Privacy Policy

1. Introduction

This Data Privacy Notice provides detailed information about the types of personal data we may collect about you, what we do with that information and how we will store that information and keep it secure and safe.

2. Who are OrthOracle?

OrthOracle Limited is a company which is incorporated under the laws of England and Wales under No. 09792457 and whose registered office is at Meriden House, 6 Great Combow Halesowen, B63 3AB.  

The business of OrthOracle is running the educational website at www.orthoracle.com (the Website) and the provision of ancillary activities.

OrthOracle is a data processor for the purposes of the Data Protection Act 1988 and the GDPR.

3. Contacting OrthOracle

You can contact OrthOracle by writing to us at the above address, or by emailing us at [email protected] or calling us on +44 (0) 20 8150 0074.

4. Who is responsible for the management of data protection at OrthOracle?

Mr Mark Herron, FRCS is responsible for the management of data protection at OrthOracle. He can be contacted using the contact details given in sections 2. and 3. above.

5. OrthOracle Direct Mail Database

OrthOracle has a direct mail database. If your details are on it then those details will only comprise either (a) your email address or (b) you name and your email address, unless you have also subscribed for one of our Atlas access packages via the Website.

6. What sort of personal data do we hold and collect?

In addition to the personal data in our Direct Mail Database, we may hold other types of personal data:-

Information you give us

You may give or already have given us information about you by filling in forms on the Website or by corresponding with us by phone, e-mail or otherwise. This includes information you provide when you register to use the Website, subscribe to our service, search for a product, place an order on the Website, participate in discussion boards or other social media functions on the Website, enter a competition, promotion or survey and when you report a problem with the Website. The information you give or already have given us may include your name, address, e-mail address and phone number, financial and credit or debit card information, personal description, qualifications and details of your employment and photograph.

Information we collect about you

With regard to each of your visits to the Website we may automatically collect the following information:

• technical information, including the Internet protocol (IP) address used to connect your computer to the Internet, your login information, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform;
• information about your visit, including the full Uniform Resource Locators (URL) clickstream to, through and from our site (including date and time); products you viewed or searched for; page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), and methods used to browse away from the page and any phone number used to call our customer service number.

7. Information that we do not hold

We do not hold any information whatsoever that would enable us to identify any individual patients on whom were performed any of the operations depicted in the Atlases on the Website. Those images were taken with the informed consent of the patients concerned who also consented to their use on the Website. The taking of the photographs was compliant with the GMC guidance on the taking and use of such photographs, the current version of which can be found at https://www.gmc-uk.org/ethical-guidance/ethical-guidance-for-doctors/making-and-using-visual-and-audio-recordings-of-patients.  

8. Cookies

The Website uses cookies to distinguish users from other users of the Website. This helps us to provide visitors to the Website with a good experience when they browse the Website and also allows us to improve our site. For detailed information on the cookies we use and the purposes for which we use them see our Cookie policy.

9. How do we use your personal data?

Your details on our Direct Mail Database

This personal data will be solely used by us to communicate with you about OrthOracle and as set out in paragraph 14 below.

Information you give to us

We will use this information:

• to carry out our obligations arising from any contracts entered into between you and us and to provide you with the information, products and services that you request from us;
• to provide you with information about other goods and services which we offer that are similar to those that you have already purchased or enquired about;
• to provide you, or permit selected third parties to provide you, with information about similar goods or services we or they feel may interest you;
• to notify you about changes to our services;
• to ensure that content from the Website is presented in the most effective manner for visitors to that site and for their computer or mobile devices.

Information we collect about you

We will use this type of information:

• to administer the Website and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes;
• to improve the Website to ensure that content is presented in the most effective manner for visitors and for their computer or mobile devices;
• to allow you to participate in interactive features of our services, when you choose to do so;
• as part of our efforts to keep the Website safe and secure;
• to measure or understand the effectiveness of advertising we serve to you and others, and to deliver relevant advertising to you;
• to make suggestions and recommendations to you and users of the Website about goods or services that may be interest you or them.

Information we receive from other sources

We may combine this type of information with information you give to us and information we collect about you. We may use this information and the combined information for the purposes set out above (depending on the types of information we receive).

10. The legal basis on which OrthOracle processes personal data

The law on data protection provides a number of different grounds that a company such as OrthOracle can rely on to make its processing of personal data lawful.

OrthOracle relies on the following four legal grounds to process personal data:-

You have consented to our using your personal data

We can collect and process your data with your consent.

This will be the case if you have provided your details to us historically for the purposes of our contacting you about our products and services or where you have subscribed to one of our Atlas access packages.

OrthOracle’s Contractual Obligations

In certain circumstances, we can process your personal data to comply with our contractual obligations. This applies where for example you have subscribed to one of our Atlas access packages.

OrthOracle’s legitimate interests

The law states that in specific situations, OrthOracle can process your personal data to pursue our legitimate interests in a way which might reasonably be expected as part of running our business and which does not materially impact your rights, freedom or interests.

Legal compliance

If complying with legal obligations upon us requires us to, we may collect and process your personal data.

11. How we protect personal data

We treat your personal data with the utmost care and take all appropriate steps to protect it.

All information you provide to us is stored on our secure servers. Any payment transactions will be encrypted. Where we have given you (or where you have chosen) a password which enables you to access certain parts of the Website, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.

We regularly monitor our computer systems for possible vulnerabilities and attacks and use state of the art firewalls and anti-virus software, which is regularly updated.

12. Data Breaches

In the unlikely event that there were to be any unauthorised access to (or an event occurs that creates a real risk of any unauthorised access to) any personal data which OrthOracle holds, then OrthOracle will, if it considers that the such events give rise to a high risk of affected individuals being adversely impacted, notify the affected individuals as soon as reasonably practicable.

13. How long will we keep personal data?

Whenever OrthOracle collects or processes your personal data, it will only keep it for as long as it is reasonably necessary for the purpose for which it was collected.

At the end of that retention period, your data will be deleted completely.

14. Who do we share personal data with?

OrthOracle may share your personal information with any member of our group, which means our subsidiaries, our ultimate holding company and its subsidiaries, as defined in section 1159 of the UK Companies Act 2006.

We may disclose your personal information to third parties:

• In the event that we sell or buy any business or assets, in which case we may disclose your personal data to the prospective seller or buyer of such business or assets.
• If OrthOracle or substantially all of its assets are acquired by a third party, in which case personal data held by it about the users of this Site will be one of the transferred assets.

If we are under a duty to disclose or share your personal data in order to comply with any legal obligation, or in order to enforce or apply our terms of use and other agreements; or to protect the rights, property, or safety of OrthOracle, our users or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction.

We may in addition share your information with selected third parties including:

• Business partners, suppliers and sub-contractors for the performance of any contract we enter into with them or you.
• Advertisers and advertising networks that require the data to select and serve relevant adverts to you and others.
• Analytics and search engine providers that assist us in the improvement and optimisation of the Website.

The policy we apply to those organisations to keep your data safe and protect your privacy includes the following elements:-

(a) We provide only the information they need to perform their specific services.

(b) They may only use your data for the exact purposes we specify in our written contract with them.

(c) We work closely with them to ensure that your privacy is respected and protected at all times.

(d) If we stop using their services, any of your data held by them will either be deleted or rendered anonymous.

(e) Such organisations must have in place state of the art IT security systems and policies to keep your data secure.

15. Where personal data may be processed

We will only process personal data within the EEA. The EEA includes all EU Member countries as well as Iceland, Liechtenstein and Norway.

If personal data is stored on a cloud based server that may be located outside the EEA. We would only use such a server if our contractual relationship with the cloud services provider ensured sufficient protection of personal data.

Personal data may also be processed by staff operating outside the EEA who work for us or for one of our business partners. We will take all steps reasonably necessary to ensure that personal data is treated securely and in accordance with this privacy policy and the law.

16. What are your rights over your personal data?

You have the legal right to request:

– Access to the personal data we hold about you, free of charge in most cases.

– The correction of your personal data when incorrect, out of date or incomplete.

– That we stop using your personal data for direct marketing.  

– That we stop any consent-based processing of your personal data after you withdraw that consent.

– That any decision made based solely on the basis of automatic processing of your data (i.e. where no human has yet reviewed the outcome and criteria for the decision) is reviewed by a human being.

– A copy of any information about you that OrthOracle holds at any time, and also to have that information corrected if it is inaccurate. To ask for a copy of information we hold about you please contact our Data Protection Officer, whose details are set out in paragraphs 2 and 3 above.

17. How can you stop OrthOracle’s use of your personal data for direct marketing?

There are several ways you can stop direct marketing communications from us:

Click the ‘unsubscribe’ link in any email communication that we send you. We will then stop any further emails and delete your contact details from our direct mail database.

Write, email or phone our data protection officer, whose details are set out in paragraphs 2 and 3 above.

18. Third party websites

The Website may, from time to time, contain links to and from the websites of our partner networks, advertisers and affiliates.  If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies.  Please check these policies before you submit any personal data to these websites.

19. Changes to our privacy policy

Any changes we may make to our privacy policy in the future will be posted on this page and, where appropriate, notified to you by e-mail. Please check back frequently to see any updates or changes to our privacy policy.

20. Contacting the Regulator

If you feel that your data has not been handled correctly, or you are unhappy with our response to any requests you have made to us regarding the use of your personal data, you have the right to lodge a complaint with the Information Commissioner’s Office.

You can contact them by calling 0303 123 1113.

Or go online to www.ico.org.uk/concerns.

If you are based outside the UK, you have the right to lodge your complaint with the relevant data protection regulator in your country of residence.

21. Further Information

Questions, comments and requests regarding this privacy policy are welcomed and should be addressed to [email protected].