Privacy Policy
Privacy Policy (“Policy”) – Stem Cell Health Limited (trading as Stem Cell Health) (“SCH” or “us”/”we”)
Your Privacy
SCH is committed to ensuring that your privacy is protected. If it is necessary for you to provide personal data, you can be assured that that information will only be used in accordance with this Policy. To ensure that you understand how your information will be used please read this Policy in full.
Our privacy practices reflect applicable legal requirements, including the General Data Protection Regulation, or GDPR (“Applicable Data Protection Laws”).
For the purpose of Applicable Data Protection Laws, the data controller of your personal data processed by us in accordance with this Policy is SCH of Cranfield Innovation Centre, Cranfield University Technology Park, University Way, Cranfield, Bedford MK43 0BT.
It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.
Please note, we reserve the right to amend this Policy at any time, normally by posting an updated Policy on this page and, where appropriate, notifying to you by e-mail. Please check back frequently to see any updates or changes to this Policy.
If you have any questions about this Policy, including any requests to exercise your legal rights, please contact us using the details set out in the “How To Contact Us” section below.
How we collect personal data
Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).
We may collect, use, store and transfer different kinds of personal data about you as set out below:
Information you give us: We may collect your personal data in the following circumstances:
• when you correspond with us;
• when you participate in a promotion or survey;
• when you sign up to a mailing list;
• when you sign up or subscribe for any SCH service (including, without limitation, when you register on the SCH website at www.stem-cell.health (“Website”) and/or download SCH’s mobile smart phone application (“Mobile Application”));
• when you participate in any prize draws or competitions;
• when you participate in discussion boards or other social media functions operated by us or on our behalf;
• when you search for a product or place an order with us including on the Website and other sites we control;
• when you interact with us with the Website or our other sites, social channels and platforms; and
• when you report a problem with our Website or other sites we control.
The information you give us may include your first name, surname, address, e-mail address, location, source, phone number, birthday, financial and credit card information, personal description and photograph.
Information we collect about you: With regard to each of your visits to our Website, or other sites we control, we may automatically collect the following information:
• technical information, including the Internet protocol (IP) address used to connect your computer to the Internet, your login information, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform; and
• information about your visit, including the full Uniform Resource Locators (URL) clickstream to, through and from our Website, and other sites we control, (including date and time); products you viewed or searched for; page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), and methods used to browse away from the page and any phone number used to call our customer service number.
Information we receive from other sources: We may receive information about you if you use any of the other websites we operate or the other services we provide. We are also working closely with third parties (including, for example, business partners, marketing agents, sub-contractors in technical, payment, order fulfilment, and delivery services, advertising and marketing networks, analytics, database and applications providers and search information providers) and may receive information about you from them.
How we use your personal data
We use information held about you in the following ways:
Information you give us: We will use this information:
• to present our Website, Mobile Application and other SCH digital platforms, to you;
• to carry out our obligations arising from any contracts entered into between you and us and to provide you with information, products or services that you request;
• to provide you with information about other goods and services and events we offer that are similar to those that you have already purchased or enquired about;
• to provide you with information about goods and/or services we feel may interest you. If you are an existing customer, we will only contact you by electronic means (e-mail or SMS) with information about goods and services similar to those which were the subject of a previous sale or negotiations of a sale to you, or where you have otherwise provided your consent. If you do not want us to use your data in this way, please contact us at the address provided at the bottom of this Policy;
• to operate and maintain an internal database of our fans, and to gather a profile on our fans, so we might better understand what interests you, and how we can better tailor our updates, goods, services and opportunities for you, including for the purposes set out in this privacy policy;
• to notify you about changes to our Website, Mobile Application and/or other sites or any products or services that we offer or provide through it (including, without limitation, when you register for our Website, Mobile Application and/or other sites);
• to ensure that content from our Website, Mobile Application and/or other sites, is presented in the most effective manner for you and for your computer or device; and
• for any other purpose with your consent.
Information we collect about you: We will use this information:
• to administer our Website, Mobile Application and other sites, and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes;
• to improve our Website, Mobile Application and other sites, to ensure that content is presented in the most effective manner for you and for your computer or device;
• to allow you to participate in interactive features of our service, when you choose to do so;
• as part of our efforts to keep our Website, Mobile Application and other sites, safe and secure;
• to measure or understand the effectiveness of advertising we serve to you and others, and to deliver relevant advertising to you; and
• to make suggestions and recommendations to you and other users of our Website, Mobile Application and other sites, about goods or services that may interest you or them.
Information we receive from other sources: We may combine this information with information you give to us and information we collect about you. We may use this information and the combined information for the purposes set out above (depending on the types of information we receive).
If there are other circumstances where SCH collects your personal data, you will be made aware of such collection at the time.
The legal bases for processing your personal data
We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:
• Where we need to perform the contract we are about to enter into or have entered into with you.
• Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests. Such legitimate interests may include:
• improving our client customer service and support as well as enhancing and developing our products and services, IT-systems and processes used to support our products and services and the marketing and sale thereof;
• to give you superior fan experience and to provide you with convenient access to our products and services;
• to keep you up-to-date on the latest product announcements, general updates, special offers and other exciting information that we think you might like to hear about;
• to deliver offers and communications tailored to you as an individual and to provide a personalised fan experience.
• Where we need to comply with a legal or regulatory obligation.
Please note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your personal data. Please contact us using the details set out in the “How To Contact Us” section, if you need details about the specific legal ground we are relying on to process your personal data.
Given the specific purposes for which we envisage using your personal data, under the provisions of Applicable Data Protection Law we do not anticipate being required to obtain your consent to do so, save for where we wish to use your personal data to provide you with marketing or information about products and services which may be of interest to you, and we are required by Applicable Data Protection Law to seek your consent before we do so. See the section “Marketing” below for more information on this.
Should we wish to use your personal data for other specific purposes that require your consent, we will contact you to request this.
When we disclose your personal data
We may share your personal data with any member of our group, which means our subsidiaries, our ultimate holding company and its subsidiaries, as defined in section 1159 of the English Companies Act 2006, including for our legitimate interests (or those of a third party) where your interests and fundamental rights do not override those interests.
We may disclose your personal data to third parties:
• in the event that we sell or buy any business or assets, in which case we may disclose your personal data to the prospective seller or buyer of such business or assets;
• if SCH or substantially all of its assets are acquired by a third party, in which case personal data held by it will be one of the transferred assets;
• if we are under a duty to disclose or share your personal data in order to comply with any legal obligation, or in order to enforce or apply our terms of use or terms and conditions of supply and other agreements from time to time; or to protect the rights, property, or safety of SCH, our customers or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction; and/or
• where we use analytics database and applications providers and search engine providers that assist us in the improvement and optimisation of our Website, Mobile Application and other sites.
Other examples of instances where SCH may wish to share your information may include:
• information provided to shipping companies so that they can deliver products;
• information provided to third party companies who may execute competitions or prize draws or marketing or social media campaigns on our behalf, and/or who may administer our fan databases;
• information provided to third party companies who may collate results from surveys on our behalf; and/or
• information to third party companies who may execute other services on our behalf from time to time.
We may disclose personal data to other parties not listed above if we are required by law to do so.
We require all third parties to respect the security of your personal data and to treat it in accordance with Applicable Data Protection 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.
Unless you have provided your consent, or we are otherwise permitted to do so under Applicable Data Protection Law, we will not disclose information about identifiable individuals to our team partners, team suppliers and/or other advertisers or sponsors for their own purposes, but we may provide them with aggregate information about our users (for example, we may inform them that 200 men aged under 25 have clicked on their advertisement on any given day). We may also use such aggregate information to help advertisers reach the kind of audience they want to target (for example, women located in a particular part of the country). We may make use of the personal data we have collected from you to enable us to comply with our advertisers’ or sponsors’ wishes by displaying their advertisement to that target audience.
All of our employees, agencies, partners and suppliers are obliged by us to respect confidentiality.
How we protect and store your personal data
SCH safeguards the security of the data you send us with physical, electronic and managerial procedures. SCH requests that you take reasonable steps to safeguard and protect your own personal data when you are on the internet. Change passwords often, use a combination of letters and numbers and make sure that you use a secure browser.
The web server may automatically record your IP address and the date and length of time you spent on our Website, and other sites, including as detailed in the “Information we collect about you” sections above.
Transfers of your personal data outside of the EEA
The data that we collect from you may be transferred to, and stored at, a destination outside the European Economic Area (‘EEA’). It may also be processed by staff operating outside the EEA who work for us or for one of our suppliers or partners. Such staff maybe engaged in, among other things, management of our fan database, the fulfilment of any order made by you, the processing of your payment details and the provision of support services. We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this Policy.
Whenever we transfer your personal data out of the EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:
• We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission.
• Where we use certain service providers, or share personal data with members of our Group or our other partners, we may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe (“Model Form Clauses”). Copies of these form of agreement are available at https://ec.europa.eu/info/law/law-topic/data-protection/data-transfers-outside-eu/model-contracts-transfer-personal-data-third-countries_en.
• Where we use providers based in the US, we may transfer data to them if they are part of the Privacy Shield which requires them to provide similar protection to personal data shared between the Europe and the US. For more information on the Privacy Shield scheme, see: https://www.privacyshield.gov/welcome.
Please contact us using the details set out in the “How to Contact Us” section if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.
Links to other sites
SCH will endeavour to only provide links to other sites that are from a trustworthy source. However, once you leave the Website or other sites we control, you should be aware and take note that we have no control over any other website. We cannot, therefore, be responsible for the protection of privacy of any information, that you provide on any other website. Those websites, including, without limitation, those of SCH’s webstore operator, will not be governed by this Policy. If you use any of the links provided to you from our site, you should read their applicable privacy statement before you submit any personal data to these websites.
Social Plugins
SCH uses social plugins of social networks such as: Facebook, Twitter, LinkedIn, YouTube and Instagram (“Buttons”).
When you visit the Website, these Buttons will be deactivated by default. To activate these Buttons you must click on them. Once they have been clicked they will remain active until they are deactivated by you or you delete your cookies.
When the Button is activated, the social network can extract data independently, whether you interact with the Button or not. If you are logged on to a social network, the network can assign your visit to the Website, or our other sites, to your user social network account.
SCH has no control on the data retrieved by social networking websites and you must consult their relevant social network privacy policy, or data protection policy, to find out how they use your data. For the avoidance of doubt this Policy only relates to the Website and other channels, networks, mobile applications, platforms and/or social media accounts operated by SCH or on SCH’s behalf.
If you do not want to combine data extracted from your own personal networking site, and our Website or other sites, please ensure that you log out of any social network sites before activating the Buttons.
Cookies
The Website uses cookies to allow SCH to gather information about how we can improve the Website. More information on how we use these cookies can be found in our Cookies Policy here.
Your Rights
Pursuant to the Applicable Data Protection Law, persons about whom we hold personal data have a number of rights which may be exercised in respect of their personal data, including the following:
• The right of access to personal data held by us
• The right to amend and rectify any inaccuracies in personal data held by us
• The right to erase personal data held by us
• The right to data portability of personal data held by us
• The right to request restriction of the processing of personal data held by us
• The right to object to processing of personal data by us
Further rights are provided for in the Model Form Clauses referenced above.
These rights will be exercisable subject to limitations as provided for in Applicable Data Protection Law.
You may also have the right to lodge a complaint with your national data protection authority or other public authority governing the protection of your personal data in the EU Member State of your habitual residence or place of work or in the place of the alleged infringement if you consider that the processing of personal data relating to you carried out by us infringes Applicable Data Protection Law. The Information Commissioner’s Office (ICO), is the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.
Where you have provided (and we have relied upon) your consent to process your personal data, you may withdraw your consent, at any time by contacting us at the address stated below and where no other legal basis exist upon which we can process your data we will apply your preferences going forward. However, this will not affect the lawfulness of any processing carried out before you withdrew your consent.
In some circumstances, withdrawing your consent or objecting to the processing of your personal data, or requesting its deletion, will mean that you cannot take advantage of certain of our services or products or other opportunities, and we may need to suspend or terminate your access to such products, services, platforms or to our Website or Mobile Application.
You may make a request to us to exercise these rights by contacting us using the details set out in the “How to contact us” section. As we must be able to identify the person making the request, we may request that you confirm any request made by you via different means by contacting us at the address stated below. Due to technological constraints and/or information security considerations, it may be inappropriate to use social media to supply information in response to any request by you for access to information, and so please provide an alternative delivery address for our response.
Marketing
You will receive marketing communications from us if you have requested information from us or purchased goods or services or another experience 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. In other cases, where required by Applicable Data Protection Law, we will ask for your consent before we sent you any marketing communications.
You have the right to ask us not to process your personal data for marketing purposes. You can exercise your right to prevent such processing by contacting us at address below, or clicking on the unsubscribe link sent as part of any electronic marketing.
Where you opt out of receiving 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.
Data retention
We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of 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 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.
For further information as to any specific retention periods that might apply to personal data, we hold about you, please contact us using the details set out in the “How to Contact Us” section.
In some circumstances you can ask us to delete your data: see the “Your Rights” section below for further information.
How to Contact Us
All comments, queries and requests regarding this privacy policy are welcome. Please direct them to: Stem Cell Health Limited, Timios Stavros Hospital, Rafael Santi 17, Larnaca 6052, Cyprus marked for the attention of the Legal Department.
Or you can write to our Data Protection Officer at: dpo@stem-cell.health.
©2022 Stem Cell Health Ltd. All rights reserved.
This privacy policy was last reviewed on 20 January 2020.
