Xtremity Solutions takes data protection seriously and are committed to being upfront about our approach to privacy. This privacy notice sets out how we will treat the personal data which you provide to us in compliance with applicable data protection law, in particular the General Data Protection Regulation (EU) 2016/679 (“GDPR”).
Who are we?
Xtremity Solutions Ltd is a privately owned, British medical device company based in the North East of England since 2005. We will act as the data controller for personal data submitted to us by participating patients.
Xtremity Solutions Registered company number is 08031770 with registered offices at 71, Jay Avenue, Teesside Estate, Thornaby-on-Tees, North Riding of Yorkshire TS 17 9LZ United Kingdom. Should you have any queries about this policy, or the way in which we control your personal data, or about exercising your rights, please e-mail gdpr@xtremitysolutions.com, or write to Data Protection at the address noted above.
What personal data do we collect?
Should you make an enquiry about one of our products, we will then collect your name, email address, telephone number and occupation. We do not collect sensitive personal data nor will we ever sell any personal information collected.
What purposes do we use your personal data for?
Contractual purposes
If you have registered to receive our products and services, we may use your personal data to:
- provide the contracted products or product information to you
- communicate with you in relation to the provision of the contracted products
- send you relevant product information or improvements that may have evolved which we believe will be to your benefit
- communicate with you for administrative purposes such as account creation, security and support
Legitimate interests
We may process your personal data for purposes which are within our legitimate interests, including:
- sending you newsletters, surveys, events, offers and promotions related to our products and services which may be of interest to you
- improving the quality of experience when you interact with our products and services including the testing of different page designs to see which performs better
- performing data analytics, determining the effectiveness of our product and customer facing endeavours
You may have the right to object to this processing if you wish, as further detailed below, under the heading ‘Your Rights’.
Marketing communications
Where you have given your express consent to receive marketing communications, we may use your personal data to:
- send you newsletters, surveys, events, offers and promotions, related our products and services which may be of interest to you
- developing, improving, and delivering marketing and advertising for the products and services
Legal purposes
We may also process your personal data if required by law, including responding to requests by government or law enforcement authorities, or for the prevention of crime or fraud.
How long will we retain your personal data?
We will retain your personal data for a minimum of 30 years as required by current medical device governance. This is designed to ensure the protection of the interest of patients who receive implants and where appropriate, to be able to comply with any legal requirements, audit requirements, regulatory requests or orders from Competent Authorities and or Courts.
You may unsubscribe from marketing communications at any time by clicking on the link provided in the relevant email.
Who do we share your personal data with?
We may share your personal data with trusted third parties including:
- our legal subsidiaries and/ or associated companies
- legal or other professional advisers, consultants, and experts
- service providers contracted to us in connection with provision of the products and services such as providers of IT services and customer relationship management services
- analytics and search engine providers that assist us in the improvement and optimisation of our website
We will ensure there is a contract in place which each of these data recipients which ensures the confidentiality, security and lawful processing of all personal data shared with them.
Where we share personal data with subsidiaries / associated that are located outside of the European Economic Area, we will ensure that the transfer of personal data will be protected by appropriate safeguards, namely the use of standard data protection clauses adopted or approved by the European Commission.
What are your rights?
You have various rights with respect to our use of your personal data:
- Access: You have the right to request a copy of the personal data that we hold about you. Please note that there are exceptions to this right, so that access may be denied if, for example, making the information available to you would reveal personal data about another person, or if we are legally prevented from disclosing such information. You are entitled to see the personal data held about you. If you wish to do this, please contact us using the contact details provided below.
- Accuracy: We aim to keep your personal data accurate, current, and complete. We encourage you to contact us using the contact details provided below to let us know if any of your personal data is not accurate or changes, so that we can keep your personal data up-to-date.
- Objecting: In certain circumstances, you also have the right to object to processing of your personal data and to ask us to block, erase and restrict your personal data. If you would like us to stop using your personal data, please contact us using the contact details provided below.
- Porting: In certain circumstances, you have the right to request that some of your personal data is provided to you, or to another data controller, in a commonly used, machine-readable format. If you would like to request that your personal data is ported to you, please contact us using the contact details provided below.
- Erasure: You have the right to erase your personal data when the personal data are no longer necessary for the purposes for which they were collected, or when, among other cases, your personal data have been unlawfully processed. If you would like to request that your personal data is erased, please contact us using the contact details provided below.
- Complaints: If you believe that your data protection rights may have been breached, you have the right to lodge a complaint the applicable supervisory authority or to seek a remedy through the courts. Please visit https://ico.org.uk/concerns/ for more information on how to report a concern to the UK Information Commissioner’s Office.
Please note that there are exceptions to these rights, if, for example, we are under a legal obligation to continue to process your personal data.
Changes to our Privacy Policy
Any changes we may make to our Policy in the future will be posted on this page and, where appropriate, notified to you by email. Please check back frequently to see any updates or changes to our Policy.
