Privacy
1. Important Information and Who We Are
This Privacy Notice sets out information about the online privacy practices of Actigen Limited (‘Actigen’)
Actigen is committed to protecting your personal data. This Privacy Notice informs you how we look after your personal data when you visit our website www.Actigen.com, regardless of where you visit the website from.
This Privacy Notice contains information about the choices you can make about the way your personal data is collected by us, how it will be used and for what purposes, as well as the rights you have in relation to that personal data.
Purpose of This Privacy Notice
This Privacy Notice aims to give you information on how Actigen collects and processes your personal data through your use of our website, including any data you may provide through the website when you use the website, whether in your capacity as an individual, or as a director, shareholder, partner, employee or other representative of a company or other organisation.
The website is not intended for children, and Actigen does not knowingly collect data relating to children under the age of 16 in respect of the website. The Website does not target any of its services to children under the age of 16.
It is important that you read this Privacy Notice together with any other privacy notice or fair processing notice we may provide 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.
Controller
This Privacy Notice is issued on behalf of Actigen, and when we mention “Actigen”, “we”, “us” or “our” in this Privacy Notice, we are referring to Actigen Limited.
Actigen is the controller and responsible for the Website.
Third-party Links
Our 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, their content or their privacy practices, which may differ from Actigen’s and are not responsible for their privacy statements. When you leave this Website, we encourage you to read the privacy notice of every website you visit.
2. The Personal Information We Collect About You and Why
Personal Data Collected on Our Website and How We Collect Such Data
We have structured our Website so that, in general, you can visit Actigen on the web without identifying yourself or revealing personal data unless you actively choose to do so.
The personal data that we may collect about you through the Website broadly falls into the following categories:
- Information you provide voluntarily
Certain parts of the Website may provide you with the choice to provide personal data voluntarily. For example, we may ask you to provide your contact details in order to receive information from us and/or to submit enquiries to us. If you submit the form on the “Contact Us” section of the Website, we may collect your name, email address, company, phone number, and any other personal data you include in the additional comments section.
- Information we collect automatically
When you visit the Website, we may collect certain information automatically from your device.
Collecting this information enables us to better understand the visitors who come to our Website, where they come from, and what content on the Website is of interest to them. We use this information for our internal analytics purposes and to improve the quality and relevance of the Website to our visitors.
Some of this information may be collected using cookies and similar tracking technology, as explained further below under the heading “Cookies”.
In general, we will use the personal data we collect from you through the Website only for the purposes described in this Privacy Notice or for purposes that we explain to you at the time we collect your personal data.
Cookies
The Website may use “cookies” to collect and use personal information about you and to enhance your experience on the Website.
Please see our Cookies Policy (note 3 below) for further information about the cookies used on the Website and your rights in respect to the same.
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 the Website may become inaccessible or not function properly.
3. How We Use Your Personal Data
Actigen uses your personal data to better understand your needs and interests and to provide you with better service. We will only use your personal data when the law allows us to.
4. Transfers of Your Personal Data
Who We Share Your Personal Data With
Actigen will not sell, rent or lease your personal data to others. Actigen will not share your personal data with third parties except in line with permitted uses, as set out in this Privacy Notice or as specifically consented to by you. We may have to share your personal data with the parties set out below.
Internal Third Parties: Advisors and consultants that provide professional services to Actigen and undertake other activities relating to the operations of Actigen as service providers or otherwise.
External Third Parties: Actigen contracts with third party service providers and suppliers to deliver services to Actigen, including providing services such as IT system administration.
Such suppliers and service providers are required to keep confidential the information received on behalf of Actigen consistent with this Privacy Notice and may not use it for any purpose other than to carry out the services they are performing for Actigen.
Regulatory Authorities. Actigen and its parent company/ies is/are subject to regulation in various jurisdictions by various authorities, including tax authorities, regulators and other authorities based in various countries who require reporting of processing activities in certain circumstances.
Successors. Circumstances may arise where, whether for strategic or other business reasons, Actigen decides to sell, buy, merge or otherwise reorganise its businesses in some countries. Such a transaction may involve the disclosure of personal data to 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. It is Actigen’s practice to seek appropriate protection for information, including personal data, in these types of transactions. 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.
5. Where Do We Transfer Your Personal Data
Your personal data may be transferred to, and processed in, countries other than the country in which you are resident. These countries may have data protection laws that are different from the laws of your country (and, in some cases, may not be as protective).
The Website’s servers are located in the United States and in other countries, including the United Kingdom. Actigen and third party service providers and partners operate around the world. The third-party service providers we use facilitate the hosting and operation of the Website, as well as store information collected and used in the course of their activities, including personal data. This means that when we collect your personal data we may process it in any of these countries.
When Actigen shares your personal data with third parties which may be located in other jurisdictions, Actigen undertakes measures such that such transfers are lawful, including making such transfers to jurisdictions that are considered to have adequate privacy protections, and/or entering into agreements with such third parties to whom we transfer your personal data with binding data protection clauses (including, for EU personal data exports, the European Commission’s Standard Contractual Clauses for transfers of personal data) or other such safeguards, as applicable. Some of these providers are located, and store personal data entrusted to them in the United States. Actigen enters into contractual arrangements with such third-party service providers requiring them to keep the personal data in question confidential and safeguard it by way of appropriate technical and organizational measures.
We require all third parties we share your personal data with to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-parties 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.
6. Your Legal Rights
Under certain circumstances, you have rights under data protection laws in certain countries in relation to your personal data. Please click here (see note 2 at bottom) about these rights. We respond to all requests we receive from individuals wishing to exercise their data protection rights in accordance with applicable data protection laws.
7. Data Security
To prevent unauthorised access or disclosure, to maintain data accuracy, and to ensure the appropriate use of information, including personal data, collected on the Website, Actigen takes reasonable and appropriate technical and organizational measures to protect your personal data from loss, misuse and unauthorised access, disclosure, alteration and destruction, taking into account the risks involved in the processing and the nature of the personal data. 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.
8. Data Retention
We only retain your personal data for as long as it is necessary in connection with the relevant processing activity associated with the Website, as long as necessary to protect our rights in respect of existing and potential claims relating to the processing activity in question, or as otherwise required by law (including legal, accounting, or reporting requirements). We also maintain policies and procedures regarding how and how long we retain your personal data collected in connection with the Website.
To determine the appropriate retention period for personal data collected in connection with the Website, 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.
9. Changes to This Website Privacy Notice
We may update this Website Privacy Notice from time to time in response to changing legal, technical or business developments. We will post any changes to this Website Privacy Notice and will update the revision date in this document, so you will know what personal data we collect about you, how we use it, and what choices you have.
10. We Do Not Use Your Personal Data From This Website to Provide Services or Products
We do not collect, use or process information relating to your use of the Website for the purpose of providing services or products to our clients.
Questions and Comments
For any comments or questions about this Website Privacy Notice or our privacy practices, or if you believe Actigen has handled your personal data in a manner that does not comply with this Website Privacy Notice, as well as if you have any general requests or questions regarding our processing of your personal data, please contact Actigen at the address of our Data Protection Coordinator below.
Contact Details
Our full details are:
Full name of legal entity: Actigen Limited
Title of Data Protection Officer: Company Secretary
Email address: info@actigen.com
Postal address: Actigen Limited, St John’s Innovation Centre, Cowley Road, Cambridge, CB4 0WS, UK
Last updated: December 2021
Note 1
Personal data collected on our website and elsewhere
We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:
• Identity Data includes name, username or similar identifier, marital status, title, date of birth and gender;
• Contact Data includes address, email address and telephone numbers.
• Technical Data includes internet protocol (IP) address, 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 the Website.
• Usage Data includes information about how you use our website.
We may also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. 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. 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 the Website Privacy Notice.
On the Website, 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) and we do not collect any information about criminal convictions and offences.
How is your personal data collected?
We use different methods to collect data from and about you, including through the methods set out below.
Direct interactions: You may give us your Identity Data and Contact Data by filling in a form or by corresponding with us. This includes personal data you provide when you:
• use the “Contact Us” form on our website;
• give us some feedback.
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, server logs and other similar technologies.
Please see our Cookie Policy for further details.
Third parties or publicly available sources: We may receive personal data about you from various third parties and public sources as set out below:
• analytics providers who could be based inside or outside the US or EU;
• advertising networks who could be based inside or outside the US or EU;
• search information providers who could be based inside or outside the US or EU; and
• Identity Data and Contact Data from public sources, data brokers or aggregators who could be based inside or outside the US or EU.
Note 2
Personal Data: Rights Terms
If you are in the European Economic Area, and more generally in respect of our collection and processing of personal data in connection with the Website that is subject to the General Data Protection Regulation (EU) 2016/679 (referred to herein as “GDPR”) or similar implementing legislation in the UK, you have specific rights (subject to exemptions) with respect to how we process your personal data, including the following:
• 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: (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 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.
• Right to lodge a complaint with your data protection supervisory authority located in the EU jurisdiction where you reside in the event you believe that we are processing your personal data otherwise than as permitted by applicable law.
If you are in the European Economic Area, and more generally in respect of our collection and processing of personal data in connection with the Website that is subject to the GDPR or similar implementing legislation in the UK, you can exercise these rights by contacting us by emailing us at data@Actigen.com
Note 3
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