ExSeed Health Ltd & ExSeed Health ApS
|Last updated||Dec 1st, 2019|
|Company||Means ExSeed Health Limited (UK company number 11002717) and ExSeed Health ApS (Danish company number 38677942).|
|GDPR||means the General Data Protection Regulation.|
|Responsible Person||Means Morten G. Ulsted.|
|Register of Systems||means a register of all systems or contexts in which personal data is processed by the Company.|
1. Data protection principles
The Company is committed to processing data in accordance with its responsibilities under the GDPR.
Article 5 of the GDPR requires that personal data shall be:
- processed lawfully, fairly and in a transparent manner in relation to individuals;
- collected for specified, explicit and legitimate purposes and not further processed in a manner that is incompatible with those purposes; further processing for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes shall not be considered to be incompatible with the initial purposes;
- adequate, relevant and limited to what is necessary in relation to the purposes for which they are processed;
- accurate and, where necessary, kept up to date; every reasonable step must be taken to ensure that personal data that are inaccurate, having regard to the purposes for which they are processed, are erased or rectified without delay;
- kept in a form which permits identification of data subjects for no longer than is necessary for the purposes for which the personal data are processed; personal data may be stored for longer periods insofar as the personal data will be processed solely for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes subject to implementation of the appropriate technical and organisational measures required by the GDPR in order to safeguard the rights and freedoms of individuals; and
- processed in a manner that ensures appropriate security of the personal data, including protection against unauthorised or unlawful processing and against accidental loss, destruction or damage, using appropriate technical or organisational measures.”
2. General provisions
- This policy applies to all personal data processed by the Company.
- The Responsible Person shall take responsibility for the Company’s ongoing compliance with this policy.
- This policy shall be reviewed at least annually.
3. Lawful, fair and transparent processing
- To ensure its processing of data is lawful, fair and transparent, the Company shall maintain a Register of Systems.
- The Register of Systems shall be reviewed at least annually.
- Individuals have the right to access their personal data and any such requests made to the Company ity shall be dealt with in a timely manner.
4. Lawful purposes
- All data processed by the Company must be done on one of the following lawful bases: consent, contract, legal obligation, vital interests, public task or legitimate interests.
- Where consent is relied upon as a lawful basis for processing data, evidence of opt-in consent shall be kept with the personal data.
- Where communications are sent to individuals based on their consent, the option for the individual to revoke their consent should be clearly available.
5. Data minimisation
- The Company shall ensure that personal data are adequate, relevant and limited to what is necessary in relation to the purposes for which they are processed.
- The Company shall take reasonable steps to ensure personal data is accurate.
- Where necessary for the lawful basis on which data is processed, steps shall be put in place to ensure that personal data is kept up to date.
7. Archiving / removal
- To ensure that personal data is kept for no longer than necessary, the Company shall put in place an archiving policy for each area in which personal data is processed and review this process annually.
- The archiving policy shall consider what data should/must be retained, for how long, and why.
- The Company shall ensure that personal data is stored securely using modern software that is kept-up-to-date.
- Access to personal data shall be limited to personnel who need access and appropriate security should be in place to avoid unauthorised sharing of information.
- When personal data is deleted this should be done safely such that the data is irrecoverable.
- Appropriate back-up and disaster recovery solutions shall be in place.
In the event of a breach of security leading to the accidental or unlawful destruction, loss, alteration, unauthorised disclosure of, or access to, personal data, the Company shall promptly assess the risk to people’s rights and freedoms and if appropriate report this breach to the ICO.
10. Cookie and remarketing information
We advertise ExSeed Health across the Internet, including on the Google and Facebook networks.
These platforms will display ads to you based on what parts of the ExSeed Health website you have viewed by placing a cookie on your web browser.
This cookie does not in any way identify you or give access to your computer or mobile device. The cookies will not be tracked without your permission and you can opt out at any time.
11. Aggregate Data
ExSeed may share aggregate data, which is information that is completely anonymized. Therefore, it does not contain any personal details such as name or contact information, and is combined with information of others so that you cannot reasonably be identified as an individual with third parties. This information is different from individual information and is not personal information because it does not identify any particular individual or disclose any particular individual’s data. For example, ExSeed’s aggregate data may include a statement that “50% of our male users share a particular range of scores,” without providing any data or testing results specific to any individual user
END OF POLICY