6.1 Data Protection / GDPR
Cobra Biologics Limited respects your privacy and is committed to protecting your personal data. This privacy notice will inform you as to how we look after your personal data when you visit our website (regardless of where you visit it from) and tell 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. Alternatively you can download a pdf version of the policy here. Please also use the Glossary to understand the meaning of some of the terms used in this privacy notice.
IMPORTANT INFORMATION AND WHO WE ARE
Purpose of this privacy notice
This privacy notice aims to give you information on how Cobra Biologics Limited collects and processes your personal data through your use of this website, including any data you may provide through this website when you submit a contact us enquiry, event meeting request or sign up to our newsletter.
This website is 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.
Cobra Biologics Limited is the controller and responsible for your personal data (collectively referred to as COMPANY, we, us or our in this privacy notice).
We have appointed a Data Protection Team (DPT) who is responsible for overseeing questions in relation to this privacy notice. This team consists of: Finance Director – Lee Warren, Human Resources Director – Sheena Pumford, and Sales and Marketing Director – Philip Ridley Smith. If you have any questions about this privacy notice, including any requests to exercise your legal rights] please contact the DPT using the details set out below.
Full name of legal entity: Cobra Biologics Limited
Names and contact email addresses: Finance Director – Lee Warren (firstname.lastname@example.org), Human Resources Director – Sheena Pumford (email@example.com), and Sales and Marketing Director – Philip Ridley Smith (firstname.lastname@example.org).
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). 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
This version was last updated on 24th May 2018.
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.
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.
When you leave our website or interact with us on social media, we encourage you to read the privacy notice of every website you visit.
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 follows:
Identity Data includes first name, last name, title, company name.
Contact Data includes email address and telephone numbers.
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 this website.
Marketing and Communications Data includes your preferences in receiving marketing from us and your communication preferences.
We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does 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.
HOW IS YOUR PERSONAL DATA COLLECTED?
We use different methods to collect data from and about you including through:
Direct interactions. You may give us your Identity and Contact Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
- apply for our products or services;
- subscribe to our service or publications;
- request marketing to be sent to you;
- enter a competition, promotion or survey; or
- give us some feedback.
Third parties or publicly available sources. We may receive personal data about you from various third parties and public sources as set out below:
Technical Data from the following parties:
- analytics providers;
- advertising networks; and
- search information providers.
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:
- Where we need to perform the contract we are about to enter into or have entered into with you.
- Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
- Where we need to comply with a legal or regulatory obligation.
- You have the right to withdraw consent to marketing at any time by contacting the DPT.
DISCLOSURES OF YOUR PERSONAL DATA
We may have to share your personal data with third parties. We set out in the relevant table the identity and purpose of such disclosure where it is possible for us to do so.
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 parties 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. Third parties who process your data on our behalf are subject to contracts under which their processing activities are managed.
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 the DPT 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.
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 and Usage 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 services from us and, in each case, you have not opted out of receiving that marketing.
You can ask us to stop sending you marketing messages at any time by contacting the DPT or following opt-out links on any marketing message sent to you.
Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of an enquiry or service purchase.
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 the DPT.
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 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 necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.
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 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 the DPT.
In some circumstances you can ask us to delete your data: see [Request erasure] below for further information.
In some circumstances we may 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.
YOUR LEGAL RIGHTS
Under certain circumstances, you have rights under data protection laws in relation to your personal data.
If you wish to exercise the right to access this information, please contact the DPT.
No fee usually required
You will not have to pay a fee to access your personal data. However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may 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. 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.
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 the DPT.
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 or regulatory obligation means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.
External Third Parties
Service providers acting as processors who provide IT and system administration services.
Professional advisers acting as processors or joint controllers including lawyers, bankers, auditors and insurers who provide their services.
YOUR LEGAL RIGHTS
You have the right to:
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.
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.
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.
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.
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: (a) if you want us to establish the data's accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) 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; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
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.
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.
7. Intellectual Property
All web site design, text, pictures, graphics and the selection and arrangement of them and all software compilations, coding, underlying source code, software and all other material on this web site are copyright  Cobra Biologics Ltd unless otherwise acknowledged. ALL RIGHTS ARE RESERVED.
Infringement of our copyright in this web site or the materials associated with this web site may lead to criminal and/or civil sanctions in the UK, US and other countries. Permission is granted to you to electronically copy and to print hard copy portions of this web site for the sole purpose of using this web site as a research and information resource provided you agree not to change and/or delete any content, web design and/or layout contained in that material. Any other use of materials on this web site, including modification, distribution or republication, are strictly prohibited. If you believe that any content of our web site in any way infringes intellectual property rights belonging to you or any third party, please contact us immediately.
Please note that viruses and similar destructive programs are an inherent risk of communication via the Internet.
We will use our reasonable endeavours to prevent contamination of any material sent to you with any virus or similar destructive code.
We do not, to the maximum extent permitted by law, accept any liability for any virus or similar destructive code which computer equipment and/or software used by you may suffer as a result of your accessing our web site and/or any other communication via the Internet between you and us. It is your responsibility to scan what you choose to download from our web site to ensure that it is free of such items as viruses, worms, trojan horses and other similar destructive code.
9. General Disclaimers
Neither we nor any of our affiliates, directors, employees or other representatives will be liable for losses arising out of or in connection with the use of this web site. We are only providing this web site and its contents on a “as is” basis and we make no (and expressly disclaim all) representations and/or warranties of any kind with respect to this web site or its contents including without limitation warranties of merchantability and/or fitness for a particular purpose. In addition we do not represent or warrant that the information accessible from or via this web site is accurate, complete or current. No action should be taken or omitted to be taken in reliance of any information contained on this web site and we shall have no liability for any action taken in such reliance. The limitations of liability in relation to this web site apply to all damages of any kind, including, without limitation, compensatory, direct, indirect or consequential damages, loss of data, income, production or profit, loss of or damage to property and claims of third parties. The limitations of liability in relation to this web site do not limit our liability to the extent that it cannot be limited and/or excluded by applicable law. The use of our web site is subject to English law. Any dispute and/or claim arising out of this web site is subject to the non-exclusive jurisdiction of the English courts.
You are liable for any telephone charges and any charges made by your internet service provider as a result of your use of the internet service.
Any rights not expressly granted by us are reserved.