6. 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.

7. Sharing your personal data

We may share your personal data with the parties set out below for the purposes set out in the table above:

• Providers of third party applications, including Hubspot, Typeform, Mailchimp, Zendesk, Google, Twilio, MMGPR, and Mixpanel which may be based in the United Kingdom or outside the United Kingdom.
• Professional advisers including lawyers, accountants, auditors and insurers based in the United Kingdom who provide legal, insurance and accounting services.
• HM Revenue & Customs, regulators and other authorities 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, with appropriate data protection safeguards are in place including data processing agreements.

8. International transfers

Certain of our services providers are based outside of the UK. Whenever we transfer your personal data out of the UK, we ensure a similar degree of protection is afforded to it by ensuring that the countries have been deemed to provide an adequate level of protection for personal data.

9. Data retention and security

We retain your personal data for as long as reasonably necessary to fulfil the purposes for which it was collected, including for the purposes of satisfying any legal, 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.

We will retain your Identity Data, Contact Data, Profile Data and Usage Data for 6 years from the date you cease to be a user of our System. This is to enable us to deal with any contractual claims by or against you, and/or by or against the NHS organisation which has authorised you as a user of the System.

We may retain your Identity Data, Contact Data, Profile Data and Usage Data for a longer period:

• to match any period which we are required to keep any Related Data (whether by Law or by the terms of any data processing agreement between us and the NHS organisation which has authorised you as a user of the System); or
• to match any period of retention we otherwise apply to the Related Data, where we reasonably believe there is a prospect of litigation for which the Related Data may be relevant;

and in either case, this is because your Identity Data, Contact Data, Profile Data and you Usage Data may be required in the event of a claim or complaint involving the Related Data, and for the purposes of which Related Data means the clinical data which you have inputted, accessed, disclosed or received in your capacity as a user on behalf of the NHS organisation which has authorised you as a user of the System, and in respect of which that NHS Organisation acts as controller, and we act as processor.

We will retain your Technical Data for 1 year, subject to any alternative period which is expressed to apply to any such data where it is collected by any of the cookies specified further below. We may in any event, 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.

We use appropriate security measures to protect your personal data from unauthorized access, use, or disclosure. 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.

10. Changes to this notice and your duty to inform us of changes

We keep our privacy policy under regular review and may update this privacy notice from time to time to reflect changes in our information practices. We encourage you to review this privacy notice periodically. This version was last updated on 28 June 2023.

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.

11. Third-party links

Our website 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.

12. Data Protection Officer

We have appointed a data protection officer (DPO) who is responsible for overseeing questions in relation to this privacy policy. If you have any concerns about our data processing practices or any questions about the information we hold about you or any questions about this privacy policy, including any requests to exercise your legal rights, please contact our DPO using the details below.

13. Contact Us

The contact details for our DPO are as follows:

• Email: dpo@cinapsis.com
• Postal Address: Cinapsis, Profile West, Suite 2, Great West Road Brentford, England TW8 9ES

14. Your Rights Under GDPR

Under certain circumstances, you have rights under data protection laws in relation to your personal data.

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 could refuse to comply with your request in these circumstances.

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.

You have the right to:

(a) 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.
(b) 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.
(c) 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.
(d) 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.
(e) 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.
• You have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.

(f) 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.
(g) 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.

15. NHS Care Identity credentials

Please note that if you access our service using your NHS Care Identity credentials, the identity access and management services are managed by NHS Digital. NHS Digital is the controller for any personal information you provided to NHS Digital to get a national digital identity and authenticate your claim to that identity, and uses that personal information solely for that single purpose. For any personal information, our role is a “processor” only and we must act under the instructions provided by NHS Digital (as the “controller”) when verifying your identity. To see NHS Digital’s Privacy Notice and Terms and Conditions, please click [https://digital.nhs.uk/services/identity-and-access-management/nhs-care-identity-service-2/care-identity-authentication]. This restriction does not apply to the personal information you provide to us separately which is managed in accordance with our Privacy Policy.

16. Use of Cookies

We use cookies and similar technologies like pixels, tags, and other identifiers to help us personalise this website and the System for you, understand how users are using our website, and help customise our communications. By visiting this website and using the System, you agree to the use of cookies and similar technologies for the purposes described in this Privacy Notice.

A cookie is a small data file that is stored on your device that allows us to recognise your device when you return to our service.

We use the following types of cookies:

• Essential Cookies: These are required for the operation of the System and website. They include, for example, cookies that enable you to log into secure areas of our System and website.
• Analytical/Performance Cookies: They allow us to monitor and improve performance for users.
• Functionality Cookies: These are used to recognise you when you return, enabling us to personalise our content for you and remember your preferences.
• Targeting Cookies: These cookies record your visit, pages you have visited and links you have followed. We use this information to make the content you see more relevant.

In particular, we use the following specific cookies:

• user session cookie - expires when the user's session ends.
• mixpanel cookie - expires in 1 year from the date added.
• device ID cookie - this is for tracking user's device ID (on both mobile and desktop) - expires in 3 months from the date added.
• login "remember me" cookie - expires in 3 months from the date added.

We may use third-party cookies as well. For example, we use Google Analytics to understand how our users navigate through our website at (www.cinapsis.org) and interact with our content.

Most web browsers automatically accept cookies, but you can usually modify your browser setting to decline cookies if you prefer. This may prevent you from taking full advantage of the website. Please consult the "Help" section of your browser for more information on how to manage your cookie settings.

However, if you use your browser settings to block all cookies (including essential cookies) you may not be able to access all or parts of our website and/or System.

7 November 2023