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Privacy Policy

Effective Date April 2015
Definitions

www.apostherapy.co.uk (the “Web Site”) is owned and operated by Apos Medical UK Limited. The terms “Apos®”, “AposTherapy®” “we”, “us”, “our” and “ours” when used in this Privacy Policy means Apos Medical UK Limited which includes all its parents, subsidiaries, divisions, branches, and affiliates. The terms “you”, “your” and “yours” when used in this Privacy Policy means any user of the Web Site. The term “Personal Data” refers to information about you from which you can be identified, such as your name, birth date, e-mail address or mailing address. This Privacy Policy describes AposTherapy’s® current policies and practices with regard to Personal Data collected by AposTherapy® through the Web Site.

Collection of Personal Data Including E-Mail Addresses

AposTherapy® takes your privacy seriously. We respect and protect the privacy of our users and take appropriate steps to safeguard your personal information.

We collect the information you give us when you visit our Web Site and use it when you request to be contacted. You may, through the Web Site, register to receive additional information (i.e. newsletters) from us. When you register, we ask you for contact information like your name, postal address and e-mail address.

We sometimes supplement the information that you provide with information that is received from third parties. For instance, if inaccurate postal or zip codes are received, we will use third party software to fix them.

AposTherapy® Email Marketing Communication Policy

AposTherapy® sends promotional email only to:

  • Customers
  • People who have given consent to AposTherapy® to receive promotional email
  • People on rented email lists who have given permission to the list owner to receive third-party promotional email
  • All of the abovementioned who have not opted out after having received promotional email from us.

In each promotional email, we provide an easy and clear way to opt out of future AposTherapy® email. Opt-out requests using the opt-out link in our emails are processed and go into effect within 10 business days. Opt-out requests sent to the following email address DataProtection@AposTherapy.co.uk are processed within 10 business days. When sending email to rented email lists, we suppress addresses of those people who have opted out of AposTherapy® email in the past.

  • We always disclose our identity in mass email communications, including the address of our headquarters location.
  • We never use deceiving header information or subject lines.
  • We never send mass, promotional email to email addresses “harvested” from websites.
  • We never, under any circumstances, rent or sell email addresses to any other company or individual.
  • When coordinating with our resellers for the purpose of follow-up on sales inquiries made to us, we provide full contact information of the inquirer to the reseller, including email address, so the reseller can follow up on the inquiry.

Our marketing email policy and practice conforms to the United States Federal “CAN SPAM” act of 2003, the Israeli applicable statues such as the Protection Of Privacy Law 5741-1981 and the EU Data Protection Directive of 1995 and Privacy and Electronic Communications Directive of 2002 each as implemented nationally. We welcome and encourage your thoughts on this policy at DataProtection@AposTherapy.co.uk

Use and Disclosure of Personal Data

We process your Personal Data only for specific and limited purposes. We ask only for data that is adequate, relevant and not excessive for those purposes. When we ask you for Personal Data, we tell you the purposes for which we will process that data.

These purposes include the following:

  • We may contact you occasionally to inform you of new services we will be providing, or special offers, events or articles we think will be of interest to you.
  • We may send you regular updates by e-mail or by post on AposTherapy® organized or related events.
  • We may send you requested service information and promotional material.
  • We may use your Personal Data for marketing purposes and market research.
  • We may use your Personal Data internally to help us improve our products, services and Web Site and to help resolve any problems.
  • We may use your Personal Data for security, administrative and legal purposes.
  • We may share Personal Data with re-sellers where they are better placed to respond to a sales query.

We do not share, sell or distribute your Personal Data with third parties outside the Apos® group, except under these limited circumstances:

Personal Data may occasionally be transferred to third parties who act for or on behalf of AposTherapy®, or in connection with the business of AposTherapy® for further processing in accordance with the purposes for which the data was originally collected or for purposes to which you have subsequently consented. For example, sometimes a third party may have access to your Personal Data in order to handle our mailings on our behalf.

We may share or transfer the information in our databases to comply with a legal requirement, for the administration of justice, to protect your vital interests, to protect the security or integrity of our databases or this Web Site, to take precautions against legal liability, or in the event of a corporate sale, merger, reorganization, dissolution or similar event.

Where appropriate, before disclosing Personal Data to a third party, we contractually require the third party to take adequate precautions to protect that data.

Where we permit selected third parties to use your data, we (or they) will contact you by electronic means only if you have consented to this.

If you do not want us to use your data for marketing purposes, or to pass your details on to third parties, please contact AposTherapy® Data Manager at dataprotection@AposTherapy.co.uk or if you are completing an online or offline form please tick the relevant box.

If, in the future, we wish to use your Personal Data in a way not set out in this Privacy Policy, we will notify you about this and seek your permission to do so.

Anonymous Data Collected Through This Web Site

In addition to the information we collect as described above, we may use technology to collect anonymous information about the use of our Web Site. This technology does not identify you personally; it simply enables us to compile statistics about our visitors and their use of our Web Site.

We use this anonymous data to improve the content and functionality of this Web Site and our e-mail updates, to better understand our customers and markets, and to improve our products and services.

Cookies

AposTherapy®® may place cookies on your computer to help us improve your experience on our website. Cookies are widely used as an industry standard in order to enable websites to work, or work more efficiently, in addition to providing useful information to the owners of the site.

We use cookies to distinguish you from other users of our Web Site. This helps us to provide you with a tailored experience when you browse our Web Site and also allows us to improve our Web Site to help diagnose problems with our server, to administer our Web Site and to better match your interests and preferences. By continuing to browse the site without changing your web browser settings, you are agreeing to our use of cookies.

A cookie is simply a small text file that we may store on your computer when you visit our Web Site. Cookies help us remember your preferences and enable us to improve your experience on our Web Site. Cookies do not contain information that can personally identify you.

There are different types of cookies. We only use the following cookies that we think are necessary or helpful to you:

  • Strictly necessary cookies: these are cookies that are required for the operation of our website. Without them, for example, you would not be able to register or log in for any services that we may offer.
  • Analytical/performance cookies: these cookies allow us to recognise and count the number of visitors and to see how visitors move around our website. This helps us to improve the way our website works, for example, by ensuring that users are finding what they are looking for easily and do not encounter technical errors.
  • Functionality cookies: these are used to recognise you when you return to our website. This enables us to personalise our content for you and remember your preferences (for example, your choice of language or region).
  • Targeting cookies: these cookies record your visit to our website, the pages you have visited and the links you have followed. This helps us to provide a website and deliver adverts or messages that are relevant to you and your interests. [We may also share this information with third parties for this purpose.

You can find more information about the individual cookies we use and the purposes for which we use them in the table below:

Cookie Name Purpose More information
[Google Analytics] [__utma
__utmb
__utmc
__utmz]
[These cookies enable us to collect information about how visitors use our site. We use the information to compile reports and to help us improve the site. The cookies collect information in an anonymous form, including the number of visitors to the site, where visitors have come to the site from and the pages they visited.] [Please refer to http://www.google.co.uk/intl/en/analytics/privacyoverview.html for an overview of the Google Analytics privacy policy. To opt out of being tracked by Google Analytics across all websites visit http://tools.google.com/dlpage/gaoptout.]
Session   This cookie is used to store user preferences and choices made as the user browses the site. This cookie expires when the browser is closed.
This cookie collects the first level domain name of the user and the date and time you accessed this Web Site.
This cookie customizes the online advertisements you encounter to those we believe are aligned with your interests.
This cookie determines what country our visitors are accessing the Web Site from.
 
Google Adwords   AdWords uses targeting and advertising cookies, such as AdWords Remarketing and Remarketing with Google Analytics. These are Remarketing and Behavioural services provided by Google. These cookies collect anonymous, aggregated information about website browsing habits, to ensure advertising is more accurately targeted to users and their interests. Google Analytics also enables us to anonymously report on audience demographic and interest data which we use to guide the enhancement of our website experience and advertising. Opt out of Google Ads link: www.google.com/settings/ads
Facebook Advertising   These cookies and similar technologies (such as information about your device or a pixel on a website) enable us to deliver ads and understand their performance, as well as make them more relevant to users. Facebook cookies enable us to gain insights about the users that see and interact with our advertising, visit our website and use our apps. Facebook may also work with an advertiser or its marketing partners to serve you an ad on or off Facebook Services, such as after you’ve visited our site or app, or show you an ad based on the websites you visit or the apps you use across the Internet. Opt out of Facebook Advertising link: http://www.youronlinechoices.eu/

Except for essential cookies, all cookies will expire after the duration set by a third party provider.

If you decide that you are not happy with the use of cookies on our Web Site, most web browsers allow you to easily delete and block cookies by activating certain settings within the browser. This should allow you to refuse either some or all cookies. However, if you use your browser settings to block all cookies, you may lose the benefit of some functionality and not be able to access all or parts of our site.

If you continue to use our website without changing your browser settings, you accept our use of cookies.

For more information on how to delete and block cookies for your specific web browser, please visit the browser’s support or instructions page.

Behaviourally Targeted Advertisements

Any behaviourally targeted advertisements appearing on our Web Site will be clearly identified as such (e.g. through an icon in the corner of the advertisement).

IP Addresses

We may collect information about your computer, including where available your IP address, operating system and browser type, for system administration and to report aggregate information to our advertisers. This is statistical data about our users’ browsing actions and patterns, and does not identify any individual.

User Communications

When you send e-mail or other communication to AposTherapy®®, we may retain those communications in order to process your inquiries, respond to your requests and improve our services.

Links to Other Web Sites

This Privacy Policy applies only to the Web Site and to other Apos® URLs through or from which you have reached this Web Site. This Web Site contains hyperlinks to web sites that are not operated by Apos®. These hyperlinks are provided for your reference and convenience only and do not imply any endorsement of the activities of these third-party web sites or any association with their operators. We do not control these web sites and are not responsible for their data or privacy practices. We urge you to review any privacy policy posted on any site you visit before using the site or providing any Personal Data about yourself.

Information Security

We take appropriate security measures to protect against unauthorized access to or unauthorized alteration, disclosure or destruction of data. These include internal reviews of our data collection, storage and processing practices and security measures, as well as physical security measures to guard against unauthorized access to systems where we store personal data.

Access to Personal Data is restricted to designated AposTherapy® employees, contractors and agents who need to know that information in order to operate, develop or improve our services. These individuals are bound by confidentiality obligations and may be subject to disciplinary proceedings, including termination, if they fail to meet these obligations.

All information you provide to us is stored on our secure servers. Where we have given you (or where you have chosen) a password which enables you to access certain parts of our site, you are responsible for keeping this password confidential and for restricting access to your account.

Transfer of Data Abroad

AposTherapy® is a global enterprise and has facilities and databases in different countries. We may, from time to time, transfer or share your Personal Data to one of our databases in another country, namely to our parent research team at Apos – Medical and Sports Technologies Ltd. The internet is made up of a large number of international connections. If you are visiting this Web Site from a country other than the country in which our server is located, the various communications will necessarily result in the transfer of information including your Personal Data across international boundaries.

Special Note for Parents and Children under Age 18

The site you are visiting is a general audience site. The Web Site is not directed to persons under 18. If a parent or guardian becomes aware that his or her child has provided us with personal information without their consent, he or she should contact us. We do not knowingly collect or solicit personal information from people under 18. If we become aware that a person under 18 has provided us with personal information, we will delete such information from our files.

If you are under 18, do not attempt to provide us any information about yourself.

Your Rights

You have the right to ask us not to process your Personal Data for marketing purposes. We ask your consent (before collecting your data) if we intend to use your data for such purposes or if we intend to disclose your information to any third party for such purposes. You can exercise your right to prevent such processing by checking certain boxes on the forms we use to collect your data. You can also exercise the right at any time by contacting AposTherapy® Data Manager at dataprotection@AposTherapy.co.uk

You have the right to access your Personal Data held by us. Any written request for access to information held about you may be subject to a fee of £10 to meet our costs in providing this information. If you wish to do this, please contact AposTherapy® Data Manager at DataProtection@AposTherapy.co.uk

Disclosure of Personal Information

We may use or disclose PHI to regulatory bodies and organizations such Medicines and Healthcare products Regulatory Agency (“MHRA”) in connection with the reporting of adverse events, product defects or problems, product tracking or for other purposes as required by such bodies. We may use or disclose PHI during the course of clinical research activities. We may also disclose PHI when required or instructed by UK or European laws. We have procedures in place for individuals to have access to PHI, and procedures in place to ensure the integrity of our information and for the timely correction of incorrect information.

Further Information

AposTherapy® may find it necessary to revise and update this policy from time to time as changes to the privacy regulations emerge, and will communicate any such changes to our patients and business partners.

Changes to This Policy

This Policy may change from time to time. We will post any Policy changes on this page and, if the changes are significant, we will provide a more prominent notice. Each version of this Policy will be identified at the top of the page by its effective date, and we will also keep prior versions of this Policy in an archive for your review.

Questions

If you have any questions about this Privacy Policy or concerns about the way we process your Personal Data, please contact AposTherapy® Data Manager at DataProtection@AposTherapy.co.uk

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