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*”IUG” refers to Intelligent Ultrasound Group plc and its subsidiary companies, MedaPhor Limited, Intelligent Ultrasound Limited
and Intelligent Ultrasound North America Inc.
Privacy Policy
The Intelligent Ultrasound Group (“IUG”*) privacy policy (the “privacy policy”) is all about letting
you know that we take the protection and management of your personal information very
seriously. As a UK based business our handling of your information is controlled by the UK Data
Protection Act 2018 and the Data Protection, Privacy and Electronic Communications
(Amendments etc) (EU Exit) Regulations 2019. We therefore take great care to protect your
personal information or anything which might identify you personally.
1. The data we collect about you
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 collect your information:
− When you visit any of our websites or portals.
− When you make an online purchase.
− When you engage with us on social media.
− When you contact us with queries or complaints, or to report a problem with our website.
− When you fill in any forms.
− When you permit a third party to share with us the information they hold about you.
− We collect data from publicly available sources (such as Companies House) where the information is
made public as a matter of law.
− When you apply for a job with us.
− When you register for our eLearning platform known as the Intelligent Ultrasound Academy;
Third-party links
Our websites 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 and are not responsible for their privacy statements. When you leave our website,
we encourage you to read the privacy policy of every website you visit.
We will collect and process the following information about you as follows:
• Information you give us. This may include your name, gender, address, e-mail address and phone number,
financial and credit card information, personal description and and details of any employees of your
company.
• Information we collect about you. With regard to each of your visits to our website we will automatically
collect the following information:
o 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 plugin types and versions, operating system and platform;
*”IUG” refers to Intelligent Ultrasound Group plc and its subsidiary companies, MedaPhor Limited, Intelligent Ultrasound Limited
and Intelligent Ultrasound North America Inc.
o information about your visit, including the full Uniform Resource Locators (URL), to, through and
from our website (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), methods used to browse away from the page, and any phone
number used to call our customer services, sales and/or renewals teams.
• Information we receive from other sources. This is information we receive about you if you use any of the
other websites we operate or the other services we provide. In this case we will have informed you when we
collected that data if we intend to share that data internally and combine it with data collected on this
website. We will also have told you for what purpose we will share and combine your data. We are working
closely with third parties (including, for example, business partners, sub-contractors in technical, payment
services, advertising networks, analytics providers, credit reference agencies). We will notify you when we
receive information about you from them and the purposes for which we intend to use that information.
We 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 this privacy policy.
If you fail to provide personal data
Where we need to collect personal data by law, or under the terms of a contract we have with you or your
organisation and you fail to provide that data when requested, we may not be able to perform the contract
we have or are trying to enter into with you or your organisation (for example, to provide you with goods or
services). In this case, we may have to cancel a product or service you have with us but we will notify you if
this is the case at the time.
2. How is your personal data collected?
We use different methods to collect data from and about you including through:
• Direct interactions. You may give us your Identity, Contact, Financial and Special Category Data by
filling in forms or by corresponding with us by post, phone, email or otherwise. This includes
personal data you provide when you:
o apply for, or purchase, our products or services;
o create an account;
o subscribe to our services or publications;
o register for our eLearning platform known as the Intelligent Ultrasound Academy;
o request marketing to be sent to you;
o enter a competition, promotion or survey; or
o give us some feedback.
• Automated technologies or interactions. 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.
• Third parties or publicly available sources. We may receive personal data about you from various
third parties and public sources as set out below:
o Special Category and Technical Data from the following parties:
(a) purchasers of our goods or services, based inside or outside the EU;
*”IUG” refers to Intelligent Ultrasound Group plc and its subsidiary companies, MedaPhor Limited, Intelligent Ultrasound Limited
and Intelligent Ultrasound North America Inc.
(b) analytics providers such as Google based outside the EU; and
(c) search information providers based inside or outside the EU.
• Contact, Financial and Transaction Data from providers of technical, payment and delivery services
based inside or outside the EU.
• Identity and Contact Data from data brokers or aggregators based inside or outside the EU.
• Identity and Contact Data from publicly availably sources such as Companies House and the
Electoral Register based inside the EU.
3. How we use 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
or your organisation.
• 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.
• Where we need to comply with a legal or regulatory obligation.
Generally we do not rely on consent as a legal basis for processing your personal data other than in relation
marketing communications which may be sent (by us or third parties acting on our behalf) to you via email
or text message. You have the right to withdraw consent to marketing at any time by contacting us.
Purposes for which we will use your personal data
We have set out below, in a table format, a description of all the ways we plan to use your personal data,
and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are
where appropriate.
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 data. Please contact usif you need details about the specific legal ground
we are relying on to process your personal data where more than one ground has been set out in the table
below.
Purpose/Activity Type of data Lawful basis for processing
including basis of legitimate
interest
To register you or your
organisation as a new
customer
(a) Identity
(b) Contact
Performance of a contract with
you or your organisation
To process and deliver your
order including:
(a) Manage payments, fees
and charges
(b) Collect and recover money
owed to us
(c) To deal with goods
returned to us
(a) Identity
(b) Contact
(c) Financial
(d) Transaction
(e) Marketing and Communications
(a) Performance of a contract
with you or your organisation
(b) Necessary for our legitimate
interests (to recover debts due
to us)
*”IUG” refers to Intelligent Ultrasound Group plc and its subsidiary companies, MedaPhor Limited, Intelligent Ultrasound Limited
and Intelligent Ultrasound North America Inc.
(d) To provide you with
support services, for example
in relation to our Intelligent
Ultrasound Academy
eLearning platform
To manage our relationship
with you which will include:
(a) Notifying you about
changes to our terms or
privacy policy
(b) Asking you to leave a
review or take a survey
(a) Identity
(b) Contact
(c) Profile
(d) Marketing and Communications
(a) Performance of a contract
with you or your organisation
(b) Necessary to comply with a
legal obligation
(c) Necessary for our legitimate
interests (to keep our records
updated and to study how
customers use our
products/services)
To enable you to partake in a
prize draw, competition or
complete a survey
(a) Identity
(b) Contact
(c) Profile
(d) Usage
(e) Marketing and Communications
(a) Performance of a contract
with you or your organisation
(b) Necessary for our legitimate
interests (to study how
customers use our
products/services, to develop
them and grow our business)
To administer and protect our
business and this website
(including troubleshooting,
data analysis, testing, system
maintenance, support,
reporting and hosting of data)
(a) Identity
(b) Contact
(c) Technical
(a) Necessary for our legitimate
interests (for running our
business, provision of
administration and IT services,
network security, to prevent
fraud and in the context of a
business reorganisation or
group restructuring exercise)
(b) Necessary to comply with a
legal obligation
To deliver relevant website
content and advertisements
to you and measure or
understand the effectiveness
of the advertising we serve to
you
(a) Identity
(b) Contact
(c) Profile
(d) Usage
(e) Marketing and Communications
(f) Technical
Necessary for our legitimate
interests (to study how
customers use our
products/services, to develop
them, to grow our business and
to inform our marketing
strategy)
To use data analytics to
improve our website,
products/services, marketing,
customer relationships and
experiences
(a) Technical
(b) Usage
Necessary for our legitimate
interests (to define types of
customers for our products and
services, to keep our website
updated and relevant, to
develop our business and to
inform our marketing strategy)
To make suggestions and
recommendations to you
(a) Identity
(b) Contact
(c) Technical
(d) Usage
(e) Profile products/services and grow
our business)
Necessary for our legitimate
interests (to develop our about
goods or services that may be
of interest to you
Marketing
*”IUG” refers to Intelligent Ultrasound Group plc and its subsidiary companies, MedaPhor Limited, Intelligent Ultrasound Limited
and Intelligent Ultrasound North America Inc.
We strive to provide you with choices regarding certain personal data uses, particularly around marketing
and advertising.
Promotional offers from us
We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you
may want or need, or what may be of interest to you. This is how we decide which products, services and
offers may be relevant for you (we call this marketing).
You will receive marketing communications from us if you have requested information from us or purchased
goods or services from us and, in each case, you have not opted out of receiving that marketing.
Third-party marketing
We will get your express opt-in consent before we share your personal data with any other company for
marketing purposes.
Opting out
You can ask that we or third parties acting on our behalf stop sending you marketing messages at any time
checking or unchecking relevant boxes to adjust your marketing preferences or by following the opt-out links
on any marketing message sent to you or by contacting us at any time.
Where you opt out of receiving these marketing messages, this will not apply to personal data provided to
us as a result of a product/service purchase, product/service experience or other transactions.
Cookies
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 this website may become inaccessible
or not function properly. For more information about the cookies we use, please see our Cookie Policy.
Change of purpose mailto:hello@intelligentultrasound.com
We will only use your personal data for the purposes for which we collected it, unless we reasonably consider
that we need to use it for another reason and that reason is compatible with the original purpose. If you wish
to get an explanation as to how the processing for the new purpose is compatible with the original purpose,
please contact us.
If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the
legal basis which allows us to do so.
Please note that we may process your personal data without your knowledge or consent, in compliance with
the above rules, where this is required or permitted by law.
4. Disclosures of your personal data
We may have to share your personal data with the parties set out below for the purposes set out in the table
in paragraph 3 above.
*”IUG” refers to Intelligent Ultrasound Group plc and its subsidiary companies, MedaPhor Limited, Intelligent Ultrasound Limited
and Intelligent Ultrasound North America Inc.
Internal Third Parties
Other companies that may be part of our group now or in the future acting as joint controllers or processors.
External Third Parties
• Service providers acting as processors based inside or outside of the EU who provide IT and system
administration services.
• Professional advisers acting as processors or joint controllers including lawyers, bankers, auditors and
insurers based inside or outside of the EU who provide consultancy, banking, legal, insurance and
accounting services.
• HM Revenue & Customs, regulators and other authorities acting as processors or joint controllers based
in the United Kingdom who require reporting of processing activities in certain circumstances.
• 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. 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
policy.
We require all third parties to respect the security of your personal data and to treat it in accordance with
the 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.
5. International transfers
We may transfer your data outside the European Economic Area (EEA) as our external third parties could be
based outside the EEA.
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. For further details, see
European Commission: Adequacy of the protection of personal data in non-EU countries.
• 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. For further details, see
European Commission: Model contracts for the transfer of personal data to third countries.
• 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 further details, see European Commission: EU-US Privacy Shield.
Please contact us if you want further information on the specific mechanism used by us when transferring
your personal data out of the EEA.
6. Data security
*”IUG” refers to Intelligent Ultrasound Group plc and its subsidiary companies, MedaPhor Limited, Intelligent Ultrasound Limited
and Intelligent Ultrasound North America Inc.
We have put in place appropriate security measures to prevent your personal data from being accidentally
lost, used or accessed in an unauthorised way, altered or disclosed. 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. They will only process your personal data on our instructions and they are subject to a duty of
confidentiality.
We have put in place procedures to deal with any suspected personal data breach and will notify you and
any applicable regulator of a breach where we are legally required to do so.
7. Data retention
How long will you use my personal data for?
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.
By law we have to keep basic information about our customers (including Contact, Identity, Financial and
Transaction Data) for at least six years after they cease being customers for tax purposes.
In some circumstances you can ask us to delete your data: see [Request erasure] below for further
information.
In some circumstances we may anonymise your personal data (so that it can no longer be associated with
you) for research or statistical purposes in which case we may use this information indefinitely without
further notice to you.
8. Your legal rights
Under certain circumstances, you have rights under data protection laws in relation to your personal data.
You have the right to:
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.
*”IUG” refers to Intelligent Ultrasound Group plc and its subsidiary companies, MedaPhor Limited, Intelligent Ultrasound Limited
and Intelligent Ultrasound North America Inc.
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 or your organisation.
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.
If you wish to exercise any of the rights sets out above, please contact us.
No fee usually required
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.
What we may need from you
We may need to request specific information from you to help us confirm your identity and ensure your right
to access your personal data (or to exercise any of your other rights). This is a security measure to ensure
that personal data 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.
Time limit to respond
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 a number of requests. In this case, we will
notify you and keep you updated.
9. Contact details
We hope this Privacy Notice has been helpful in terms of how we use your personal data and your rights in
relation to such personal data. If you have any questions or wish to make a complaint, please contact our
Data Protection Officer:
Email address: dpo@intelligentultrasound.com
*”IUG” refers to Intelligent Ultrasound Group plc and its subsidiary companies, MedaPhor Limited, Intelligent Ultrasound Limited
and Intelligent Ultrasound North America Inc.
Postal address: Data Protection Officer, Floor 6A, Hodge House, 114-116 St Mary Street, Cardiff,
CF10 1DY
You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO),
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.
Last update
This Privacy Policy was last updated on 26 January 2021.
Glossary
LAWFUL BASIS
Legitimate Interest means the interest of our business in conducting and managing our business to enable
us to give you the best service/product and the best and most secure experience. We make sure we consider
and balance any potential impact on you (both positive and negative) and your rights before we process your
personal data for our legitimate interests. We do not use your personal data for activities where our interests
are overridden by the impact on you (unless we have your consent or are otherwise required or permitted
to by law). You can obtain further information about how we assess our legitimate interests against any
potential impact on you in respect of specific activities by contacting us.
Performance of Contract means processing your data where it is necessary for the performance of a contract
to which you or your organisation are a party or to take steps at your request before entering into such a
contract.
Comply with a legal or regulatory obligation means processing your personal data where it is necessary for
compliance with a legal or regulatory obligation that we are subject to.