Privacy Policy

INTRODUCTION
Everyone has rights with regard to the way in which their personal data is handled. Focal Software LTD are committed to protecting and respecting your privacy. During the course of our business activities we will collect, store and process personal data about our clients, employees and other healthcare professionals who use our services. We recognise that the correct and lawful treatment of this data will promote confidence in our organisation.
This policy sets out the basis on which any personal information we collect from you, or you provide to us will be processed by us. Types of personal data that we may be required to handle includes information about current, past and prospective clients, employees and other healthcare professionals that we communicate with. This personal data may be held on paper, on a computer or other media. Please read the following carefully to understand our views and practices regarding your personal information and how it will be treated.

Focal Software LTD (registered in England under company number 10600068). For more details about Focal Software LTD, please visit www.focal.software
This privacy notice is issued on behalf of the Focal Software LTD so when we mention "we", "us" or "our" in this privacy notice, we are referring to Focal Software LTD responsible for controlling and processing your data. Focal Software LTD is the controller responsible for this website.

DATA PROTECTION PRINCIPLES
When processing your information, we must comply with the six enforceable principles of good practice. These state that your personal information must be:

processed lawfully, fairly and in a transparent manner,
processed for specified, explicit and legitimate purposes,
adequate, relevant and limited to what is necessary,
accurate and kept up-to-date,
kept for no longer than is necessary, and
processed in a manner that ensures appropriate security.

INFORMATION YOU GIVE TO US
We may collect, use, store and transfer different kinds of personal information about you, including:

Information that you provide by filling in forms on our Website. This includes information provided at the time of registering to use our Website, posting material or requesting further services.
If you contact us, we may keep a record of that correspondence.
Details of transactions or enquiries you make with us through our Website, email, telephone, letters or otherwise.
Details of your visits to our website including, but not limited to, traffic data, location data, weblogs, and other communication data whether this is required for our bulling purposes or otherwise and the resources that you access.

'SPECIAL CATEGORY' DATA
This include information relating to your racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, health, criminal convictions, sex life or sexual orientation, or certain types of genetic or biometric data is known as ‘special category’ data.
During the course of dealing with you, we do not expect to collect any ‘special category’ data about you.

HOW WE COLLECT YOUR PERSONAL INFORMATION
We may obtain personal information by directly interacting with you, such as:

creating an account on our website,
entering into an agreement with us for products or services,
subscribing to our services or publications, or otherwise requesting marketing material to be sent to you, or
corresponding with us by phone, email, letters or otherwise.
We may obtain personal information via automated technology when you interact with our website by using cookies, server logs and other similar technologies.

THE LEGAL BASIS FOR OUR USE OF YOUR PERSONAL INFORMATION
We will only use your personal information when the law allows us to. Most commonly, we will use your personal information in the following circumstances:

you have given us consent,
we need to perform a contract we are about to enter into, or have entered into, with you,
where it is necessary for our or a third party’s legitimate interests, and your interests and rights do not override those interests, or
where we need to comply with a legal or regulatory obligation.

Particular purposes for which we will use your personal information, and the legal basis for that use, are as follows:

*Purposes for which we will use the information you give to us*	*Legal basis*
Where you are acting as a representative of an organisation, then to register that organisation as a new customer	It will be necessary for our legitimate business interests, namely with a view to providing products and services to your organisation
Where you are acting as a representative of an organisation, to process your instructions and, if accepted, to provide products and services to your organisation (including managing payments, fees and charges)	It will be necessary for our legitimate business interests, namely with a view to providing products and services to your organisation
To obtain further information about you and/or your organisation	It will be necessary for our legitimate business interests, namely to ensure we are fully aware of all issues relating to the products and services we are providing

We will only use your personal information for the purpose(s) 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 we need to use your personal information 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 information without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

IF YOU CANNOT OR WILL NOT PROVIDE US WITH YOUR PERSONAL INFORMATION
Without your personal information, we cannot register you or your organisation (as the case may be) as a new customer. That means that we will be unable to provide you or your organisation with any products or services.

DISCLOSURE OF YOUR INFORMATION
We may share your personal information with the parties set out below:

public bodies and regulatory authorities,
providers of IT and system administration services to our business,
our professional advisers,
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 information in the same way as set out in this policy.

We require all third parties to respect the security of your personal information and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal information for their own purposes and only permit them to process your personal information for specified purposes and in accordance with our instructions.

KEEPING YOUR PERSONAL INFORMATION SECURE
All information you provide to us is encrypted and transferred securely using the latest in Secure Server Language and is stored on servers within the United States of America.
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. Our servers are secured by security patrols, keycard access, biometric hand and fingerprint identification, and 3rd-party alarm monitoring, with data centre activity recorded and footage archived for 90 days. Data is maintained and backed up regularly, with sensitive data (e.g. passwords) encrypted using md5/SHA1 encrypting technologies.
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 (Information Commissioners Office) of a breach where we are legally required to do so.

HOW LONG WE WILL STORE YOUR PERSONAL INFORMATION
The length of time that we will store your data will depend on the ‘legal basis’ for why we are using that data, as follows:

*Legal basis*	*Length of time*
Where we use/store your data because it is necessary for the performance of the contract between you and us	We will use/store your data for as long as it is necessary for the performance of the contract between you and us
Where we use/store your data because it is necessary for us to comply with a legal obligation to which we are subject	We will use/store your data for as long as it is necessary for us to comply with our legal obligations
Where we use/store your data because it is necessary for our legitimate business interests	We will use/store your data until you ask us to stop. However, if we can demonstrate the reason why we are using/storing your data overrides your interests, rights and freedoms, then we will continue to use and store your data for as long as it is necessary for the performance of the contract between you and us (or, if earlier, we no longer have a legitimate interest in using/storing your data)
Where we use/store your data because you have given us your specific, informed and unambiguous consent	We will use/store your data until you ask us to stop

To determine the appropriate retention period for personal information, we consider the amount, nature and sensitivity of the personal information, the potential risk of harm from unauthorised use or disclosure of your personal information, the purposes for which we process your personal information and whether we can achieve those purposes through other means, and the applicable legal requirements.

YOUR RIGHTS
You have various legal rights in relation to the information you give us, or which we collect about you, as follows:
You have a right to access the information we hold about you, together with various information about why and how we are using your information, to whom we may have disclosed that information, from where we originally obtained the information and for how long we will use your information.
You have the right to ask us to rectify any information we hold about you that is inaccurate or incomplete.
You have the right to ask us to erase the information we hold about you (the ‘right to be forgotten’). Please note that this right can only be exercised in certain circumstances and, if you ask us to erase your information and we are unable to do so, we will explain why not.
You have the right to ask us to stop using your information where: (i) the information we hold about you is inaccurate; (ii) we are unlawfully using your information; (iii) we no longer need to use the information; or (iv) we do not have a legitimate reason to use the information. Please note that we may continue to store your information, or use your information for the purpose of legal proceedings or for protecting the rights of any other person.
You have the right to ask us to transmit the information we hold about you to another person or company in a structured, commonly-used and machine-readable format. Please note that this right can only be exercised in certain circumstances and, if you ask us to transmit your information and we are unable to do so, we will explain why not.
Where we use/store your information because it is necessary for our legitimate business interests, you have the right to object to us using/storing your information. We will stop using/storing your information unless we can demonstrate why we believe we have a legitimate business interest which overrides your interests, rights and freedoms.
Where we use/store your data because you have given us your specific, informed and unambiguous consent, you have the right to withdraw your consent at any time.
You have the right to object to us using/storing your information for direct marketing purposes.
If you wish to exercise any of your legal rights, please contact our Privacy Office by writing to the address at the top of this policy, or by emailing us at GDPR@focal.software
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 may 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.
We try to respond to all legitimate requests within one month. Occasionally, it may 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.

COOKIES AND HOW WE USE THEM
What is a Cookie?
A cookie is a small text file that stores Internet settings. The cookie is downloaded by your Internet browser the first time you visit a website.
Some cookies are extremely useful because they can improve your user experience when you return to a website you have already visited. This assumes that you are using the same device and the same browser as before; if so, cookies will remember your preferences, will know how you use the website, and will adapt the content you are shown so that it is more relevant to your personal interests and needs.
Types of Cookies
There are four categories of cookies:
Strictly necessary cookies are essential in order to enable you to move around the website and use its features. Without these cookies, some services cannot be provided – for example, remembering previous actions when navigating back to a page in the same session.
Performance cookies gather information about how a website is used – for example, which pages a visitor frequently visits. These cookies do not save personal information or information that would allow the user to be identified. These cookies are used exclusively to improve the performance of the website, and with it the user experience.
Functional cookies enable a website to save information which has already been entered (such as user names, languages choices, and your location), so that it can offer you improved and more personalised functions. These cookies collect anonymous information and cannot track your movements on other websites.
Marketing cookies are used to deliver adverts and other communications more relevant to you and your interests. They are also used to limit the number of times you see an advertisement and to help measure the effectiveness of advertising campaigns.

Managing the use of Cookie settings on this website
While you can completely disable some cookies in your browser at any time, it is important to note that if you change your settings and block certain cookies, you will not be able to take full advantage of some features of our site.
Cookies that are essential, also known as ‘strictly necessary’ cookies, enable features without which you would not be able to use the website as intended. These Cookies are only saved on your computer while you are actually browsing the website and for the duration of the session. Strictly necessary cookies cannot be disabled.

OPTING OUT OF RECEIVING COMMUNICATIONS
You can ask us to stop sending you communications at any time by contacting us on support@focal.software

AUTOMATED DECISION-MAKING
We do not use automated decision-making processes.

LINKS TO OTHER WEBSITES
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 notice of every website you visit.

CHANGES TO OUR POLICY
The contents of this policy may change from time to time, so you may wish to check this page occasionally to ensure you are still happy to share your information with us. Where possible, we may also contact you directly to notify you of these changes.