ETHOS Ltd (“We”) are committed to protecting your personal data and respecting your privacy. This notice and any other documents referred to in them sets out the basis on which any personal data we collect from you, or you provide to us, will be processed by us. The notice also describes your rights over the data we collect and how you can exercise your rights.

WHAT INFORMATION DO WE COLLECT AND PROCESS ABOUT YOU WHEN YOU VISIT OUR WEBSITE?

We will collect your personal data when you fill in forms on our website www.ethos.co.im (“our site”). It includes information you provide when you register to use our site. We will collect information about your visit, including the full Uniform Resource Locators (URL), clickstream to, through and from our site (including date and time), 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.

WHEN YOU CONTACT US

We will collect your information when you correspond with us by phone, e-mail or otherwise and will collect information each time you visit our sites. The information you give us may include your name, address, e-mail address and phone number. We do this based on our legitimate interest to ensure that we can respond to you to requests for information about our services.

FOR MARKETING PURPOSES

We will never sell your data nor provide access to it to any third parties for marketing purposes.

We will only use your personal data, to provide you with information about other goods and services we offer which are similar to those you have already purchased or enquired about, including premium services. We do this based on our legitimate interest. However, you can ask us to stop sending you marketing messages at any time by following the opt out links on any marketing messages sent to you or by contacting us at any time.

We will only send you our newsletters where you have agreed to receive these.

WHEN YOU APPLY FOR A JOB WITH US

When you apply for a position at ETHOS Ltd, the personal information you provide to us may include, your name, address (including email address), job and career history, educational background, professional membership and other relevant information from your CV. We process the information you provide to us based on discussing a possible contract of employment.

WHAT DO WE DO WITH YOUR PERSONAL DATA?

We will use the information for our legitimate interest to improve our site to ensure the content is presented in the most effective manner for you as part of our efforts to provide a service and to keep our site safe and secure. We will only use your information when the law allows us, in this instance, where we need to comply with a legal or regulatory obligation.

Our website uses cookies to distinguish you from other users of our website. This helps us to provide you with a good experience when you browse our website and allows us to improve our site. A cookie is a small file of letters and numbers that we store on your browser or the hard drive of your computer if you agree. The cookies will collect the following information when you use our site:

• 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
• Mobile device type and version
• Anonymous statistics about message transmission

Please read our cookie policy for further information.

DISCLOSURE OF YOUR INFORMATION

We will only share your personal data with third parties where we have a legal obligation to do so:

• Where we are under a duty to disclose or share your personal data in order to comply with any laws, or in order to enforce or apply our terms of use or any other terms within the agreements; or to protect the rights, property, or safety of ETHOS Ltd, our customers, or where we are required to share it with government agencies or regulators.

HOW DO WE LOOK AFTER AND STORE YOUR DATA?

The data we collect from you via the website may be transferred to, and stored at, a destination outside the EEA. It may also be processed by staff operating outside the EEA who work for us or for one of our suppliers, for example our e-mail marketing services provider.

Whenever we transfer your information out of the EEA, we ensure a similar degree of protection is afforded to the data 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, we may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe.
• Where we use providers based in the US, we may transfer data to them if they are registered with Privacy Shield which requires them to provide similar protection to personal data shared between Europe and the US. All information you provide to us is stored on our secure servers in the UK or EEA.

The transmission of information via the internet is never completely secure. Although we will do our best to protect your information, we cannot 100% guarantee the security of your data transmitted to our site. However, once we have received your information, we will use strict ‘best-in-class’ procedures and technologically up-to-date security features to prevent unauthorised access.

RETAINING YOUR INFORMATION

We will only retain your information for as long as necessary to fulfil the purposes for which we collected it, including for the purposes of satisfying any legal, accounting, regulatory, 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

WHAT ARE YOUR RIGHTS?

You have the following rights:

• to ask us not to process your personal data at any time;
• to access your personal data;
• You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances. Hospify does not store or hold patient data, this data remains on the device so any subject access right made by a patient will need to be directed to the doctor or hospital to which the patient is attached;
• to request us to amend your personal data so that it is correct and complete; or
• to request us to delete your personal data.

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

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 several requests. In this case, we will notify you and keep you updated. You also have the right to make a complaint to the Information Commissioner’s Office – the supervisory authority that handles data protection law in the UK. You can contact them at:

Their website: https://ico.org.uk/make-a-complaint/

Information Commissioner’s Office:

Wycliffe House
Water Lane
Wilmslow
Cheshire SK9 5AFE
casework@ico.org.uk
Telephone: 0303 123 1113

THIRD PARTY WEBSITES

Our site may, from time to time, contain links to and from the websites of our partner networks, advertisers and affiliates.  If you follow a link to any of these websites, please note that these websites have their own privacy policies, we do not accept any responsibility or liability for the policies.  Please check these policies before you submit any personal data to these websites.

CONTACT US

If you have any questions about how we use your personal data, or want to exercise your rights over your information, you can use our contact form email us on brett@ethos.co.im

POLICY INFORMATION

This policy was last updated on the 11th August 2020. We may update it at any time.