any provider of services, we are subject to legal, regulatory and professional obligations. We need to keep certain records to demonstrate that our services are provided in compliance with those obligations and those records may contain personal data.

We are continually looking for ways to help our customers and to improve our business and services. Where agreed with our customers, we may use information that we receive in the course of providing services for other lawful purposes, including analysis to better understand a particular issue, industry or sector, provide insights back to our customers, to improve our business, service delivery and offerings and to develop new Nanosonics products and services. To the extent that the information we receive in the course of providing professional services contains personal data, we will de-identify the data prior to using the information for these purposes.

Data retention
We retain the personal data processed by us for as long as is considered necessary for the purpose for which it was collected (including as required by applicable law or regulation). In the absence of specific legal, regulatory or contractual requirements, our baseline retention period for records and other documentary evidence created in the provision of services is seven years.

Individuals whose personal data we obtain in connection with providing services to our customers

Collection of personal data
Our policy is to collect only the personal data necessary for agreed purposes and we ask our customers only to share personal data where it is strictly needed for those purposes. Where we need to process personal data to provide our products and services, we ask our customers to provide the necessary information to the data subjects concerned regarding its use. We collect and use contact details for our customers in order to manage and maintain our relationship with those individuals. Please see the Business contacts section of this privacy statement for more information about our processing of this type of data.

Use of personal data
We use personal data for the following purposes:

Providing customer support
We provide customer support e.g. training and technical services. Some of our services may require us to process personal data in order to provide advice and deliverables.

Administering, managing and developing our businesses and services
We process personal data in order to run our business, including:

– Managing our relationship with clients
– Developing our businesses and services (such as identifying client needs and improvements in service delivery)
– Maintaining and using IT systems
– Hosting or facilitating the hosting of events, and
– Administering and managing our website and systems and applications.

Security, quality and risk management activities
We have security measures in place to protect our and our clients’ information (including personal data), which involve detecting, investigating and resolving security threats. Personal data may be processed as part of the security monitoring that we undertake; for example, automated scans to identify harmful emails. We may monitor the services provided to clients for quality purposes, which may involve processing personal data stored on the relevant client file. We have policies and procedures in place to monitor the quality of our services and manage risks in relation to client engagements.

Providing our customers with information about us and our range of products and services
Unless we are asked not to, we use client business contact details to provide information that we think will be of interest about us and our services. For example, industry updates and insights, other services that may be relevant and invites to events.

Complying with any requirement of law, regulation or a professional body of which we are a member
As with any provider of services, we are subject to legal, regulatory and professional obligations. We need to keep certain records to demonstrate that our services are provided in compliance with those obligations and those records may contain personal data.

We are continually looking for ways to help our customers and to improve our business and services. Where agreed with our customers, we may use information that we receive in the course of providing services for other lawful purposes, including analysis to better understand a particular issue, industry or sector, provide insights back to our customers, to improve our business, service delivery and offerings and to develop new Nanosonics products and services. To the extent that the information we receive in the course of providing professional services contains personal data, we will de-identify the data prior to using the information for these purposes.

Data retention
We retain the personal data processed by us for as long as is considered necessary for the purpose for which it was collected (including as required by applicable law or regulation).
In the absence of specific legal, regulatory or contractual requirements, our baseline retention period for records and other documentary evidence created in the provision of services is seven years.

Individuals who get in touch with us

Collection of personal data
We collect personal data when an individual gets in touch with us with a question, complaint, comment or feedback (such as name, contact details and contents of the communication). In these cases, the individual is in control of the personal data shared with us and we will only use the data for the purpose of responding to the communication.

Staff
We may collect personal data concerning our own personnel as part of the administration, management and promotion of our business activities. Staff should consult the legal department for information on why and how personal data is collected and processed.

Recruitment applicants
When applying online for a role at Nanosonics via the Nanosonics website careers page, applicants should refer to the information made available when applying for a job for details about why and how personal data is collected and processed.

Visitors to our website

Collection of personal data
Visitors to our websites are generally in control of the personal data shared with us. We may capture limited personal data automatically via the use of cookies on our website. Please see the section on Cookies for more information.

We receive personal data, such as name, title, company address, email address, and telephone and fax numbers, from website visitors; for example when an individual subscribes to updates from us.

Visitors are also able to send an email to us through the website. Their messages will contain the user’s screen name and email address, as well as any additional information the user may wish to include in the message. We ask that you do not provide sensitive information (such as race or ethnic origin; political opinions; religious or philosophical beliefs; trade union membership; physical or mental health; genetic data; biometric data; sexual life or sexual orientation; and, criminal records) to us when using our website; if you choose to provide sensitive information to us for any reason, the act of doing so constitutes your explicit consent for us to collect and use that information in the ways described in this privacy statement or as described at the point where you choose to disclose this information.

Cookies
We use small text files called ‘cookies’ which are placed on your hard drives to assist in personalising and enriching your browsing experience by displaying content that is more likely to be relevant and of interest to you. The use of cookies is now standard operating procedure for most websites. However if you are uncomfortable with the use of cookies, most browsers now permit users to opt-out of receiving them. You need to accept cookies in order register on our website. You may find other functionality in the website impaired if you disable cookies. After termination of the visit to our site, you can always delete the cookie from your system if you wish. You can find out more details regarding our use of cookies on our Cookies page.

Use of personal data
When a visitor provides personal data to us, we will use it for the purposes for which it was provided to us as stated at point of collection (or as obvious from the context of the collection).

Typically, personal data is collected to:

• Subscribe to updates
• Enquire for further information
• Distribute requested reference materials
• Submit curriculum vitae
• Monitor and enforce compliance with our terms and conditions for use of our website
• Administer and manage our website, including confirming and authenticating identity and preventing unauthorised access to restricted areas, premium content or other services limited to registered users, and
• Aggregate data for website analytics and improvements.

Unless we are asked not to, we may also use your data to contact you with information about Nanosonics products, services and events, and other information which may be of interest to you. Should visitors subsequently choose to unsubscribe from mailing lists or any registrations, we will provide instructions on the appropriate webpage, in our communication to the individual, or the individual may contact us by email to data.protection@nanosonics.co.uk.

Our websites do not collect or compile personal data for the dissemination or sale to outside parties for consumer marketing purposes or host mailings on behalf of third parties. If there is an instance where such information may be shared with a party that is not a Nanosonics company, the visitor will be asked for their consent beforehand.

Data retention
Personal data collected via our websites will be retained by us for as long as it is necessary (e.g. for as long as we have a relationship with the relevant individual).

Security
We take the security of all the data we hold very seriously. We have a framework of policies, procedures and training in place covering data protection, confidentiality and security and regularly review the appropriateness of the measures we have in place to keep the data we hold secure.

When and how we share personal data and locations of processing
We will only share personal data with others when we are legally permitted to do so as required. When we share data with others, we put contractual arrangements and security mechanisms in place to protect the data and to comply with our data protection, confidentiality and security standards.

We are part of a global organisation and in common with other businesses, we use third parties located in other countries to help us run our business. As a result, personal data may be transferred outside the countries where we and our clients are located. This includes to countries outside the European Union (“EU”) and to countries that do not have laws that provide specific protection for personal data. We have taken steps to ensure all personal data is provided with adequate protection and that all transfers of personal data outside the EU are done lawfully. Where we transfer personal data outside of the EU to a country not determined by the European Commission as providing an adequate level of protection for personal data, the transfers will be under an agreement which covers the EU requirements for any transfer of personal data outside the EU, such as the European Commission approved standard contractual clauses. The European Commission approved standard contractual clauses are available here. Personal data held by us may be transferred to:

Other Nanosonics companies
For details of our companies located around the world, please click here. We may share personal data with other Nanosonics companies where necessary for administrative purposes and to provide services to our clients (e.g. when providing services involving advice from Nanosonics companies in different territories). Our business contacts are visible to and used by Nanosonics to learn more about a contact, customer or an opportunity they have an interest in (please refer to the Business Contacts section of this privacy statement for more information about our processing of this type of data).

Third party organisations that provide applications/functionality, data processing or IT services to us
We use third parties to support us in providing our services and to help provide, run and manage our internal IT systems. For example, providers of information technology, cloud based software as a service providers, identity management, website hosting and management, data analysis, data back-up, security and storage services. The servers powering and facilitating that cloud infrastructure are located in secure data centres around the world, and personal data may be stored in any one of them where necessary to deliver goods and services.

Third party organisations that otherwise assist us in providing goods, services or information

Law enforcement or other government and regulatory agencies or to other third parties as required by, and in accordance with, applicable law or regulation
Occasionally, we may receive requests from third parties with authority to obtain disclosure of personal data, such as to check that we are complying with applicable law and regulation. We will only fulfil requests for personal data where we are permitted to do so in accordance with applicable law or regulation.

Changes to this privacy statement
We recognise that transparency is an ongoing responsibility so we will keep this privacy statement under regular review. This privacy statement was last updated on 15 May 2018.


Data controller and contact information

The data controller is Nanosonics UK Limited with its registration address at Nanosonics Unit 2, Linfit Court, Colliers Way, Clayton West, Huddersfield, West Yorkshire HD8 9WL, United Kingdom for the purposes of providing or receiving services.

If you have any questions about this privacy statement or how and why we process personal data, please contact us at:

Nanosonics
Unit 2, Linfit Court,
Colliers Way, Clayton West,
Huddersfield,
West Yorkshire HD8 9WL,
United Kingdom
Email: data.protection@nanosonics.co.uk
Phone: 01484 860581

Individuals’ rights and how to exercise them
Individuals have certain rights over their personal data and data controllers are responsible for fulfilling these rights. Where we decide how and why personal data is processed, we are a data controller and include further information about the rights that individuals have and how to exercise them below.

Access to personal data
You have a right of access to personal data held by us as a data controller. This right may be exercised by emailing us at data.protection@nanosonics.co.uk. We may charge for a request for access in accordance with applicable law. We will aim to respond to any requests for information promptly, and in any event within the legally required time limits (currently 40 days).

Amendment of personal data
To update personal data submitted to us, you may email us at data.protection@nanosonics.co.uk or, where appropriate, contact us via the relevant website registration page or by amending the personal details held on relevant applications with which you registered. When practically possible, once we are informed that any personal data processed by us is no longer accurate, we will make corrections (where appropriate) based on your updated information.

Withdrawal of consent
Where we process personal data based on consent, individuals have a right to withdraw consent at any time. To withdraw consent to our processing of your personal data please email us at data.protection@nanosonics.co.uk or, to stop receiving an email from a Nanosonics marketing list, please click on the unsubscribe link in the relevant email received from us.

Other data subject rights
This privacy statement is intended to provide information about what personal data we collect about you and how it is used. As well as rights of access and amendment referred to above, individuals may have other rights in relation to the personal data we hold, such as a right to erasure/deletion, to restrict or object to our processing of personal data and the right to data portability. Some of these rights will only be available from 25 May 2018.
If you wish to exercise any of these rights, please send an email to data.protection@nanosonics.co.uk.

Complaints
We hope that you won’t ever need to, but if you do want to complain about our use of personal data, please send an email with the details of your complaint to data.protection@nanosonics.co.uk. We will look into and respond to any complaints we receive. You also have the right to lodge a complaint with the Information Commissioner’s Office (“ICO”) (the UK data protection regulator). For further information on your rights and how to complain to the ICO, please refer to the ICO website.