Introduction

 

Please read this privacy notice carefully as it sets out how the Corin Group uses your personal information and what your data privacy rights are.

If you are a Corin website user you should also read our websites terms of use which explain the conditions of using our websites, providing gateways to our products and services, as well as lots of other useful information. https://www.coringroup.com/uk/about-us/terms-and-conditions 

Personal data is any information that can be used to identify a living person. It does not include data where the identity has been removed (anonymous data) where there is no reasonable possibility of re-associating that data with the identity of a person.

Corin respects your privacy and is committed to protecting your personal data. This privacy notice will inform you as to how we look after your personal data and tell you about your privacy rights under data protection law.  

Purpose of this privacy notice

 

This privacy notice aims to give you information on how Corin collects and processes your personal data.

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.

Third-party links

 

The Corin Group 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.

The data we collect about you

 

We may collect, use, store and transfer different kinds of personal data about you which we describe as follows: 

  • Identity data includes first name, maiden name, last name, username or similar identifier, marital status, title, date of birth and gender.
  • Contact data includes billing address, delivery address, email address and telephone numbers.
  • Financial data includes bank account and payment card details.Transaction data includes details about payments to and from you and other details of products and services you have purchased from us.
  • 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.
  • Profile data includes your username and password, purchases or orders made by you, your interests, preferences, and feedback and survey responses.Usage data includes information about how you use our website, products and services.
  • Marketing and communications data includes your preferences in receiving marketing from us and our third parties and your communication preferences.
  • Aggregated data is that which is de-identified and combined with other data sets such that it cannot reveal your identified. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature.  

Special category data

 

This is also referred to as sensitive data.

We collect special category health information that is shared with us by care providers and other third parties in the medical sphere, specific to orthopaedic medical treatment. This data is analyzed and used in order to deliver the requested products and services for your treatment.

We do not collect special category data about religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership or information about your genetic and biometric data.  Nor do we collect any information about criminal convictions and offences outside of our employee Privacy Notice. 

In some circumstances, we may use sensitive data for secondary purposes such as research, product development and analytics for commercial and non-commercial purposes.  In this case, additional precautions (including pseudonymization, de-identification or anonymization) will be carried out prior to use.

If you fail to provide personal data 

 

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 or your care provider with goods or services). In this case, we may have to cancel a product or service you or your care provider have with us, but we will notify you if this is the case at the time.

How your personal data is collected

 

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

Direct interactions. You may give us information such as 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:

  • apply for our products or services;
  • create an account on our website;
  • subscribe to our service or publications;
  • request marketing to be sent to you;
  • enter a competition, promotion or survey; or
  • give us some feedback
  • use one of our health information monitoring applications

Indirectly we typically collect patient identifiable information when providing services to a healthcare provider for your diagnosis and medical treatment.

Automated technologies or interactions

 

As you interact with Corin Group by electronic or other means, we may automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies. We may also receive Technical Data about you if you visit other websites employing our cookies. Please see the cookie policy on our website.

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 such as Google
  • advertising networks
  • search information providers.
  • Contact, Financial and Transaction Data from providers of technical, payment and delivery
  • Identity and Contact Data from data brokers or aggregators
  • Identity and Contact Data from publicly availably sources

 

How we use your personal data

 

We have set out below in Table 1 a description of the ways we plan to receive and use your personal data, and which of the lawful bases we do so.

 

Table 1. Data Processed

 

Purpose/Activity

Type of data

Lawful basis for processing personal data

Registration of a new customer

(a) Identity (contact details)

(b) Contact

Performance of agreement to terms and conditions

A commercial agreement

(a) Identity (contact details)

(b) Contract

Performance of a contract

Patient treatment

(a) Patient Identity

(b) Sensitive health information

This will depend on the country in which the treatment takes place. In some countries the lawful basis will be patient consentin others where the product or service provided by a Corin Group entity which is classified as a healthcare provider, the law may not require consent and may be described in some countries as a ‘legitimate interest’ or ‘treatment disclosure’.

Patients will be notified of the lawful basis being used in their country of treatment.

Product research

(a) de-identified patient treatment data

(b) de-identified medical data from business associates

The lawful basis will depend on the applicable laws of the country in which the patient data is collected.  

In some countries a legitimate interest is permissible in others patient consent is required. An ethical committee waiver of consent may have been applied for and granted to the Corin Group business entity.

Patients will be notified of the lawful basis for de-identified data being used in their country of treatment.

Product development

 (a) anonymised patient data

Notification to patients

An agreement to provide product or services for a clinical trial

(a) Identity (contact details)

(b) Contract

A contract which necessitates exchange of contact details of personnel conducting or providing products and services for the clinical trial

Your participation in a clinical trial for which a Corin Group business entity is the sponsor

(a) Identity

(b) Sensitive health information

Your consent in order to receive any medical data with your identity

To process and deliver an order including:

1. Management of fees and payments

2. Collection and recovery of money owed

(a) Identity (contact details)

(b) Contract

(c) Financial

(d) Transaction

Performance of a contract

Legitimate interest (business operations)

To manage our relationship with you which will include:

1. Notifying you about changes to our terms or privacy policy

2. Asking you to leave a review or take a survey

(a) Identity (contact details)

(b) Contract

(c) Profile

(d) Marketing and Communications

Performance of a contract with you

Legal obligation to notify and inform

Performance of a contract

Opt-in (to keep our records updated and to study how customers use our products/services)

CCTV footage

(a)   Identity on an image

 

Legitimate interest for

Premises security

Personal Safety

 

Lawful Basis Further Explanation

 

Legitimate Interest means the interest of our business within the sector within which the Corin Group operates (namely Healthcare), thus facilitating us to provide a regulated and legally compliant products and services with applicable data protection.   We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law).

Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.

Marketing

 

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

 

  • Promotional offers from us 

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, services 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 or services from us or if you provided us with your details when you entered a competition or registered for a promotion and, in each case, you have not opted out of receiving that marketing.

 

  • Third-party marketing 

We will receive and express opt-in consent before we share your personal data with any company outside Corin for marketing purposes.

 

  • Opting out 

You can ask us or third parties to stop sending you marketing messages at any time by contacting our customer services department, info@coringroup.com or by using the appropriate website opt outs.

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

 

  • 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 on our website.

 

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 purpose 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. 

 

Disclosures of your personal data 

 

We may have to share your personal data with the parties set out below

 

  • Internal Third Parties.

Those authorized within the business to process data.

 

  • External Third Party Service Providers.

These are service providers acting as processors who provide IT and system administration services.

 

  • Professional advisers and business associates

These are business partners who we instruct to process data or may be legally required or permitted to share the data with. This includes but is not limited to clinical health professionals, industry consultants, lawyers, bankers, auditors and insurers who provide consultancy, banking, legal, insurance and accounting services.

 

  • Revenue & Customs, regulators and other authorities acting as processors or joint controllers who require reporting of processing activities in certain circumstances.

 

  • 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.

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.

 

International transfers

 

If we transfer your personal data outside your country of residence to support your clinical treatment, research or product improvements, we will notify you of the legal basis for doing so, which, depending on the purpose my require your consent.

 

Data security

 

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used,  accessed, altered or disclosed in an unauthorized way. 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.

All data transferred or stored is protected with stringent technical security solutions deployed on contracted by the Corin Group along with its data security policies. Our external websites are tested using independent penetration testing providers, validating our controls to mitigate the threat of cyber-crime.

All data processing is compliant with the laws of the countries in which it is collected and those to which it may be transferred.

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.

 

Data retention

 

We will only retain your personal information for as long as necessary to fulfil the purposes we collected it for, including 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 unauthorized 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. Laws of the country of your citizenship will also determine the period of data retention.

In some circumstances we may anonymize your personal information so that it can no longer be associated with you, in which case we may use such information without further notice to you.

 

Your legal rights

 

You have rights under data protection laws in relation to your personal data.

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

Under certain circumstances, by law you have the right to: 

 

  • Request access

You may request access to your personal data in order to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.

We may need to request specific information from you to help us confirm your identity and ensure your right to access the information (or to exercise any of your other rights). This is a security measure to ensure that personal information 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.

 

  • Fees

Where possible we try to avoid charging a fee for access requests to data, however, this may be not be possible if there is a significant administrative overhead. We will charge a fee if your request is unfounded, repetitive or excessive, alternatively, we may refuse to comply with your request in these circumstances.

 

  • 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. 

 

  • Request correction

You may request a 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 also need to verify the accuracy of the new data you provide to us.

 

  • Request erasure

You may request erasure of the personal data we hold about you were there is no legally justifiable or otherwise reason for us to continue to process or store 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

Where we are processing your personal data legally for a purpose that does not require your consent, but there is something about your particular situation which makes you feel that it impacts on your fundamental rights and freedoms, you are entitled to object to processing. 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.

 

  • Request a restriction of processing

You may request the 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.

 

  • Request a transfer

You can request transfer of your  personal data to a third party upon your written request to do so. We will provide to you, or directly to the 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.

 

  • Withdrawal of consent

Where we are relying on consent to process your personal data you may withdraw your consent at any time. 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. Please be aware that if processing of your data has commenced for clinical treatment, we are required to retain such medical data by law within the country it is processed for a set period of time.  

 

Contacting The Corin Group

 

We have a Data Protection Officer who is responsible for overseeing questions in relation to this privacy notice. If you have any questions about this privacy notice, please write to  

 

The Data Protection Officer at Corin Group, The Corinium Centre, Cirencester, GL7 1YJ, United Kingdom

 

Or

 

Email :  DPO@coringroup.com

 

Complaints

 

If you have been in contact with Corin about a matter regarding data privacy and you do not think this was dealt with properly you can make a complaint to the Regulator in your country of residence.

 

A useful website for finding the contact information for Regulators is:

 

https://www.linklaters.com/en/insights/data-protected/home