At CREATION.co we love connecting with and understanding people – whether that’s our contacts, customers, or the healthcare professionals (HCPs) that we observe online. This means that we process a whole range of basic personal information on a day-to-day basis.
1.1 We are committed to safeguarding the privacy of CREATION.co visitors and service users.
1.2 This policy applies where we are acting as a data controller with respect to the personal data of CREATION.co visitors and service users; in other words, where we determine the purposes and means of the processing of that personal data.
1.4 Our website incorporates privacy controls which affect how we will process your personal data. By using the privacy controls, you can specify whether you would like to receive direct marketing communications and limit the publication of your information.
1.5 In this policy, “we”, “us” and “our” refer to Creation Interactive Limited.For more information about us, see Section 13.
2. How we use personal data – specifics
Are you a client, or do you receive insights and information updates from us?
Like all companies, we store and process information about our existing customers, and we also have many contacts in the healthcare industry who have signed up to receive our insights via the CREATION.co Knowledge eJournal and other similar resources.
We follow guidance provided by the UK Information Commissioner’s Office (ICO) when processing your contact information, only using your contact details as you would reasonably expect. CREATION.co does not share your information with any third parties. We have robust policies and processes in place to ensure that your data is protected and well managed.
Are you a healthcare professional?
Our specialism is understanding how HCPs like yourself collaborate online. We are experts in what HCPs are saying on public social media about therapies, products, policy and market access – to read some of our recent research, visit CREATION.co Knowledge.
What information do we process?
In order to identify an HCP we hold a very basic record of the individual’s public online profile (name, screen name, location, language, description). Using CREATION.co’s proprietary technology, with subsequent human review, we confirm whether someone indeed is or is not an HCP.
In addition to this, we may process information that you have made available through your online profile, or which is readily available in the public domain (for example, if you are identified as working at a particular organisation on that organisation’s official website). Our team of analysts only study information that you have posted or that is available on public platforms.
How do we use your information?
Our team of research analysts observe online public conservations to gain insights into HCP views and opinions. For example, we may analyse HCP opinion about established or innovative products or look to understand HCP concerns about a specific policy or market access issue. We may also monitor popular hashtags, conferences, and collaborations.
Who do we share your information with?
CREATION.co works with a range of clients in the healthcare sector, including academic institutions, pharmaceutical companies and public health organisations. Although we generally present insights about trends in an aggregate form, we may also share details of your public online activity.
How can I find out more?
We uphold your rights under the 1998 Data Protection Act and the 2016 General Data Protection Regulations. If you have a public social media account that you use in a professional capacity and would like to find out whether you are included in our database of online HCPs, or to find out more about CREATION.co’s approach to data protection and data management, or to submit a ‘subject access request’, please contact firstname.lastname@example.org.
3. How we use your personal data – general
3.1 In this Section 3 we have set out:
(a) the general categories of personal data that we may process;
(b) [in the case of personal data that we did not obtain directly from you, the source and specific categories of that data];
(c) the purposes for which we may process personal data; and
(d) the legal bases of the processing.
3.2 We may process data about your use of our website and services (“usage data“). The usage data may include your IP address, geographical location, browser type and version, operating system, referral source, length of visit, page views and website navigation paths, as well as information about the timing, frequency and pattern of your service use. The source of the usage data is Google Analytics. This usage data may be processed for the purposes of analysing the use of the website and services. The legal basis for this processing is consent OR our legitimate interests, namely monitoring and improving our website and services.
3.3 We may process your account data (“account data“). The account data may include your name and email address. The source of the account data is you or your employer. The account data may be processed for the purposes of operating our website, providing our services, ensuring the security of our website and services, maintaining back-ups of our databases and communicating with you. The legal basis for this processing is consent OR the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract.
3.4 We may process information relating to our customer relationships, including customer contact information (“customer relationship data“), see Section 2. The customer relationship data may include your name, your employer, your job title or role, your contact details, and information contained in communications between us and you or your employer. The source of the customer relationship data is you or your employer. The customer relationship data may be processed for the purposes of managing our relationships with customers, communicating with customers, keeping records of those communications and promoting our products and services to customers. The legal basis for this processing is consent OR our legitimate interests.
3.5 We may process information that you provide to us for the purpose of subscribing to our email notifications and/or newsletters (“notification data“). The notification data may be processed for the purposes of sending you the relevant notifications and/or newsletters. The legal basis for this processing is consent.
3.6 We may process information contained in or relating to any communication that you send to us (“correspondence data“). The correspondence data may include the communication content and metadata associated with the communication. Our website will generate the metadata associated with communications made using the website contact forms. The correspondence data may be processed for the purposes of communicating with you and record-keeping. The legal basis for this processing is our legitimate interests, namely the proper administration of our website and business and communications with users.
3.7 Please do not supply any other person’s personal data to us, unless we prompt you to do so.
4. Providing your personal data to others
4.1 We may disclose your personal data to any member of our group of companies (this means our subsidiaries, our ultimate holding company and all its subsidiaries) insofar as reasonably necessary for the purposes of communication.
5. Retaining and deleting personal data
5.1 This Section 6 sets out our data retention policies and procedure, which are designed to help ensure that we comply with our legal obligations in relation to the retention and deletion of personal data.
5.2 Personal data that we process for any purpose or purposes shall not be kept for longer than is necessary for that purpose or those purposes.
5.3 Notwithstanding the other provisions of this Section 6, we may retain your personal data where such retention is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.
6.1 We may update this policy from time to time by publishing a new version on our website.
6.2 You should check this page occasionally to ensure you are happy with any changes to this policy.
6.3 We may notify you of significant changes to this policy by email or through our website.
7. Your rights
7.1 In this Section 7, we have summarised the rights that you have under data protection law. Some of the rights are complex, and not all of the details have been included in our summaries. Accordingly, you should read the relevant laws and guidance from the regulatory authorities for a full explanation of these rights.
7.2 Your principal rights under data protection law are:
(a) the right to access;
(b) the right to rectification;
(c) the right to erasure;
(d) the right to restrict processing;
(e) the right to object to processing;
(f) the right to data portability;
(g) the right to complain to a supervisory authority; and
(h) the right to withdraw consent.
7.3 You have the right to confirmation as to whether or not we process your personal data and, where we do, access to the personal data, together with certain additional information. That additional information includes details of the purposes of the processing, the categories of personal data concerned and the recipients of the personal data. Providing the rights and freedoms of others are not affected, we will supply to you a copy of your personal data.
7.4 You have the right to object to our processing of your personal data for direct marketing purposes (including profiling for direct marketing purposes). If you make such an objection, we will cease to process your personal data for this purpose.
7.5 You have the right to object to our processing of your personal data for scientific or historical research purposes or statistical purposes on grounds relating to your particular situation, unless the processing is necessary for the performance of a task carried out for reasons of public interest.
7.6 To the extent that the legal basis for our processing of your personal data is:
(a) consent; or
(b) that the processing is necessary for the performance of a contract to which you are party or in order to take steps at your request prior to entering into a contract,
and such processing is carried out by automated means, you have the right to receive your personal data from us in a structured, commonly used and machine-readable format. However, this right does not apply where it would adversely affect the rights and freedoms of others.
7.7 If you consider that our processing of your personal information infringes data protection laws, you have a legal right to lodge a complaint with a supervisory authority responsible for data protection. You may do so in the EU member state of your habitual residence, your place of work or the place of the alleged infringement.
7.8 To the extent that the legal basis for our processing of your personal information is consent, you have the right to withdraw that consent at any time. Withdrawal will not affect the lawfulness of processing before the withdrawal.
7.9 You may exercise any of your rights in relation to your personal data by written notice to us, in addition to the other methods specified in this Section 12.
8. About cookies
8.1 A cookie is a file containing an identifier (a string of letters and numbers) that is sent by a web server to a web browser and is stored by the browser. The identifier is then sent back to the server each time the browser requests a page from the server.
8.2 Cookies may be either “persistent” cookies or “session” cookies: a persistent cookie will be stored by a web browser and will remain valid until its set expiry date, unless deleted by the user before the expiry date; a session cookie, on the other hand, will expire at the end of the user session, when the web browser is closed.
8.3 Cookies do not typically contain any information that personally identifies a user, but personal information that we store about you may be linked to the information stored in and obtained from cookies.
9. Cookies that we use
10. Cookies used by our service providers
11. Managing cookies
11.1 Most browsers allow you to refuse to accept cookies and to delete cookies. The methods for doing so vary from browser to browser, and from version to version. You can however obtain up-to-date information about blocking and deleting cookies via these links:
(a) https://support.google.com/chrome/answer/95647?hl=en (Chrome);
(b) https://support.mozilla.org/en-US/kb/enable-and-disable-cookies-website-preferences (Firefox);
(c) http://www.opera.com/help/tutorials/security/cookies/ (Opera);
(d) https://support.microsoft.com/en-gb/help/17442/windows-internet-explorer-delete-manage-cookies (Internet Explorer);
(e) https://support.apple.com/kb/PH21411 (Safari); and
(f) https://privacy.microsoft.com/en-us/windows-10-microsoft-edge-and-privacy (Edge).
11.2 Blocking all cookies will have a negative impact upon the usability of many websites.
11.3 If you block cookies, you will not be able to use all the features on our website.
12. Our details
12.1 This website is owned and operated by Creation Interactive Limited.
12.2 We are registered in England and Wales under registration number 3543711, and our registered office is at Raigersfeld, Maidstone ME14 4AE.
12.3 Our principal place of business is at Maidstone House, King Street, Maidstone, ME15 6JQ
12.4 You can contact us:
(a) by post, to the postal address given above;
(b) using our website contact form;
(c) by email, using email@example.com.
13. Data protection officer
13.1 Our data protection officer’s contact details are Luke Wilson and can be contacted in the ways listed in section 12.