EnteroBiotix Privacy Policy
Last updated: November 2022
Introduction
Welcome to EnteroBiotix’ privacy policy. EnteroBiotix is committed to protecting your privacy and your personal data. This policy explains what personal data we collect from (i) individuals visiting enterobiotix.com (‘EnteroBiotix Website’), (ii) individuals and donors visiting number2.org and donors accessing the Number 2 App (‘Number 2 Website and App’); and (ii) individuals visiting insidematters.health (‘Inside Matters Website’) (collectively the ‘EnteroBiotix Sites’), and how we use it.
Important information and who we are
EnteroBiotix Limited (registered number SC559230), is the controller and is responsible for your personal data, collected both as EnteroBiotix Ltd and under trading names: Number2.org and Insidematters.health (collectively referred to as ‘EnteroBiotix’, ‘we’, ‘us’, or ‘our’ in this Privacy Policy).
We have appointed a data protection office (DPO) who is responsible for overseeing questions in relation to this Privacy Policy. If you have any questions about this privacy policy or our privacy practices, please contact our DPO in the following ways:
Full name of legal entity: EnteroBiotix Limited
Address: 1 West Regent Street, Glasgow, Scotland, G2 1AP
Email address: dpo@enterobiotix.com
You have the right to make a complaint at any time to the Information Commissioner's Office (ICO), the UK regulator 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.
The EnteroBiotix Sites 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.
Key terms
Personal Data
Any information relating to an identified or identifiable individual
Special Categories of Personal Data
Personal information revealing your racial or ethnic origin; political opinions; religious or philosophical beliefs; or trade union membership; genetic data; biometric data; data related to your health or data concerning your sex life or sexual orientation; and criminal convictions or involvement in criminal proceedings
The data we collect about you
We will collect, store, and use the following categories of Personal Data about you as part of your use of the EnteroBiotix Sites:
Identity Data: first name, last name, username, job title, marital status, date of birth, gender and photographs.
Contact Data: postal address, telephone number and email address.
Financial Data: bank account and payment card details.
Technical Data: IP address, login data, browser plug-in, operating systems and other technology on the devices used to access the EnteroBiotix Sites.
Usage Data: information about your use of the EnteroBiotix Sites and services provided by EnteroBiotix, including the donation scheme (‘Services’).
Profile Data: username and password, feedback and survey responses.
Marketing and Communications Data: includes your preferences in receiving marketing from us and our third parties and your communication preferences.
Personal Data does not include data where the identity has been removed (anonymous data). There are certain types of more sensitive personal data which require a higher level of protection, such as information about a person’s health or sexual orientation, known as Special Categories of Personal Data.
We may also collect Special Categories of Personal Data in the donor registration process via the Number 2 Website and App including health information, such as:
History of sexually transmitted diseases;
General medical history;
Whether you smoke;
Body mass index and weight;
Alcohol/drug history;
Current medicine you take;
as well as other forms of Special Category Personal Data, such as details about your nationality.
In terms of the health data that we may collect from you, please note that we work within strict MHRA guidelines and must ensure patient safety is maintained at all times.
How is your personal data collected?
Direct Interactions: You may give us your Identity and Contact data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
sign up to be a donor on the Number 2 Website;
create an account on the Number 2 App;
contact us via the contact details listed on EnteroBiotix Website, Number 2 Website or Inside Matters Website;
apply for a job via the EnteroBiotix Website;
give us feedback.
Automated technologies or interactions. As you interact with the EnteroBiotix Sites, we will automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies and other similar technologies. Please see our cookie policy for further details.
Third party sources. We will receive personal data about you from various third parties, including as set out below:
Smart Survey (Basepoint Business Centre, Oakfield Close, Tewkesbury, Gloucestershire, GL20 8SD), the survey provider used to collect data from donors when registering to be a donor on the Number 2 Website.
How we will 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 you have provided clear consent for us to process your personal data for the purposes of conducting research.
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.
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.
In addition to the below ways we plan to process your Personal Data, we may also process your Personal Data where this is required or permitted by law.
EnteroBiotix website
| Purpose/activity | Type of data | Lawful basis for processing |
|---|---|---|
| To communicate with you regarding your query | a) Identity Data b) Contact Data |
Legitimate Interests (Necessary to use the data provided by you to respond to your query and provide you with the information requested (if any)) |
| To process the information provided by you in your CV and job application when applying for a position advertised on the EnteroBiotix Website | a) Identity Data b) Contact Data | Performance of a Contract (Necessary steps required before entering into a contract with the applicant) |
| To administer and protect our business and the EnteroBiotix Website including troubleshooting, data analysis and system testing | a) Identity Data b) Contact Data c) Technical Data | Legitimate Interests (for running our business, provision of administration and IT services, network security) |
| To use data analytics to improve the EnteroBiotix Website and customer relationships | a) Technical Data d) Usage Data | Legitimate Interest (to define types of users visiting the Website, to keep our Website updated and relevant, to develop our business) |
| For the general running of our business and the EnteroBiotix Website | b) Identity Data c) Contact Data d) Technical Data e) Profile Data f) Usage Data | Legitimate Interests (for running our business) |
Number 2 Website and App
| Purpose/activity | Type of data | Lawful basis for processing |
|---|---|---|
| To process the information provided when applying to be a donor on the Number 2 Website and to determine whether you are eligible to be a donor. | a) Identity Data b) Contact Data c) Special Categories of Data (e.g. information about your health) |
Legitimate Interests (Necessary to use the data provided by you to assess your eligibility to be a donor) Consent |
| To communicate with you to inform of you of details of the screening session/approved application if you are eligible to be a donor, including processing any expenses incurred by the donor. | a) Identity Data b) Contact Data c) Financial Data |
Legitimate Interests (Necessary to use the data provided by you to process the donation and conduct our research)> |
| To process information provided by you during the donation process, submitted via the medical questionnaire and by other means. | Special Categories of Data (e.g. information about your health) | Legitimate Interests (Necessary to use the data provided by you to process the donation and conduct our research) Consent |
| To register you as an App user if you are eligible to be a donor | a) Identity Data b) Contact Data c) Profile Data | Legitimate Interests (Necessary to progress your application to be a donor) |
| To manage our relationship with you, including notifying you of changes to the App or donation process | a) Identity Data b) Contact Data c) Profile Data |
Necessary to comply with our legal obligations (to inform you of any changes to our terms) Legitimate Interests (Necessary to communicate with your regarding your donations) |
| To administer and protect our business and the Number 2 Website and App including troubleshooting, data analysis and system testing | c) Identity Data d) Contact Data e) Technical Data |
Legitimate Interests (for running our business, provision of administration and IT services, network security) |
| To enable you to complete surveys and provide feedback | a) Identity b) Contact c) Profile d) Usage e) Marketing and Communications |
Legitimate Interests (to study how users use the Website and App, to develop our services and grow our business) |
| To use data analytics to improve our Website and App, Services and customer relationships | g) Technical Data h) Usage Data |
Legitimate Interest (to define types of users visiting the Website and App, to keep our Website updated and relevant, to develop our business) |
| For the general running of our business and the Number 2 Website | i) Identity Data j) Contact Data k) Technical Data l) Profile Data m) Usage Data |
Legitimate Interests (for running our business) |
Inside Matters Website
| Purpose/activity | Type of data | Lawful basis for processing |
|---|---|---|
| To communicate with you regarding your query | a) Identity Data b) Contact Data |
Legitimate Interests (Necessary to use the data provided by you to respond to your query and provide you with the information requested (if any)) |
| To administer and protect our business and the Inside Matters Website including troubleshooting, data analysis and system testing | f) Identity Data g) Contact Data c) Technical Data |
Legitimate Interests (for running our business, provision of administration and IT services, network security) |
| To use data analytics to improve the Inside Matters Website and customer relationships | n) Technical Data d) Usage Data | Legitimate Interests (to define types of users visiting the Website, to keep our Website updated and relevant, to develop our business) |
| For the general running of our business and the Inside Matters Website | o) Identity Data p) Contact Data q) Technical Data r) Profile Data s) Usage Data |
Legitimate Interests (for running our business) |
Marketing
We strive to provide you with choices regarding certain Personal Data uses, particularly around marketing and advertising. We do not currently send out marketing, however we request information from you on via the registration form on our Number2 Website relating to where you have heard of us from in order that we can further target those media sites for future marketing of our services.
If we do start to send out marketing, you will only receive communications if you have requested information from us and you have not opted out of receiving that marketing.
Cookies
Please see our Cookie Policy for further details on how we use cookies on the EnteroBiotix Sites.
Automated decision making
The application survey used to assess whether an individual is eligible to be a donor has questions relating to your health that when information is entered it may automatically stop at a particular page in the survey, if some of the critical criteria is not met.
If you fail to provide personal data
If you fail to provide certain information when requested, we may not be able to progress your application as a donor.
Disclosure of your personal data
We may share your data with third parties, including third-party service providers and other entities in our group. We will share your Personal Data with third parties where required by law, where it is necessary to administer the relationship with you or where we have another legitimate interest in doing so.
Such third parties include without limitation:
SmartSurvey Ltd
Google Firebase Firestore
AWS SES
GearedApp Ltd
We only allow our service providers to handle your Personal Data if we are satisfied they take appropriate measures to protect your Personal Data. We also impose contractual obligations on service providers to ensure they can only use your Personal Data to provide services to us and to you.
We may disclose and exchange information with law enforcement agencies and regulatory bodies to comply with our legal and regulatory obligations. We may also disclose health data to your personal doctor.
We may also need to share some Personal Data with other parties, such as potential buyers of some or all of our business or during a re-structuring. Usually, information will be anonymised but this may not always be possible. Only personal data which is strictly relevant and necessary for the purpose of the transaction will be shared. The recipient of the information will be bound by confidentiality obligations.
International transfers
We may transfer the Personal Data outside of the United Kingdom.
Whenever we transfer your personal data out of the UK, 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.
Where we use certain service providers, we may use specific contracts approved for use in the UK which give Personal Data the same protection it has in the UK.
If you require further information about these adequate safeguards, you can request it using our contact details below.
Data security
We have appropriate security measures to prevent Personal Data from being accidentally lost, or used or accessed unlawfully.
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.
Data retention
How long will you use my information 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, regulatory, accounting, or reporting requirements.
To determine the appropriate retention period for your 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 and regulatory requirements.
If we decide that you are not eligible to be a donor under the Number2 Website, or if you do not complete the full survey then all information you provide will be deleted within 30 days.
In some circumstances we may anonymise your Personal Data so that it can no longer be associated with you, in which case we may use such information without further notice to you.
Your rights
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.
You have the following rights:
Access
The right to be provided with a copy of your Personal Data (the right of access).Rectification
The right to require us to correct any mistakes in your Personal Data.Erasure
The right to require us to delete your Personal Data – in certain situations.Restriction of processing
The right to require us to restrict processing of your Personal Data – in certain circumstances, e.g. if you contest the accuracy of the data.Data portability
The right to receive the Personal Data you provided to us, in a structured, commonly used and machine-readable format and/or transmit that data to a third party – in certain situations.To object
The right to object:
at any time to your Personal Data being processed for direct marketing (including profiling); or
in certain other situations to our continued processing of your Personal Data, e.g. processing carried out for the purpose of our legitimate interests.
Not to be subject to automated individual decision-making
The right not to be subject to a decision based solely on automated processing (including profiling) that produces legal effects concerning you or similarly significantly affects you.Withdraw consent
The right to withdraw your consent to us processing your Personal Data at any time if our processing is based on your consent.
For further information on each of those rights, including the circumstances in which they apply, please contact us or see the Guidance from the UK Information Commissioner’s Office (ICO) on individuals’ rights under the UK GDPR.
If you would like to exercise any of the above rights, please email, call or write to us, using the contact details set out in the below section: ‘How to 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 for access is clearly unfounded or excessive. Alternatively, we may refuse to comply with the request in such 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 could 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.
Changes to this privacy policy
We reserve the right to update this Privacy Policy at any time, and we will provide you with a new Privacy Policy when we make any substantial updates. We may also notify you in other ways from time to time about the processing of your Personal Data.
How to contact us
Please contact us by post, email or telephone if you have any questions about this Privacy Policy or the information we hold about you.
Our full details are:
Full name of legal entity: EnteroBiotix Limited
Address: 1 West Regent Street, Glasgow, Scotland, G2 1AP
Email address: dpo@enterobiotix.com