Haelu Ltd (trading as Cliniconex UK) respects your privacy and is committed to protecting your personal data. This privacy notice will inform you as to how we look after your personal data when you visit our website or when you use, purchase or enquire about any of our services or products and will tell you about your privacy rights and how the law protects you.
This website is not intended for children and we do not knowingly collect data relating to children.
Haelu Ltd (trading as Cliniconex UK) (a company registered in England and Wales with company number 12684134 and whose registered office is at Wesley Clover Innovation Centre, Coldra Wood, Chepstow Road, Newport, Wales, NP18 2YB) (“we”, “us” or “our”) is the controller and is responsible for your personal data. This website is owned by our partner, Cliniconex Inc. (a company incorporated and registered in Canada with company number 721749-8 whose registered office is at 400 March Rd, Kanata, ON, K2K 3H4), with whom we may share your personal data for the purposes set out in this policy (please see the section headed “Disclosures of your personal data” below for more information).
Please note that where we provide services to a customer, Haelu ltd is the data processor, and the customer is the data controller, of any third-party personal data the customer provides to us (such as personal data of a care resident name) to enable us to provide certain features of our services. The data processing provisions governing our use of such personal data and our duties as a data processor will be governed by the terms of our agreement with each customer, which will be compliant with applicable data protection laws. The customer must not input, upload, provide or otherwise make available to or through the services any Third-Party Data unless the customer has a legal right to do so.
It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.
2. The Data We Collect About You
We may collect, use, store and transfer different kinds of personal data about you as follows:
- Identity Data includes first name, last name, title.
- Contact Data includes email addresses and telephone numbers.
- Employment Data includes workplace, job title and employer details.
- Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access this website.
- Usage Data includes information about how you use our website and/or services and any feedback given to us with respect to our website and/or services, for example as to their suitability, problem reports, suggestions and any other information.
- Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.
We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.
3. How Is Your Personal Data Collected?
We use different methods to collect data from and about you including through:
- Information you give us. You may give us your Identity, Contact and Employment Data by filling in forms on our website or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you book a demo through our website, apply for our products or services, request marketing to be sent to you, give us feedback or contact us.
- Information we receive from other sources. We may receive personal data about you from various third parties and public sources, including Cliniconex Inc. where you raise an enquiry directly with them.
4. How We Use Your Personal Data
- Where we need to perform the contract we are about to enter into or have entered into with you.
- Where you have consented before the processing.
- 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 obligation or regulatory obligation.
5. 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.
|Purpose/Activity||Type of data||Lawful basis for processing including basis of legitimate interest|
|To record, respond to and deal with any correspondence you have sent to us||(a) Identity
(b) Necessary for our legitimate interests (for running our business)
|To process and deliver your request and/or order and to manage our relationship with you||(a) Identity
(c) Employment (d) Marketing and Communications (e) Usage
|(a) Performance of a contract
(b) Necessary for our legitimate interests (for running our business and to study how customers use our products/services)
|To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)||(a) Identity
|(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
(d) Marketing and Communications (e) 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
|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 about goods or services that may be of interest to you||(a) Identity
(e) Marketing and Communications
|Necessary for our legitimate interests (to develop our products/services and grow our business)|
We may use your Identity, Contact, Technical and Usage 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 may receive marketing communications from us if you have requested information from us or purchased services from us and you have not opted out of receiving that marketing.
We will get your express opt-in consent before we share your personal data with any third party for marketing purposes.
You can ask us or third parties to stop sending you marketing messages at any time 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 order.
Change of purpose
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.
6. Disclosures Of Your Personal Data
We may share your personal data with the parties set out below for the purposes set out in the table above:
- Our partner companies, including Cliniconex Inc.
- Our third-party service providers, including IT, communications and software service providers and scheduling, marketing and administration service providers including Calendly, CloudTalk, Hubspot, Zoom and Google Workspace.
- Professional advisers including lawyers, bankers, auditors and insurers based in the UK who provide consultancy, banking, legal, insurance and accounting services.
- HM Revenue and Customs, regulators and other authorities based in the UK who require reporting of processing activities in certain circumstances.
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
7. International Transfers
Some of the parties with whom we share your personal data are based outside the UK and the European Economic Area (EEA), including Cliniconex Inc. who are based in Canada, so their processing of your personal data will involve a transfer of data outside the UK and the EEA.
Whenever we transfer your personal data out of the UK and 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 or UK government (to the extent applicable). Such countries include Canada where the personal data to be transferred is subject to Canada’s Personal Information Protection and Electronic Documents Act.
- Where we use certain service providers, we may use specific contracts approved by the European Commission or UK government (to the extent applicable) which give personal data the same protection it has in Europe or the UK (to the extent applicable).
8. Data Security
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.
9. Data Retention
How long will you use my personal data for?
We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.
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, regulatory, tax, accounting or other requirements.
Details of retention periods for different aspects of your personal data are set out in the table below.
|Type of Personal Data||Retention Period|
|Identity, Contact, Employment and Transaction Data||2 years from last contact|
|Technical Data||2 years|
|Marketing and Communication Data||2 years from last contact|
10. Your Legal Rights
Under certain circumstances, you have the following rights under data protection laws in relation to your personal data.
- 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.
- 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:
- if you want us to establish the data’s accuracy;
- where our use of the data is unlawful but you do not want us to erase it;
- 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
- 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.
- 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.
You can also ask us or third parties to stop sending you marketing messages 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 or other transactions. You can exercise any of these rights at any time by contacting us using the details set out below
11. Contacting Us And Complaints
- Company details: Haelu Ltd trading as Cliniconex UK (a company registered in England and Wales with company number: 12684134)
- Email address: firstname.lastname@example.org
- Postal address: Wesley Clover Innovation Centre, Coldra Wood, Chepstow Road, Newport, Wales, NP18 2YB
You also 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. We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.