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Cookie and Privacy Policy

This is the cookie and privacy policy of Iceberg Medical Ltd. In this document, the words “we”, “our”, or “us” refer to Iceberg Medical, and “you” and “your” refers to you as a user of our website: www.icebergmedical.com

If you have any questions, please get in touch with us:

Telephone: 01494 776 289
Email: enquiries@icebergmedical.com
Registered office address: Unit 12 Chess Business Park, Moor Road, Chesham, Buckinghamshire HP5 1SD

Our registered company number is: 06418962
Data Protection Officer: Asad Raja
Nature of Business: Provision of Marketing and Medical Communications services

Privacy policy last updated: September 2021

1. Introduction

a. This policy has been developed to inform you about all the information we collect and use about you. It sets out the conditions under which we may process any information that we collect from you, or that you provide to us. It covers information that could identify you (“personal information”) and information that could not. In the context of the law and this policy, “process” means collect, store, transfer, use or otherwise act on information.

b. Your “personal information” is defined as data which by itself or with other data can be used to identify you. The personal information collected may include: your name and contact information; your date of birth, national insurance number; financial details such as income, bank accounts; biometric data such as finger prints; information from third parties such as credit reference, fraud prevention, insurance, regulatory, courts, publicly available agencies/ bodies; family, lifestyle or social circumstances if relevant to the service; education and employment details for the service.

c. We want users to enjoy our website, but if there are one or more points below with which you are not happy, the only option available to you is to leave our website.

d. At Iceberg Medical, we take the protection of your privacy seriously. We understand that visitors to our website are entitled to know that their personal data will not be used for any purposes unintended by them, and will not accidentally fall into the hands of a third party.

e. We undertake to preserve the confidentiality of all the information you provide to us.

f. Our policy complies with English and Welsh law, and EU General Data Protection Regulation (GDPR).

g. The law requires us to tell you about your rights and our obligations to you, regarding the processing and control of your personal data. In line with that, we request that you read the information provided at: www.knowyourprivacyrights.org

h. Except as set out below, we do not share, sell or disclose to a third party, any of the user information collected through our website.

2. The bases on which we process information about you

a. The law requires us to determine under which of six defined bases we process different categories of your personal information, and to notify you of the basis for each category.

b. If a basis on which we process your personal information is no longer relevant, we shall immediately stop processing your data.

c. If the basis changes and we are required by law to notify you, we shall do so and also notify you of any new basis under which we continue to process your information.

3. Information we process because we have a contractual obligation with you

a. When you purchase our services, or otherwise agree to our terms and conditions, a contract is formed between you and us.

b. In order to carry out our obligations under that contract we must process the information you give us. Some of this information may be personal information.

c. We may use it in order to: verify your identity for security purposes; market our services to you; provide you with suggestions and advice on our services and how to obtain the most from using our website.

d. We process this information on the basis that there is a contract between us, or that you have requested we use the information before we enter into a legal contract.

e. Additionally, we may aggregate this information in a general way and use it to provide business-related insights, for example, to monitor our performance with respect to a particular service we provide. If we use it for this purpose, you as an individual will not be personally identifiable.

f. We shall continue to process this personal information until the contract between us ends or is terminated by either party under the terms of the contract.

4. Information we process with your consent

a. Through certain actions when there is no contractual relationship between us, such as when you browse our website or ask us to provide you with more information about our business, including job opportunities and details about our services, you provide your consent to us processing information that may be personal in nature.

b. Wherever possible, we aim to obtain your explicit consent to process personal information, for example, by asking you to agree to our use of cookies.

c. Sometimes you might give your consent implicitly, such as when you send us a message by email, to which you would reasonably expect us to reply.

d. Except where you have consented to our use of your information for a specific purpose, we do not use your information in any way that would identify you personally. We may aggregate it in a general way and use it to provide business-related insights, for example to monitor the performance of a particular page on our website.

e. If you have given us explicit permission to do so, we may pass your name and contact information to selected associates, whose products or services we believe you might find useful.

f. We will continue to process your information on this basis until you withdraw your consent, or it can be reasonably assumed that your consent no longer exists.

g. You may withdraw your consent at any time by instructing us to do so. You can contact us via email here: enquiries@icebergmedical.com

h. Please note, if you do withdraw consent, you may not be able to use our website or our services further.

5. Information we process for the purposes of legitimate interests

a. We may process information on the basis there is a legitimate interest, either to you or to us, of doing so.

b. Where we process your information on this basis, we do so after giving careful consideration to: whether the same objective could be achieved through any other means; whether processing it may cause you harm; whether you would expect us to process your data, and whether you would consider it reasonable for us to do so.

c. For example, we may process your data on this basis for the purposes of: record-keeping for required administration purposes of Iceberg Medical Ltd; responding to communications from you to which we believe you would expect a response; protecting and asserting the legal rights of any party; insuring against risk or obtaining professional advice;  protecting your interests where we believe we have a duty to do so.

6. Information we process because we have a legal obligation

a. Sometimes, we are obliged to process your information in order to comply with a statutory obligation.

b. For example, we may be required to give information to legal authorities if they request it, or if they have the proper authorisation, such as a search warrant or court order. 

c. This may include your personal information.

7. Information provided on the understanding that it will be shared with a third party

a. Our website allows you to post information with a view to that information being read, copied, downloaded, or used by other people.

b. Examples include: posting a comment on our blog; clicking on an icon next to another visitor’s comment to convey your emotions around that comment, such as liking or disliking.

c. When publicly posting personal information, it is your responsibility to consider who might see this information before you post and decide whether you are happy to post.

d. We allow this information to be displayed and shared.

e. We store this information, and we reserve a right to use it in the future in any way we decide.

f. Once your information enters the public domain, we have no control over what any individual third party may do with it. We accept no responsibility for their actions at any time.

g. Provided your request is reasonable and there is no legal basis for us to retain it, then at our discretion we may agree to your request to delete personal information that you have posted. You can make a request by contacting us at: enquiries@icebergmedical.com

8. Complaints regarding content on our website

a. We attempt to moderate user-generated content on our website, but we are not always able to do so.

b. If you complain about any of the content on our website, we shall investigate your complaint.

c. If we feel it is justified or if we believe the law requires us to do so, we shall remove the content while we investigate.

d. Free speech is a fundamental right, so we have to make a judgment as to whose right will be obstructed: yours, or that of the person who posted the content that offends you.

e. If your complaint is deemed to be vexatious or without any basis, we reserve the right not to correspond with you about it.

9. Job application and employment

a. If you send us information in connection with a job application, we may keep it for a number of years in case we decide to contact you at a later date. If you would like us to remove your information from our system, please contact us at: enquiries@icebergmedical.com

10. Sending a message to our team

a. When you contact us, whether by telephone, through our website or by email, we collect the data you have given to us in order to reply with the information you need.

b. We may record the contents of your communication and our reply in order to increase efficiency.

c. We keep personally identifiable information associated with your message, such as your name and email address, so that we may track our communications with you to provide a high-quality service.

11. Complaining

a. When we receive a complaint, we record all the information you have given to us.

b. We use that information to resolve your complaint.

c. If your complaint reasonably requires us to contact some other person, we may decide to give to that other person some of the information contained in your complaint. We do this as infrequently as possible, but it is a matter for our sole discretion as to whether we do give information, and if we do, what that information is.

d. We may also compile statistics showing information obtained from this source to assess the level of service we provide, but not in a way that could personally identify you or any other person.

12. Cookies

a. Cookies are small text files that are placed on your computer’s hard drive by your web browser when you visit any website. They allow information gathered on one web page to be stored until it is needed for use on another, allowing a website to provide you with a personalised experience and the website owner with statistics about how you use the website so that it can be improved.

b. Some cookies may last for a defined period of time – for example, they may last one day, or last until you close your browser. Others last indefinitely.

c. You should be able to delete cookies via your web browser at any time. Your web browser should also allow you to prevent or limit their use.

d. Our website uses cookies. They are placed by software that operates on our servers, and by software operated by third parties whose services we use.

e. When you first visit our website, we ask you whether you wish us to use cookies. If you choose not to accept them, we shall not use them for your visit except to record that you have not consented to their use for any other purpose.

f. If you choose not to use cookies or you prevent their use through your browser settings, you will not be able to use all the functionality of our website.

g. We use cookies in the following ways: to track how you use our website; to record whether you have seen specific messages we display on our website; to record your answers to surveys and questionnaires on our site while you complete them.

h. We may use social networking tools, such as Facebook, Instagram, WhatsApp, LinkedIn and Twitter, who may themselves also put cookies on your machine. We have little control over these ‘third party’ cookies, so we suggest that you check the respective privacy policies for these external services to help you understand what data these organisations hold about you and what they do with it. For instance, the Facebook Data Use Policy and the Twitter and Instagram privacy policy give further information about those services. For further information on cookies visit www.allaboutcookies.org or www.aboutcookies.org.

13. Personal identifiers from your browsing activity

a. Requests by your web browser to our servers for web pages and other content on our website are recorded.

b. We record information such as your geographical location, your internet service provider and your IP address. We also record information about the software you are using to browse our website, such as the type of computer or device and the screen resolution.

c. We use this information to assess the popularity of the pages on our website and how we perform in providing content to you.

d. If combined with other information we know about you from previous visits, the data possibly could be used to identify you personally.

14. Our use of re-marketing

a. Re-marketing involves placing a cookie on your computer when you browse our website in order to be able to serve to you an advert for our services when you visit some other website.

b. We may use a third party to provide us with re-marketing services from time to time. If so, then if you have consented to our use of cookies, you may see advertisements for our services on other websites.

15. Disclosure and sharing of your information

a. Although we do not disclose your personal information to any third party (except as set out in this notice), we sometimes receive data that is indirectly made up from your personal information from third parties whose services we use.

b. No such information is personally identifiable to you.

16. Your rights

You have a right to request a copy of the personal information we hold about you. This is called a subject access request. If you wish to make such a request, contact the Data Protection Officer on our registered office telephone number as advertised on our website and our communications with you. If you wish to correct any information about you held by us contact our Data Protection Officer in the first instance.

17. Access to your personal information

a. At any time you may review or update personally identifiable information that we hold about you.

b. To obtain a copy of any information that is held about you, you may send us a request at: enquiries@icebergmedical.com

c. After receiving the request, we will tell you when we expect to provide you with the information, and whether we require any fee for providing it to you.

18. Removal of your information

a. If you wish us to remove personally identifiable information from our website, you may contact us at: enquiries@icebergmedical.com

b. Please note that this may limit the service we can provide to you.

19. Verification of your information

a. When we receive any request to access, edit or delete personal identifiable information we shall first take reasonable steps to verify your identity before granting you access or otherwise taking any action. This is important to safeguard your information.

20. Use of site by children

a. We do not sell products or provide services for purchase by children, nor do we market to children.

b. If you are under 18, you may only use our website with consent from a parent or guardian. We collect data about all users of and visitors to these areas regardless of age, and we cannot take responsibility for the use of our site by minors, nor their experience of our site if they access it without the permission of a parent or guardian.

21. Encryption of data sent between us

a. We use Secure Sockets Layer (SSL) certificates to verify our identity to your browser and to encrypt any data you give us.

b. Whenever information is transferred between us, you can check that it is done so using SSL by looking for a closed padlock symbol or other trust mark in your browser’s URL bar or toolbar.

22. How you can complain

a. If you are not happy with our privacy policy, you can let us know by email at: enquiries@icebergmedical.com

b. If you are in any way dissatisfied about how we process your personal information, you have a right to lodge a complaint with the Information Commissioner’s Office. This can be done at: https://ico.org.uk/concerns/

23. Retention period for personal data

a. Except as otherwise mentioned in this privacy notice, we keep your personal information only for as long as required by us: to provide you with the services you have requested to comply with other law, including for the period demanded by tax authorities to support a claim or defence in court.

24. Compliance with the law

a. Our privacy policy has been developed to comply with the law of every country or legal jurisdiction in which we do business.

b. If you think it does not satisfy the law of your jurisdiction, please let us know: enquiries@icebergmedical.com

c. However, ultimately it is your choice as to whether you wish to use our website.

25. Review of this privacy policy

a. We may update this privacy notice from time to time as necessary. The terms that apply to you are those posted here on our website on the day you use our website. We advise you to print a copy for your records.

b. If you have any question regarding our privacy policy, please contact us: enquiries@icebergmedical.com

01494 776 289 enquiries@icebergmedical.comenquiries@icebergmedical.com

Iceberg Medical Ltd, Unit 12 Chess Business Park, Moor Road, Chesham, Buckinghamshire HP5 1SD

Cookie and Privacy Policy