PRIVACY POLICY

Cemplicity Privacy Policy

Effective from: 24 February 2018

Your privacy is very important to us.

This Privacy Policy describes how Cemplicity manages personal data collected when You visit our website, talk by phone or communicate with us by email or in meetings.

In this Privacy Policy, when we say ‘You’ or ‘Your’ we mean You, the organisation You work for and any other employees, contractors and sub-contractors who work for Your organisation.

  1. GENERAL INFORMATION
    1. About Us.
      The Cemplicity group of companies operate in Ireland, The United Kingdom, Australia and New Zealand. We communicate with people and receive visitors to our website from these countries and other countries around the world.

      The Cemplicity company registered in New Zealand is a limited liability company and was incorporated on 27 March, 2013. This company is the owner of Cemplicity Ireland and Cemplicity UK. Cemplicity Australia is a branch of Cemplicity NZ.The details of each company are here:

      CompanyEmail AddressSupervisory Authority
      Cemplicity NZ
      Company number:4382418
      Address:Level 1, 10 Customs St East, Auckland, New ZealandOffice of the Privacy Commissioner
      Email:hello@cemplicity.com
      Contact phone number:0800 157 258
      Cemplicity Australia
      ABN:93554622967
      Address:C/- Cemplicity NZ
      Email:hello@cemplicity.com
      Contact phone number:1800 765 924
      Cemplicity Ireland
      Company number:598107Office of the Data Protection Commissioner.
      Address:32 Merrion Street, Upper Dublin 2Ireland
      Email:hello@cemplicity.com
      Cemplicity UK
      Company number:11122673
      Address:Health Foundry, Canterbury House1 Royal Street

      London SE1 7LL

      Email:hello@cemplicity.com
      Contact phone number:0-800-098-8525


      In this Policy, when we refer to “Cemplicity”, “we”, “us”, “our” we are referring to all these companies unless we state otherwise.

    2. What we do. Cemplicity is a Software-as-a-Service company that works with hospitals, clinics, government departments or agencies and other leaders in the health sector to capture, measure and report on patient feedback.
    3. This Policy.  This Privacy Policy (the “Policy”) sets out important information about how we use information You give us when You contact us or meet with us or that we collect when You visit our website at www.cemplicity.com. We want to make Your rights clear and tell You how we use this information.
    4. Related Documents. If You become a Cemplicity client, your contract with us may include important terms that supersede or expand the terms in this Policy. As a Cemplicity client, both You and we will also have important privacy obligations to Your customers or patients. Cemplicity obligations in our role as a supplier to You are covered in our “Privacy Policy – Surveys” and are also covered in detail in our contracts with clients.
    5. Controller.Cemplicity UK and Cemplicity Ireland, for the purposes of this Policy, are what are known under the General Data Protection Regulation (EU) 2016/679 (the “GDPR”) as the “controller” of the personal data You provide to us.
    6. Contact Us. If You have any queries relating to this Policy or our privacy practices, please contact us at hello@cemplicity.com.
  2. THE INFORMATION WE COLLECT
    We will collect and process the following data about You:

    1. Information You give us.
      This is information about You that You give us by filling in forms on our website or by corresponding with us by phone, e-mail, in meetings or otherwise. It includes information You provide when You use our website, search for a product, participate in blogs or other social media functions on our website. It also includes information you provide when You email or meet with us to discuss our Services, usually prior to entering any contract for services. The information You give us may include Your name, address, email address and phone number and sometimes information on Your company, services or needs.
    2. Information we collect about You on the website.
      When You visit our website we automatically collect the following information:

      • technical information, including your IP address, browser type and version, time zone setting, region and the device you used to visit the website;
      • information about Your visit, including which pages You visited on our website, how You found our website (e.g. which advertisement You clicked on, the search term You used) the date and time of Your visit, products You viewed or searched for, page response times, download errors, length of visits to certain pages and page interaction.
    3. Other Information we receive.
      Like many other companies, we also use third party services such as Adwords, Google Analytics, Salesforce CRM, Active Campaign and independent advertising advisors. When You provide Your contact details on our website or information by email, telephone or on meetings, these may be entered into one of these third party services for storage and analysis but the terms of our use of these third party services precludes them accessing or using any of these details. These services also provide aggregated information on visitor behaviour on our website and Your anonymous information may be included in this. When you use websites like LinkedIn or Facebook you also provide information to these services that they may then make available to advertisers like Cemplicity. (e.g. your position title, employer, location etc.) What information they provide to advertisers is governed by their Privacy terms. If you do not want companies like Cemplicity to see such information, this can be managed through the Privacy settings on their website.
  3. COOKIES
    1. Our website uses cookies from time to time. “Cookies” are small text files which are stored by Your browser on Your computer and are normally used to gather statistical information and to analyse trends of use or access to a website. Cookies cannot be used to run programs or deliver viruses to Your computer.
      1. Cookies may be used to save Your personal preferences so You do not have to re-enter them each time You access the website.
      2. Our cookies will record the number of user sessions on this website and track the number of users who return to the website.
      3. While most browsers automatically accept cookies, You are free to accept or reject our cookies or to ask Your browser to indicate when a cookie is being sent, provided Your browser permits. Each time You visit our website You will be provided the option to stop us using Cookies for Your visit. (If you refuse our cookies remember this may affect your ease of use of the website).
      4. The information created by using cookie technology does not, and cannot be used to, identify or contact You.
      5. When our emails or website include links, these may include tracking code that tells us if you click on the link. Often these cannot identify you personally but just tell us that the link was clicked.
      6. The website may use cookies to promote Cemplicity to You on third party websites. For example, if You visit our website, You may then see an advertisement for the Service on another websites in the future. The cookies do this by recording which browsers have visited our websites – they do not personally identify You.
  4. What we do with Your INFORMATION
    We use information held about You in the following ways:

    1. Information You give to us:
      We will use this information:

      • to provide You with the information, products and services that You request from us;
      • to provide You with information about other goods and services we offer that are similar to those that You have already purchased or enquired about;
      • where You have given us Your consent to do so, to provide You, or permit selected third parties to provide You, with information about goods or services we feel may interest You; and
      • to ensure that content from our website is presented in the most effective manner for You and for Your computer.
    2. Information we collect about You through the website.
      We will use this information:

      1. to administer our website and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes;
      2. to improve our website to ensure that content is presented in the most effective manner for You and for Your computer;
      3. to allow You to participate in interactive features of our service, when You choose to do so;
      4. as part of our efforts to keep our website safe and secure;
      5. to measure or understand the effectiveness of advertising we serve to You and others, and to deliver relevant advertising to You; and
      6. where we have Your consent to do so, to make suggestions and recommendations to You and other users of our website about goods or services that may interest You or them.
    3. Blogs and other public forums.
      Please remember that any information You reveal, including personally identifiable information in a public forum such as a discussion forum, blog or an online chat, is not subject to this Policy and can be seen by third parties unrelated to us. It is therefore important that You carefully consider what information You disclose in these areas.
    4. How long we keep Your information and your rights.
      We will store and report data provided by You for at least 3 years. After this we may delete or archive the data. At any time you can contact us in writing to find out what personal data about You we have stored and to ask us to return, delete or change this data and we will provide reasonable assistance to respond to this request in a timely way. All data requests should be sent to hello@cemplicity.com
    5. More on your rights:
      • Access to Your Information.
        If you would like a copy of Your personal data please email us at hello@cemplicity.com and this will be provided at no cost.
      • Right of Restriction.
        You have the right to restrict us from processing Your personal data where one of the following applies:

        1. You believe the personal data we hold on You is not accurate;
        2. the processing of Your personal data is unlawful and rather than delete it you want to restrict its use;
        3. we no longer need it for the purpose of processing but You require this data for the establishment, exercise or defence of legal claims; or
        4. where You have contested the processing pursuant to Article 21(1) of the GDPR pending the verification of whether our legitimate grounds override those of Yours.
      • Corrections or Erasure (Right to Rectification and Right to Be Forgotten):
        If the purpose for which the personal data were collected or if You withdraw consent for us to process it, You can ask for it to be deleted. This right will not apply where we are required to process personal data in order to comply with a legal obligation or where the processing is carried out for reasons of public interest in the area of public health. You can also request to have Your personal data corrected if it is inaccurate.
      • Right to Object. Where we process personal data on the basis of a legitimate interest, You may object to our processing. Should this occur, we will no longer process it unless doing so is justified by a compelling legitimate ground. If your objection is related to direct marketing, we will stop on request.
      • Data Portability. Where we process personal data by automated means (i.e. not on paper) You have the right to receive Your personal data (as applicable) in a structured, commonly used machine-readable format and have us transfer that personal data to another controller.
      • Profiling. You have the right not to be exposed to a decision based only on automated processing, including profiling, which produces legal effects concerning You or similarly significantly affects You.
    6. Aggregated non-personal data
      You acknowledge and agree that we may aggregate non-personally identifiable data about You and use this to understand how people are using our website and to provide further information about Cemplicity and our services. We will also use the non-personally identifiable data to enhance our productivity and general “know-how”, including by creating insights for industry benchmarking.
    7. Third party personal data
      If You provide Cemplicity with personal data about a third-party, You must ensure that You are authorised to disclose this to us and that, you have obtained full permission from the third-party for Cemplicity to use this information as described in this Policy
  5. DISCLOSURE OF YOUR INFORMATION
    1. You agree that we have the right to share Your personal data with selected third parties including;
      1. Partners, business partners, suppliers and sub-contractors for the performance of any contract we enter into with them or You in relation to the Service;
      2. where we have Your consent to do so, advertisers and advertising networks that require the data to select and serve relevant adverts to You and others;
      3. where we have Your consent to do so, email marketing service providers, to send marketing communications to You from time to time by email about promotions, competitions, updates and new products or services that may be of interest to You;
      4. analytics and search engine providers that assist us in the improvement and optimisation of our website;
      5. credit reference agencies for the purpose of assessing Your credit score where this is a condition of us entering into a contract with You;
    2. We will disclose Your personal data to third parties:
      1. In the event that we sell or buy any business or assets, in which case we will disclose Your personal data to the prospective seller or buyer of such business or assets.
      2. If Cemplicity or substantially all of its assets are acquired by a third party, in which case personal data held by it about its customers will be one of the transferred assets.
      3. If we are under a duty to disclose or share Your personal data in order to comply with any law, legal obligation or court order, or in order to enforce rights under the GDPR and other agreements; or to protect the rights, property, or safety of Cemplicity, our customers, or others.
  6. INTERNATIONAL TRANSFERS
    Transfers outside the European Economic Area (“EEA”). Personal Data may be transferred to our Partners and service providers who maintain their servers outside of the EEA where the privacy laws may not be as protective as those in Your jurisdiction. Any transfer of personal data will be in accordance with Chapter V of the GDPR.
  7. SECURITY OF YOUR INFORMATION
    Acknowledgement and Disclaimer.We take our security responsibilities seriously, using the most appropriate physical and technical measures and require our hosting partner to use the same standard of care.   Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect Your personal data, we cannot guarantee the security of Your data transmitted to our website; any transmission is at Your own risk. Once we have received Your information, we will use strict procedures and security features to try to prevent unauthorised access.  These are described in more detail below.
  8. MARKETING COMMUNICATIONS
    1. General. Where You have given us Your consent to do so, we may also use Your data to send marketing communications to You from time to time about promotions, competitions, updates and new products or services that may be of interest to You
    2. Your right to withdraw Your Consent. If You change Your mind at any time, You may withdraw Your consent to the processing of Your personal data for such marketing purposes by contacting us hello@cemplicity.com or by unsubscribing when You receive an email marketing communication from us.  The withdrawal of Your consent will not impact upon the lawfulness of processing based on Your consent prior to the withdrawal.
  9. THIRD PARTY MATERIAL
    We endeavour to only deal with Partners, vendors and other third parties who are GDPR compliant or in the case of the third parties located outside of the EEA, who are certified as compliant with the EU-US Privacy Shield, as applicable, or who have adequate security measures in place to safeguard the security of personal data.  That said, we, our employees, agents, holding company and subsidiaries, accept no liability howsoever arising for the content or reliability of any third party materials or websites referenced by hyperlink or other means on the website or for the data collection and use practices or security measures used by such third parties.
  10. CHANGES TO THIS POLICY
    Any changes made to this Policy from time to time will be published at the website and, where appropriate, notified to You by email. If any change to this Policy might result in personal data being used in a way which is different from that made known to You at the time it was collected, we will notify You to determine whether or not we may use Your personal data in this new way.
  11. QUESTIONS AND COMPLAINTS
    1. Contact Us. Should You have any questions or complaints relating to this Policy, please contact us at the addresses given above.
    2. Supervisory Authority.We are committed to complying with the terms of the GDPR and other local data protection and privacy legislation, and to the processing of personal data in a fair, lawful and transparent manner.  If, however, You believe that we have not complied with our obligations under law, You have the right to lodge a complaint with the Supervisory Authority shown in the table in 1.1 above.