This Privacy Policy describes Our policies and procedures on the collection, use and disclosure of Your information when You use the Service and tells You about Your privacy rights and how the law protects You
We use Your Personal data to provide and improve the Service
By using the Service, You agree to the collection and use of information in accordance with this Privacy Policy
Interpretation and Definitions
Interpretation
The words of which the initial letter is capitalized have meanings defined under the following conditions
The following definitions shall have the same meaning regardless of whether they appear in singular or in plural
Definitions
For the purposes of this Privacy Policy:
Account means a unique account created for You to access our Service or parts of our Service
Affiliate means an entity that controls, is controlled by or is under common control with a party, where "control" means ownership of 50% or more of the shares, equity interest or other securities entitled to vote for election of directors or other managing authority
Application means the software program provided by the Company downloaded by You on any electronic device, named Surgery Connect
Company (referred to as either "the Company", "We", "Us" or "Our" in this Agreement) refers to Storacall Technology Ltd, t/a X-on, 22 Riduna Park, Melton, Suffolk IP12 1QT, United Kingdom
For the purpose of the GDPR, the Company is the Data ControllerCookies are small files that are placed on Your computer, mobile device or any other device by a website, containing the details of Your browsing history on that website among its many uses
Country refers to: United Kingdom
Data Controller, for the purposes of the GDPR (General Data Protection Regulation), refers to the Company as the legal person which alone or jointly with others determines the purposes and means of the processing of Personal Data
Device means any device that can access the Service such as a computer, a cellphone or a digital tablet
Personal Data is any information that relates to an identified or identifiable individual.
For the purposes for GDPR, Personal Data means any information relating to You such as a name, an identification number, location data, online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identityService refers to the Application or the Website or both
Service Provider means any natural or legal person who processes the data on behalf of the Company. It refers to third-party companies or individuals employed by the Company to facilitate the Service, to provide the Service on behalf of the Company, to perform services related to the Service or to assist the Company in analyzing how the Service is used. For the purpose of the GDPR, Service Providers are considered Data Processors
Usage Data refers to data collected automatically, either generated by the use of the Service or from the Service infrastructure itself (for example, the duration of a page visit)
Website refers to Surgery Connect, accessible from https://patient.surgeryconnect.app or https://video.x-onweb.com
You means the individual accessing or using the Service, or the company, or other legal entity on behalf of which such individual is accessing or using the Service, as applicable
Under GDPR (General Data Protection Regulation), You can be referred to as the Data Subject or as the User as you are the individual using the Service
Collecting and Using Your Personal Data
Types of Data Collected
Personal Data
While using Our Service, We may ask You to provide Us with certain personally identifiable information that can be used to contact or identify You. Personally identifiable information may include, but is not limited to:
Email address
First name and last name
Phone number
Usage Data
Usage Data
Usage Data is collected automatically when using the Service
Usage Data may include information such as Your Device's Internet Protocol address (e.g. IP address), browser type, browser version, the pages of our Service that You visit, the time and date of Your visit, the time spent on those pages, unique device identifiers and other diagnostic data
When You access the Service by or through a mobile device, We may collect certain information automatically, including, but not limited to, the type of mobile device You use, Your mobile device unique ID, the IP address of Your mobile device, Your mobile operating system, the type of mobile Internet browser You use, unique device identifiers and other diagnostic data
We may also collect information that Your browser sends whenever You visit our Service or when You access the Service by or through a mobile device
Information Collected while Using the Application
While using Our Application, in order to provide features of Our Application, We may collect, with Your prior permission:
Information regarding your location
Pictures and other information from your Device's camera and photo library
We use this information to provide features of Our Service, to improve and customize Our Service. The information may be uploaded to the Company's servers and/or a Service Provider's server or it may be simply stored on Your device
You can enable or disable access to this information at any time, through Your Device settings
Tracking Technologies and Cookies
We use Cookies and similar tracking technologies to track the activity on Our Service and store certain information. Tracking technologies used are beacons, tags, and scripts to collect and track information and to improve and analyse Our Service
For more information about the cookies we use and your choices regarding cookies, please visit our Tracking Technology and Cookies Policy
Use of Your Personal Data
The Company may use Personal Data for the following purposes:
To provide and maintain our Service, including to monitor the usage of our Service
To manage Your Account: to manage Your registration as a user of the Service. The Personal Data You provide can give You access to different functionalities of the Service that are available to You as a registered user
For the performance of a contract: the development, compliance and undertaking of the purchase contract for the products, items or services You have purchased or of any other contract with Us through the Service
To contact You: To contact You by email, telephone calls, SMS, or other equivalent forms of electronic communication, such as a mobile application's push notifications regarding updates or informative communications related to the functionalities, products or contracted services, including the security updates, when necessary or reasonable for their implementation
To provide You with news, special offers and general information about other goods, services and events which we offer that are similar to those that you have already purchased or enquired about unless You have opted not to receive such information.
To manage Your requests: To attend and manage Your requests to Us
For business transfers: We may use Your information to evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of Our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which Personal Data held by Us about our Service users is among the assets transferred
For other purposes: We may use Your information for other purposes, such as data analysis, identifying usage trends, determining the effectiveness of our promotional campaigns and to evaluate and improve our Service, products, services, marketing and your experience
We may share Your personal information in the following situations:
With Service Providers: We may share Your personal information with Service Providers to monitor and analyze the use of our Service, to contact You
For business transfers: We may share or transfer Your personal information in connection with, or during negotiations of, any merger, sale of Company assets, financing, or acquisition of all or a portion of Our business to another company
With Affiliates: We may share Your information with Our affiliates, in which case we will require those affiliates to honor this Privacy Policy. Affiliates include Our parent company and any other subsidiaries, joint venture partners or other companies that We control or that are under common control with Us
With business partners: We may share Your information with Our business partners to offer You certain products, services or promotions
With other users: when You share personal information or otherwise interact in the public areas with other users, such information may be viewed by all users and may be publicly distributed outside
With Your consent: We may disclose Your personal information for any other purpose with Your consent
Retention of Your Personal Data
The Company will retain Your Personal Data only for as long as is necessary for the purposes set out in this Privacy Policy. We will retain and use Your Personal Data to the extent necessary to comply with our legal obligations (for example, if we are required to retain your data to comply with applicable laws), resolve disputes, and enforce our legal agreements and policies
The Company will also retain Usage Data for internal analysis purposes. Usage Data is generally retained for a shorter period of time, except when this data is used to strengthen the security or to improve the functionality of Our Service, or We are legally obligated to retain this data for longer time periods
Transfer of Your Personal Data
Your information, including Personal Data, is processed at the Company's operating offices and in any other places where the parties involved in the processing are located. It means that this information may be transferred to — and maintained on — computers located outside of Your state, province, country or other governmental jurisdiction where the data protection laws may differ than those from Your jurisdiction
Your consent to this Privacy Policy followed by Your submission of such information represents Your agreement to that transfer
The Company will take all steps reasonably necessary to ensure that Your data is treated securely and in accordance with this Privacy Policy and no transfer of Your Personal Data will take place to an organization or a country unless there are adequate controls in place including the security of Your data and other personal information
Disclosure of Your Personal Data
Business Transactions
If the Company is involved in a merger, acquisition or asset sale, Your Personal Data may be transferred. We will provide notice before Your Personal Data is transferred and becomes subject to a different Privacy Policy
Law enforcement
Under certain circumstances, the Company may be required to disclose Your Personal Data if required to do so by law or in response to valid requests by public authorities (e.g. a court or a government agency)
Other legal requirements
The Company may disclose Your Personal Data in the good faith belief that such action is necessary to:
Comply with a legal obligation
Protect and defend the rights or property of the Company
Prevent or investigate possible wrongdoing in connection with the Service
Protect the personal safety of Users of the Service or the public
Protect against legal liability
Security of Your Personal Data
The security of Your Personal Data is important to Us, but remember that no method of transmission over the Internet, or method of electronic storage is 100% secure. While We strive to use commercially acceptable means to protect Your Personal Data, We cannot guarantee its absolute security
We have put in place appropriate security measures to prevent your personal information from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal information to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal information on our instructions and they are subject to a duty of confidentiality
We have put in place procedures to deal with any suspected data security breach and will notify you and any applicable regulator of a suspected breach where we are legally required to do so
X-on Health is accredited by a number of organisations, accreditations which are regularly audited, and which attest to the high levels of data security maintained by X-on Health, e.g. ISO9001 (Quality Management of Systems requirements), ISO27001 (Information Security Management Standards), ICO (Data Protection Act compliance), IGT (NHS digital services access requirements), are a Crown Commercial Service Supplier and are PCI-DSS (credit card security rules) Level 4 providers
If you have concerns regarding how X-on Health handles your data, please contact us to discuss, otherwise, you can opt to leave the website and not engage with X-on Health
Transferring data outside the UK
Personal data is not transferred outside the UK except where contractually agreed.
Detailed Information on the Processing of Your Personal Data
The Service Providers We use may have access to Your Personal Data. These third-party vendors collect, store, use, process and transfer information about Your activity on Our Service in accordance with their Privacy Policies
Analytics
We may use third-party Service providers to monitor and analyze the use of our Service
Google Analytics
Google Analytics is a web analytics service offered by Google that tracks and reports website traffic. Google uses the data collected to track and monitor the use of our Service. This data is shared with other Google services. Google may use the collected data to contextualize and personalize the ads of its own advertising network
You can opt-out of having made your activity on the Service available to Google Analytics by installing the Google Analytics opt-out browser add-on. The add-on prevents the Google Analytics JavaScript (ga.js, analytics.js and dc.js) from sharing information with Google Analytics about visits activity
You may opt-out of certain Google Analytics features through your mobile device settings, such as your device advertising settings or by following the instructions provided by Google in their Privacy Policy: https://policies.google.com/privacy
For more information on the privacy practices of Google, please visit the Google Privacy & Terms web page: https://policies.google.com/privacyFirebase
Firebase is an analytics service provided by Google Inc.
You may opt-out of certain Firebase features through your mobile device settings, such as your device advertising settings or by following the instructions provided by Google in their Privacy Policy: https://policies.google.com/privacy
We also encourage you to review the Google's policy for safeguarding your data: https://support.google.com/analytics/answer/6004245
For more information on what type of information Firebase collects, please visit the How Google uses data when you use our partners' sites or apps webpage: https://policies.google.com/technologies/partner-sitesMatomo
Matomo is a web analytics service. You can visit their Privacy Policy page here: https://matomo.org/privacy-policyMixpanel
Mixpanel is provided by Mixpanel Inc.
You can prevent Mixpanel from using your information for analytics purposes by opting-out. To opt-out of Mixpanel service, please visit this page: https://mixpanel.com/optout/
For more information on what type of information Mixpanel collects, please visit the Terms of Use page of Mixpanel: https://mixpanel.com/terms/Intercom
Use of Intercom Services: We use third-party analytics services to help understand your usage of our services. In particular, we provide a limited amount of your information (such as sign-up date and some personal information like your email address) to Intercom, Inc. (“Intercom”) and utilize Intercom to collect data for analytics purposes when you visit our website or use our product. As a data processor acting on our behalf, Intercom analyses your use of our website and/or product and tracks our relationship by way of cookies and similar technologies so that we can improve our service to you. For more information on Intercom's use of cookies, please visit
We may also use Intercom as a medium for communications, either through email, or through messages within our product(s). The Intercom Messenger Apps and Apps in Inbox products may also provide you with access to other third party applications such as Stripe. You should consult these third parties' privacy notices for further information on their use of your personal data. As part of our service agreements, Intercom collects publicly available contact and social information related to you, such as your email address, gender, company, job title, photos, website URLs, social network handles and physical addresses, to enhance your user experience. For more information on the privacy practices of Intercom, please visit Terms and Policies | Intercom . Intercom’s services are governed by Intercom’s terms of use which can be found at Terms and Policies | Intercom . If you would like to opt out of having this information collected by or submitted to Intercom, please contact us
HubSpot
HubSpot is our CRM system for storing existing and potential customer’s data. A customer’s data is added to HubSpot either by site, visitors providing their contact information or when an X-on Health user adds the information
This is crucial as it enables us to give our customers and potential customers relevant, useful and personalised marketing, sales and customer services content. We also document communications, such as emails and meetings that have been held. We can also see whether you have opened an email or not. This informs us instantly whether what we send you is interesting, allowing us to tailor our communications to best serve our audience
This data is stored by us as long as you are a customer and/or have a relationship with us
Email Marketing
We may use Your Personal Data to contact You with newsletters, marketing or promotional materials and other information that may be of interest to You. You may opt-out of receiving any, or all, of these communications from Us by following the unsubscribe link or instructions provided in any email We send or by contacting Us
We may use Email Marketing Service Providers to manage and send emails to You
SendGrid
Their Privacy Policy can be viewed at https://www.twilio.com/legal/privacy
Usage, Performance and Miscellaneous
We may use third-party Service Providers to provide better improvement of our Service
Sentry
Their Privacy Policy can be viewed at https://sentry.io/privacy/
GDPR Privacy
Legal Basis for Processing Personal Data under GDPR
We may process Personal Data under the following conditions:
Consent: You have given Your consent for processing Personal Data for one or more specific purposes
Performance of a contract: Provision of Personal Data is necessary for the performance of an agreement with You and/or for any pre-contractual obligations thereof
Legal obligations: Processing Personal Data is necessary for compliance with a legal obligation to which the Company is subject
Vital interests: Processing Personal Data is necessary in order to protect Your vital interests or of another natural person
Public interests: Processing Personal Data is related to a task that is carried out in the public interest or in the exercise of official authority vested in the Company
Legitimate interests: Processing Personal Data is necessary for the purposes of the legitimate interests pursued by the Company
In any case, the Company will gladly help to clarify the specific legal basis that applies to the processing, and in particular whether the provision of Personal Data is a statutory or contractual requirement, or a requirement necessary to enter into a contract
Your Rights under the GDPR
The Company undertakes to respect the confidentiality of Your Personal Data and to guarantee You can exercise Your rights
You have the right under this Privacy Policy, and by law if You are within the EU, to:
Request access to Your Personal Data. The right to access, update or delete the information We have on You. Whenever made possible, you can access, update or request deletion of Your Personal Data directly within Your account settings section. If you are unable to perform these actions yourself, please contact Us to assist You. This also enables You to receive a copy of the Personal Data We hold about You
Request correction of the Personal Data that We hold about You. You have the right to have any incomplete or inaccurate information We hold about You corrected
Object to processing of Your Personal Data. This right exists where We are relying on a legitimate interest as the legal basis for Our processing and there is something about Your particular situation, which makes You want to object to our processing of Your Personal Data on this ground. You also have the right to object where We are processing Your Personal Data for direct marketing purposes
Request erasure of Your Personal Data. You have the right to ask Us to delete or remove Personal Data when there is no good reason for Us to continue processing it
Request the transfer of Your Personal Data. We will provide to You, or to a third-party You have chosen, Your Personal Data in a structured, commonly used, machine-readable format. Please 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
Withdraw Your consent. You have the right to withdraw Your consent on using your Personal Data. If You withdraw Your consent, We may not be able to provide You with access to certain specific functionalities of the Service
Exercising of Your GDPR Data Protection Rights
You may exercise Your rights of access, rectification, cancellation and opposition by contacting Us. Please note that we may ask You to verify Your identity before responding to such requests. If You make a request, We will try our best to respond to You as soon as possible
You have the right to complain to a Data Protection Authority about Our collection and use of Your Personal Data. For more information, if You are in the European Economic Area (EEA), please contact Your local data protection authority in the EEA
Job Applicants and Prospects
Information sent when seeking employment at X-on Health may be retained for up to a year. This is to assess CVs against any current position, or new position that might arise in the future
The details of anyone employed by X-on Health are retained during the period of employment, in order to properly engage with that employee, with that data retained for up to 6 years
When you apply for a role with us:
If you apply for a role at X-on Health, we will collect the following information about you:
Name
Telephone number
Email address
Employment history and other data in your CV or otherwise submitted to us
Assessments completed by you as part of the application process
Feedback about you from our staff and your referees
Children's Privacy
Our Service does not address anyone under the age of 13. We do not knowingly collect personally identifiable information from anyone under the age of 13
If You are a parent or guardian and You are aware that Your child has provided Us with Personal Data, please contact Us. If We become aware that We have collected Personal Data from anyone under the age of 13 without verification of parental consent, We take steps to remove that information from Our servers
If We need to rely on consent as a legal basis for processing Your information and Your country requires consent from a parent, We may require Your parent's consent before We collect and use that information
Links to Other Websites
Our Service may contain links to other websites that are not operated by Us. If You click on a third party link, You will be directed to that third party's site. We strongly advise You to review the Privacy Policy of every site You visit
We have no control over and assume no responsibility for the content, privacy policies or practices of any third party sites or services
Changes to this Privacy Policy
We may update Our Privacy Policy from time to time. We will notify You of any changes by posting the new Privacy Policy on this page
We will let You know via email and/or a prominent notice on Our Service, prior to the change becoming effective and update the "Last updated" date at the top of this Privacy Policy
You are advised to review this Privacy Policy periodically for any changes. Changes to this Privacy Policy are effective when they are posted on this page
Contact Us
If you have any questions about this Privacy Policy, You can contact us:
By email: legal@x-on.co.uk