Touch Medical Media Services Limited (collectively referred to as “Touch Medical Media”, “we”, “us” or “our” in this privacy policy) respects your privacy and is committed to protecting your personal data. This privacy notice explains how we use any personal data that we collect about you. It also tells you about your privacy rights and how the law protects you.
This privacy notice is provided in a layered format so you can click through to the specific areas set out below.
Purpose of this privacy notice
This privacy notice provides information on how we collect and process your personal data, including any data you may provide through our websites. Our websites, products and services are not intended for children and we do not knowingly collect data relating to children.
It is important that you read this privacy notice together with any other privacy notice or fair processing notice we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy notice supplements the other notices and is not intended to override them.
Controller
Touch Medical Media Services Limited is the controller and responsible for your personal data (collectively referred to as “we”, “us”, or “our” in this privacy notice). We are registered with the Information Commissioner’s Office (registration number ZA322566).
We have appointed a Data Privacy Manager who is responsible for overseeing questions in relation to this privacy notice. If you have any questions about this privacy notice, including any requests to exercise your legal rights, please contact our Data Privacy Manager using the details set out below.
Phone: 0207 1933009
Email: hello@touchmedicalmedia.com
Post: Touch Medical Media Services, 3 Stockport Exchange, Stockport, Cheshire, United Kingdom, SK1 3GG.
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.
Changes to the privacy notice and your duty to inform us of changes
We reserve the right to update this privacy notice at any time and will provide you with a new privacy notice when we make any substantial updates. We may also notify you in other ways from time to time about the processing of your personal information. This version was last updated on 04 November 2021 and historic versions can be obtained by contacting us.
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.
Third-party links
This 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.
Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).
We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:
We also collect, use and share Aggregated Data, such as statistical or demographic data, for any purpose. Aggregated Data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy notice.
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.
If you fail to provide personal data
Where we need to collect personal data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with goods or services). In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.
Using your social media details to sign into your Touch Medical Media account
When you sign into our sites or apps using your social media login details, you give permission to the social media sites to share with us your email address and certain aspects of your profile if you have made these public on your profile.
We will then use this personal data to form a profile for your TMM account. If you remove the TMM Websites from your social media settings we will no longer have access to this data. However, we will still have the personal data that we received when you first set up your TMM account using your social media ID. Below are listed the social media sites which can be used to log in to your TMM account and the data which we receive from them.
When you sign into our sites or apps using your Facebook login details, this application will be able to:
See Your name and profile picture and email address.
This only includes your first and last name, age range, link to your Facebook profile and profile picture. We do not have access to updates on your Facebook profile.
X
When you sign into our sites or apps using your X login details, this application will be able to:
See posts from your timeline (including protected posts) as well as your Lists and collections.
See your X profile information and account settings.
See accounts you follow, mute, and block.
See your email address.
Linked IN
When you sign into our sites or apps using your Linked In login details, this application will be able to:
Use your name and photo
Use the primary email address associated with your LinkedIn account
When you sign into our sites or apps using your Google login details, this application will be able to:
See will share your name, email address, language preference and profile picture
Amazon
When you sign into our sites or apps using your Google login details, this application will be able to:
See your First name and Last Name
See your Email address
Microsoft
When you sign into our sites or apps using your Google login details, this application will be able to:
See your profile info, including your name, gender, display picture, contacts, and friends and access your email addresses.
You can stop the sync of data in your social media account settings and you can ask us to delete your data (see Your Legal Rights below for further information).
If you wish to exercise any of the rights set out above, please contact us.
We use different methods to collect data from and about you including through:
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:
Generally, we do not rely on consent as a legal basis for processing your personal data.
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. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.
Purpose/Activity | Type of data | Lawful basis for processing including basis of legitimate interest |
To register you as a new customer | (a) Identity
(b) Contact (c) Profile |
Performance of a contract with you |
To process and deliver your order including:
(a)Manage payments, fees and charges (b)Collect and recover money owed to us |
(a) Identity
(b) Contact (c) Transaction (d) Marketing and Communications |
(a) Performance of a contract with you
(b) Necessary for our legitimate interests (to recover debts due to us) |
To manage our relationship with you which will include:
(a) Notifying you about changes to our terms or privacy policy (b) Asking you to leave a review or take a survey |
(a) Identity
(b) Contact (c) Profile (d) Marketing and Communications |
(a) Performance of a contract with you
(b) Necessary to comply with a legal obligation (c) Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services) |
To ensure we are able to provide the services to you including:
(a) Generating certificates of credit; (b) ensuring we remain accredited and notably complying with out obligations with relevant Accrediting Bodies1 |
(a) Identity
(b) Contact (c) Profile |
(a) Performance of a contract with you
(b) Necessary to comply with legal obligation whilst we remain accredited (c) Necessary for our legitimate interest (to ensure we remain accredited) |
To enable you to partake in a prize draw, competition or complete a survey | (a) Identity
(b) Contact (c) Profile (d) Usage (e) Marketing and Communications |
(a) Performance of a contract with you
(b) Necessary for our legitimate interests (to study how customers use our products/services, to develop them and grow our business) |
To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data) | (a) Identity
(b) Contact (c) Technical |
(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
(b) Contact (c) Profile (d) Usage (e) Marketing and Communications (f) 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
(b) Usage |
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 products/services that may be of interest to you | (a) Identity
(b) Contact (c) Technical (d) Usage (e) Profile |
Necessary for our legitimate interests (to develop our products/services and grow our business) |
Legal Bases
Further details of the legal bases relied on are below:
Marketing
We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising. You may opt out of marketing and advertising communications by contacting us or following the unsubscribe instructions or link on the relevant communication.
We may use your Identity, Contact, Technical, Usage and Profile 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 and services may be relevant for you (we call this marketing).
You will receive marketing communications from us if you have requested information from us or purchased/received products or services from us or if you provided us with your details when you entered a competition/promotion/survey and, in each case, you have not opted out of receiving that marketing.
Third-party marketing
We will get your express opt-in consent before we share your personal data with any third party for marketing purposes.
Opting out
You can ask us or third parties to stop sending you marketing messages at any time by contacting us at any time or by following the unsubscribe instructions or link on the relevant communication.
Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a providing a product/service, product/service experience or other transactions.
Cookies
You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly. For more information about the cookies we use, please see our Cookie Policy.
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.
We may have to share your personal data with the parties set out below for the purposes set out in the table in paragraph 4 above.
THIRD PARTY PROCESSORS
Our carefully selected partners and service providers may process personal information about you on our behalf as described below:
Digital Marketing Service Providers
We periodically appoint digital marketing agents to conduct marketing activity on our behalf, such activity may result in the compliant processing of personal information. Our appointed data processors include:
Many of our external third parties are based outside the United Kingdom (UK) so their processing of your personal data will involve a transfer of data outside 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 at least one of the following safeguards is implemented:
Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the UK.
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.
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.
By law we have to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for six years after they cease being customers for tax purposes.
In some circumstances you can ask us to delete your data (see Your Legal Rights below for further information).
In some circumstances we will anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.
Under certain circumstances, you have rights under data protection laws in relation to your personal data. These rights may include the right to:
If you wish to exercise any of the rights set out above, please 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 is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these 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 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.
1Accreditation Council for Continuing Medical Education (ACCME), American Nurses Credentialing Centre (ANCC), and the Accreditation Council for Pharmacy Education (ACPE)
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