Last updated: 25 April 2021
1. Definitions and Interpretation
In this Policy the following terms shall have the following meanings:
“Account” means an account required to access and/or use certain areas and features of Our Site;
“Cookie” means a small text file placed on your computer or device by Our Site when you visit certain parts of Our Site and/or when you use certain features of Our Site.
“Our Site” means the website, www.soteranalytics.com and www.soterspine.com
“Our Services” means any hardware, software or Cloud Services owned and operated by Soter Analytics LTD, including but not limited to the SoterSpine solution.
“We/Us/Our” means the Soter Analytics entity you contract with and pay fees to based on the edition of the Soter product you’re using. This table shows which Soter entity you contract with.
For United Kingdom data protection purposes we act as a controller in relation to your personal data.
2. Our Principles of Data Protection
Our approach to data protection is built around four key principles. They’re at the heart of everything we do relating to personal data.
Transparency: We take a human approach to how we process personal data by being open, honest and transparent.
Enablement: We enable connections and efficient use of personal data to empower productivity and growth.
Security: We champion industry leading approaches to securing the personal data entrusted to us.
Stewardship: We accept the responsibility that comes with processing personal data.
3. Scope – What Does This Policy Cover?
4. What Data Do We Collect?
Some data will be collected automatically by Our Site and Our Services, other data will only be collected if you voluntarily submit it, for example, when signing up for an Account. Depending upon your use of Our Site and Our Services, We may collect some or all of the following data:
4.2 date of birth;
4.5 weight, height or other body characteristics;
4.6 business/company name;
4.7 job title;
4.9 contact information such as email addresses and telephone numbers;
4.10 company identification number;
4.11 demographic information such as post code, preferences and interests;
4.12 IP address (automatically collected);
4.13 web browser type and version (automatically collected);
4.14 operating system (automatically collected);
4.15 a list of URLs starting with a referring site, your activity on Our Site, and the site you exit to (automatically collected);
4.16 activity information collected from, but not limited to, wearable sensors;
4.17 For SoterTask product purposes we may collect, store and process your physical data through a video processing application.
5. How Do We Use Your Data?
We use your data to provide the best possible products and services to you. This includes:
5.1 Providing and managing your Account;
5.2 Providing and managing your access to Our Site and Our Services;
5.3 Personalising and tailoring your experience on Our Site and Our Services;
5.4 Supplying Our products and services to you;
5.5 Personalising and tailoring Our products and services for you;
5.6 Responding to communications from you;
5.7 Supplying you with email that you have subscribed to (you may unsubscribe or opt-out at any time;
5.8 Market research;
5.9 Analysing your use of Our Site and Our Services to enable Us to continually improve Our Site and Our Services and your user experience.
6. How and Where Do We Store Your Data?
When you visit our websites or use our services, we collect personal data. The ways we collect it can be broadly categorised into the following:
Information you provide to us directly: When you visit or use some parts of our websites and/or services we might ask you to provide personal data to us. For example, we ask for your contact information when you sign up for a free trial, take part in training and events, contact us with questions or request support. If you don’t want to provide us with personal data, you don’t have to, but it might mean you can’t use some parts of our websites or services.
Information we collect automatically: We collect some information about you automatically when you visit our websites or use our services, like your IP address and web browser type and version. We also collect information when you navigate through our websites and services, including what pages you looked at and what links you clicked on. This information is useful for us as it helps us get a better understanding of how you’re using our websites and services so that we can continue to provide the best experience possible (e.g., by personalising the content you see).
Some of this information is collected using cookies and similar tracking technologies.
Information we get from third parties: The majority of information we collect, we collect directly from you. Sometimes we might collect personal data about you from other sources, such as publicly available materials or trusted third parties like our marketing and research partners. We use this information to supplement the personal data we already hold about you, in order to better inform, personalise and improve our services, and to validate the personal data you provide.
Where we collect personal data, we’ll only process it:
- to perform a contract with you, or
- where we have legitimate interests to process the personal data and they’re not overridden by your rights, or
- in accordance with a legal obligation, or
- where we have your consent.
If we don’t collect your personal data, we may be unable to provide you with all our services, and some functions and features on our websites may not be available to you.
If you’re someone who doesn’t have a relationship with us, but believe that a Soter Analytics subscriber has entered your personal data into our websites or services, you’ll need to contact that Soter Analytics subscriber for any questions you have about your personal data (including where you want to access, correct, amend, or request that the user delete, your personal data).
7. Do We Share Your Data?
There will be times when we need to share your personal data with third parties. We will only disclose your personal data to:
- other companies in the Our group of companies
- your employer, if Our agreement with your employer states for the data to be shared
- third party service providers and partners who assist and enable us to use the personal data to, for example, support delivery of or provide functionality on the website or services, or to market or promote our goods and services to you
- regulators, law enforcement bodies, government agencies, courts or other third parties where we think it’s necessary to comply with applicable laws or regulations, or to exercise, establish or defend our legal rights. Where possible and appropriate, we will notify you of this type of disclosure
- an actual or potential buyer (and its agents and advisors) in connection with an actual or proposed purchase, merger or acquisition of any part of our business
- other people where we have your consent
We may compile statistics about the use of Our Site and Our Services including data on traffic, usage patterns, user numbers, sales and other information. All such data will be anonymised and will not include any personally identifying information. We may from time to time share such data with third parties such as prospective investors, affiliates, partners and advertisers. Data will only be shared and used within the bounds of the law.
8. International Data Transfers
When we share data, it may be transferred to, processed and stored in , countries other than the country you live in – such as to the Republic of Ireland. These countries may have laws different to what you’re used to. Rest assured, where we disclose personal data to a third party in another country, we put safeguards in place to ensure your personal data remains protected.
9. How We are Keeping It Safe?
Security is a priority for us when it comes to your personal data. We’re committed to protecting your personal data and have appropriate technical and organisational measures in place to make sure that happens.
We only keep your data for as long as We need to in order to use it as described above in section 5, and/or for as long as We have your permission to keep it up to a maximum of 5 years after you last use Our products and services. After 5 years, We will automatically delete your personal data.
11. Your Rights
You also have rights to:
- know what personal data we hold about you, and to make sure it’s correct and up to date
- request a copy of your personal data, or ask us to restrict processing your personal data or delete it
- object to our continued processing of your personal data
- request from us rectification or erasure of personal data
- the right to withdraw consent at any time, without affecting the lawfulness of processing based on consent before its withdrawal
- the right to lodge a complaint with a supervisory authority.
12. How Can You Access Your Data?
You have the legal right to ask for a copy of any of your personal data held by Us (where such data is held). Please contact Us for more details at firstname.lastname@example.org, or using the contact details below in section 15.
Our Site may place and access certain first party Cookies on your computer or device. First party Cookies are those placed directly by Us and are used only by Us. This type of Cookies includes:
Functionality cookies (Necessary Cookies)
We use functionality cookies that support certain functionalities of our website, prevent failures and errors.
There are also cookies set by third parties across our websites and services. Third party cookies enable third party features or functionality to be provided on or through our websites and services, such as advertising, interactive content and analytics. Website analytics refers to a set of tools used to collect and analyse usage statistics, enabling Us to better understand how people use Our Site.
They also enable us to use advertising networks to manage our advertising on other websites. This type of Cookies includes:
Google Analytics (Analytics)
We use Facebook as a medium to talk to customers and to measure effectiveness of campaigns.
We use LinkedIn as a medium to talk to customers and to measure effectiveness of campaigns.
Microsoft Advertising (Analytics)
We use Microsoft Advertising as a medium to help reach new users and measure effectiveness of such campaigns.
We use AdRoll as a medium to help reach new users and measure effectiveness of such campaigns. You can find out more about this service and how AdRoll uses your data at https://help.adroll.com/hc/en-us/articles/360003957591.
Lead Forensics (Analytics)
We use Lead Forensics as a medium to identify anonymous website traffic. You can find out more about this service and how Lead Forensics uses your data at https://www.leadforensics.com/privacy-policy/.
We use Leadfeeder as a medium to identify anonymous website traffic. You can find out more about this service and how Leadfeeder uses your data at https://www.leadfeeder.com/privacy/.
Mailchimp (Analytics and functionality)
We use Mailchimp as a marketing automation platform so we can personalise your experience with us.
14. Contacting Us
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