Introduction

 

Oxford Immune Algorithmics Ltd (company number 11588155) (also referred to as OIA, we, our or us) respects your privacy and is committed to protecting your personal data.

 

This privacy policy will inform you as to how we look after your personal data when you become a User of our product, the Algocyte platform (accessible via our website uk.algocyte.com or mobile app).  In particular, this privacy policy details how we look after the data of Subscribers to, and Providers of, our Algocyte Service which allows purchase and use of our full, rapid, remote blood testing kit (Algocyte Kit).  It tells you about your privacy rights and how the law protects you.

This privacy policy does not apply to other OIA websites or any other websites that you may be able to access via the Algocyte platform and/or activities offered by third parties.  Please ensure that you review any relevant policies on any other OIA or third party websites before proceeding.  We are not responsible for the collection or use of your personal data from third party websites.

 

Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it.

Please also use the Glossary to understand the meaning of some of the terms used in this privacy policy.

TOPICS COVERED

 

1. IMPORTANT INFORMATION AND WHO WE ARE

2. THE DATA WE COLLECT ABOUT YOU

3. HOW IS YOUR PERSONAL DATA COLLECTED?

4. HOW WE USE YOUR PERSONAL DATA

5. DISCLOSURES OF YOUR PERSONAL DATA

6. INTERNATIONAL TRANSFERS

7. DATA SECURITY

8. DATA RETENTION

9. YOUR LEGAL RIGHTS

10. GLOSSARY

 

1.                   Important information and who we are

Controller

Oxford Immune Algorithmics Ltd is the controller and responsible for your personal data.

 

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

 

Contact details

If you have any questions about this privacy policy or our privacy practices, please contact our DPO in the following ways:

 

Oxford Immune Algorithmics Ltd

Unit 6 Richfield Place, 12 Richfield Avenue, Reading RG1 3EU, England

dpo@immunealgorithmics.com

0118 228 0980

 

You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk) or if you are based within the European Economic Area (EEA) you can also complain to your local supervisory authority (as applicable).  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 policy and your duty to inform us of changes

We keep our privacy policy under regular review.  This version was last updated on the 14^th of October 2022.

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.

 

2.                   The data we collect about you

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:

·         Identity Data includes first name, last name, title, date of birth and sex.

·         Contact Data includes billing address, delivery address, email address and telephone number.

·         Test Data includes information about your health (including your weight and height, allergies, medications and alcohol or other substance intake) or your family’s health, genetic data and other data collected by your use of the testing kit provided by us (blood cell count) and the resulting immune score.

·         Financial Data includes credit or debit card details and account number, and any other personal data required to facilitate the payment.

·         Transaction Data includes details about payments to and from you and other details of any additional services you have purchased from us.

·         Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access the Algocyte platform.

·         Profile Data includes your username and password and any feedback you may provide as a result of using the Algocyte platform.

·         Usage Data includes information about how you use the Algocyte platform and associated services.

·         Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.

 

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 feature on the Algocyte platform.  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 policy.

 

Pseudonymised data is personal data that is replaced with one or more artificial identifiers or pseudonyms so that the person to whom the data relates cannot be identified without the use of additional information which is kept separately and secure.  We use pseudonymised data to help us develop and improve our services.

 

We collect health data and details about your race or ethnicity in order to perform our services.  These are referred to as Special Categories of Personal Data.  We do not collect any other Special Categories of Personal Data about you (this includes details about your religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership or 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.

 

3.                   How is your personal data collected?

We use different methods to collect data from and about you, including:

 

·         Through direct interaction.  You may give us your Identity, Contact and Financial Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:

·         create an account on the Algocyte platform;

·         pay for and use the Algocyte Service;

·         request marketing to be sent to you;

·         give us feedback or contact us.

 

·         By the third party laboratory.  We may engage a third party sub-contractor to analyse samples collected with the Algocyte Kit.

 

·         Through automated technologies or interactions.  As you interact with the Algocyte platform, we will automatically collect Technical Data about your equipment, browsing actions and patterns.  We collect this personal data by using cookies, server logs and other similar technologies.  Please see our Cookie Policy for further details.

 

·         By third parties or through publicly available sources.  We will receive personal data about you from various additional third parties as set out below:

·         Technical Data from analytics providers;

·         Contact, Financial and Transaction Data from providers of technical, payment and delivery services.

 

·         If you have a Provider, they may also provide us with the following information to organise access to the Algocyte Service:

·         name;

·         gender;

·         information about your health (as detailed under ‘Test Data’ above);

·         date of birth;

·         email address;

·         postal address;

·         telephone number; and

·         Subscriber ID number.

 

4.                   How we use your personal data

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:

·         When we have obtained your explicit consent.

·         When another User of the Algocyte platform (or your Provider, if you have one) has obtained your explicit consent.

·         When it is necessary for us to perform medical research in the public interest.

·         When we need to perform the contract we are about to enter into or, have entered into with you.

·         When it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.

·         When we need to comply with a legal obligation.

 

Click here to find out more about the types of lawful basis that we will rely on to process your personal data.

 

Where we rely on your explicit consent, you have the right to withdraw such consent at any time by contacting us.

 

We will always get your consent before sending third party direct marketing communications to you via email or text message.  You have the right to withdraw consent to marketing at any time by contacting us.

 

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 subscribe you to the Algocyte Service.	(a) Identity Data (b) Contact Data	Performance of a contract with you where you purchase the Algocyte Service.
To process and deliver your order including: (a) Manage payments, fees and charges (b) to deliver the Algocyte Kit to you.	(a) Identity Data (b) Contact Data the Financial Data (d) Transaction Data	Performance of a contract with you where you purchase the Algocyte Service.
To process your blood sample and conduct the analysis.	(a) Identity Data (b) Test Data	Performance of a contract with you to undertake the analysis upon receipt of the sample.   We also obtain your explicit consent to process your special category data (data relating to your health).
To share the results: (a) with you; (b) with your Provider (if you have one) to enable them to notify you of the results.	(a) Identity Data (b) Contact Data (c) Test Data	Performance of a contract with you to share the results of the test.   If you have a Provider, we also obtain your explicit consent to share your special category data (data relating to your health) with them so that they may interpret the results of the test and make an assessment as to the frequency of any future test, or any subsequent treatment or intervention as required.
To further develop and improve the Algocyte platform and associated services.	(a) Test Data (b) Pseudonymised Data	Necessary for our legitimate interests (to develop and improve our services).   Condition for processing special category data: Consent.
To manage our relationship with you which will include: (a) Notifying you about changes to the Algocyte platform Terms of Use or Privacy Policy (b) Asking you to leave a review or take a survey.	(a) Identity Data (b) Contact Data (c) Profile Data (d) Marketing and Communications Data	(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 administer and protect our business and the Algocyte platform (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data).	(a) Identity Data (b) Contact Data (c) Technical Data (d) Profile Data	(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 content and advertisements to you via the Algocyte platform, and measure or understand the effectiveness of the advertising we serve to you.	(a) Identity Data (b) Contact Data (c) Profile Data (d) Usage Data (e) Marketing and Communications Data (f) Technical Data	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 the Algocyte platform and associated services, marketing, customer relationships and experiences.	(a) Technical Data (b) Usage Data	Necessary for our legitimate interests (to define types of customers for the Algocyte platform and associated services, to keep the Algocyte platform updated and relevant, to develop our business and to inform our marketing strategy).
To make suggestions and recommendations to you about goods or services that may be of interest to you.	(a) Identity (b) Contact (c) Technical (d) Usage (e) Profile (f) Marketing and Communications	Necessary for our legitimate interests (to develop our products/services and grow our business).

 

 

Marketing

We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising.

 

Promotional offers from us

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, services and offers 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 goods or services from us and 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.

Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a product/service purchase.

 

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 the Algocyte platform may become inaccessible or not function properly.

 

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.

 

5.                   Disclosures of your personal data

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

·         Service providers acting as processors based in the UK who provide IT and system administration services.

·         Professional advisers acting as processors or joint controllers including lawyers, bankers, auditors and insurers based in the United Kingdom who provide consultancy, banking, legal, insurance and accounting services.

·         HM Revenue & Customs, regulators and other authorities acting as processors or joint controllers based in the United Kingdom who require reporting of processing activities in certain circumstances.

·         Specific third parties such as:

·         Any User of the Algocyte platform with independent knowledge of your Subscriber ID number, including your Provider;

·         Any UK medical professional with access to the Algocyte platform and independent knowledge of your Subscriber ID number;

·         The third party laboratory where your test is analysed; and

·         Additional companies who undertake services on our behalf such as sending the testing kits to you.

·         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.

 

6.                   International transfers

Our external third parties with whom we store your personal data are based in Europe 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 as we will only transfer your personal data to countries that are in Europe or have been deemed to provide an adequate level of protection for personal data.

 

Please contact us if you want further information regarding international data transfers.

 

7.                   Data security

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.

 

8.                   Data retention

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.

 

Details of retention periods for different aspects of your personal data are available in our retention policy which you can request from us by contacting us.

 

In some circumstances you can ask us to delete your data: see 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.

 

9.                   Your legal rights

Under certain circumstances, you have rights under data protection laws in relation to your personal data. Please click on the links below to find out more about these rights:

·         Request access to your personal data.

·         Request correction of your personal data.

·         Request erasure of your personal data.

·         Object to processing of your personal data.

·         Request restriction of processing your personal data.

·         Request transfer of your personal data.

·         Right to withdraw consent.

 

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 could 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.

 

10.                Glossary

PRODUCT SPECIFIC

 

·         OIA: Oxford Immune Algorithmics Ltd., the end provider of the Algocyte platform and Algocyte Service

·         User: an individual signed up to the Algocyte platform.  Each individual User is allocated an individual User account on the Algocyte platform

·         Subscriber: an individual subscribing to the optional Algocyte Service, should they choose to do so

·         Provider: a healthcare provider, who may organise and oversee the testing regime of a Subscriber.  Each individual Provider is allocated an individual User account on the Algocyte platform.  It is not necessary to have a Provider to become a User or Subscriber

·         Algocyte platform: an OIA product, a personal medical data platform provided both on a website and on a mobile app

·         Algocyte Kit: a home blood testing kit provided as part of the Algocyte Service

·         Algocyte Service: a home blood testing service provided via the Algocyte platform, comprising issue of the Algocyte Kit, postage and analysis of the blood test, and uploading the blood test result onto the Algocyte platform

 

LAWFUL BASES

·         Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience.  We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests.  We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law).  You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.

·         Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.

·         Comply with a legal obligation means processing your personal data where it is necessary for compliance with a legal obligation that we are subject to.

·         Explicit consent means a specific, informed and unambiguous indication of your wishes, which you have freely given and affirmed in a clear statement (whether oral or in writing).

 

11.                Your Legal Rights

You have the right to:

(i)            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.

(ii)           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.

(iii)          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.

(iv)          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.

(v)           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.

(vi)          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.

(vii)        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.