A “controller” is a person or organisation who alone or jointly determines the purposes for which and the way any personal data is or is likely to be processed. Unless we notify you otherwise, we are the controller of your personal data.

Any inquiries about your data should either be sent to us on email at info@radiidevices.com or sent in a letter to Engine Shed, Station Approach, Bristol, BS1 6QH, United Kingdom.

This privacy notice applies to the processing of personal data by us in connection with any:

• Organisations or persons for the provision of services by us.
• Suppliers for the provision of products and services to us by suppliers or service providers.
• Visitors on our website.

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. This is known as anonymised data. Anonymised data falls outside the scope of Data Protection Laws.

Radii Devices may collect, use, store and transfer different kinds of personal data about you which we have grouped together. The collection of personal data depends on what services we offer to you.

• Identity Data includes first name, last name, username, date of birth or similar identifier and title.
• Contact Data includes billing address, delivery address, email address and telephone numbers.
• Financial Data includes bank account and payment card details.
• Transaction Data includes details about payments to and from you and other details for the provision of 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 our website.
• Profile Data includes your username and password, searches made by you, your ratings and comments, preferences, feedback and survey responses.
• Usage Data includes information about how you use our website and services.
• Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.

We collect and use aggregated data about prosthetics to improve our services. We may also aggregate data to enable research or analysis so that we can better understand and serve those who require prosthetic services. Where aggregated data does not directly reveal an identifiable individual, it will not fall under Data Protection Laws. However, where we combine or connect aggregated data with personal data so that it can directly or indirectly identify an individual, we treat the combined data as personal data which will be used in accordance with this privacy notice.

During the course of our prosthetics services or studies with providers such as medical professionals where personal data is collected, we will obtain the necessary consent to process your personal data including special categories of data (known as sensitive data such as medical records where required).

Directly from you: You give us your personal data in your direct interactions with us. Such personal data includes Identity Data, Contact Data, Financial Data, Profile Data, Usage Data, Technical Data, Marketing and Communications Data (i) by filling in forms on our website (ii) by corresponding with us by email or post (iii) by calling us over the telephone.

This includes personal data you provide when you:

• contract with us to use our services
• request marketing to be sent to you
• give us feedback or contact us with concerns
• participate in our marketing or other promotional events
• participate in studies

From use of our website

We may gather information and statistics collectively about visitors to our website. Analysis of this information demonstrates the most frequently used sections of the website and assists us in continually improving the online service. You give us your personal data, which includes Profile Data, Usage Data, Technical Data and/or Marketing and Communications Data when you use our website or which we have agreed with you to use or when you review any publications or marketing material we send you. Please see our cookies notice [insert link] for more information.

Indirectly: Third-party sources: We may receive Identity Data and Contact Data about you from third parties when:

• we provide our services or other parties send us your personal data to enable the provision of those service such as medical professionals who pass on your details to us
• you provide your personal data to a third party for the purpose of sharing it with us

We may use professional public directories as an indirect source to contact you such as clinicians’ directories.

Where we need to collect personal data by law or under the terms of a contract we have with you and you do not provide that information 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 our services. In this case we may have to cancel our service but we will notify you if this is the case at the time.

Radii Devices will only use your personal data when the law allows us to. We will use your personal data in the following circumstances:

• Performance of a contract: Where we need to perform the contract we are about to enter into or have entered into with you. For example when you sign up to our services.
• Legal obligation: Where we need to comply with a legal obligation. For example for accounting or legal purposes.
• Legitimate interests: 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.
• Consent: Certain situations requires us to collect personal data with your consent such as when you consent to participate in a study, when you consent to a box that confirms you are happy to receive email newsletters from us, or consent to our service. Where we rely on consent you have the right to withdraw consent at any time. Please contact us at info@radiidevices.com to withdraw consent.

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.

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 Radii Devices will notify you and we will explain the legal basis which allows us to do so.

You will receive marketing and new content communications from us if you have created an account and chosen to opt in to receiving those communications. We may make suggestions and recommendations to you about goods or services that may be of interest to you. You can unsubscribe from receiving marketing communications from us by using the unsubscribe methods contained in communications we send to you or by contacting us. Where you opt out of receiving marketing communications this will not apply to personal data provided to us as a result of using our service, your service experience or other interactions with this website.

We may have to share your personal data with the parties set out below:

• Internally: Your personal data will be used by our employees and contractors who are working on providing your services to you on a need-to-know basis.
• Suppliers: This would include service providers who support our business including IT and communication suppliers, marketing administration providers and outsourced business support to ensure our service runs smoothly.
• Medical professionals and health organisations: For the purpose of our prosthetics services to individuals who may require it.
• Professional advisers: This would include lawyers, bankers, auditors and insurers who provide consultancy, banking, legal, insurance and accounting services.
• Law enforcement bodies, regulators and other authorities: This is to comply with our legal requirements or adhere to good practices.
• Advertising networks and analytics service providers: This is to support and display ads on our website and other social media tools.
• Third parties: This is in the context of the acquisition or transfer of any part of our business or in connection with the business reorganisation. 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 notice.

We ensure a similar degree of protection is afforded whenever we transfer personal data out of the UK by ensuring at least one of the following safeguards is implemented:

1. We will only transfer your personal information to countries that have been deemed to provide an adequate level of protection for personal information; or
2. We will use specific contracts approved for use in the UK which give personal information the same protection it has in the UK. For example, the use of Article 46 UK/EU GDPR safeguard mechanisms to transfer personal data.

If you would like to find out more about how we safeguard personal data in the context of international transfer please contact us.

We are concerned with keeping your data secure and protecting it from inappropriate disclosure. We implement a variety of security measures to ensure the security of your personal data on our systems, including using systems which adopt a secure protocol and encrypt data at rest and in-transit. Any personal data collected by us is only accessible by a limited number of employees who have special access rights to such systems and are bound by obligations of confidentiality.

If and when we use subcontractors to store your data, we will not relinquish control of your personal data or expose it to security risks that would not have arisen had the data remained in our possession. However, unfortunately no transmission of data over the internet is guaranteed to be completely secure. It may be possible for third parties not under the control of Radii Devices Ltd to intercept or access transmissions or private communications unlawfully. While we strive to protect your personal data, we cannot ensure or warrant the security of any personal data you transmit to us. Any such transmission is done at your own risk. If you believe that your interaction with us is no longer secure, please contact us.

Account holders: Your account information will be protected by a password for your privacy and security. You need to prevent unauthorised access to your account and personal information by selecting and protecting your password appropriately and limiting access to your computer or device and by signing off after you have finished accessing your account. You can access information associated with your account by logging into your account you created with us.

Your account information will be protected by a password for your privacy and security. You need to prevent unauthorised access to your account and personal information by selecting and protecting your password appropriately and limiting access to your computer or device and by signing off after you have finished accessing your account.

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 information we consider the amount, nature and sensitivity of the personal information, the potential risk of harm from unauthorised use or disclosure of your personal information, the purposes for which we process your personal information and whether we can achieve those purposes through other means and the applicable legal, regulatory, tax, accounting or other requirements.

Following the end of a study, data will be securely archived for a period of 10 years.

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.

Under certain circumstances, you have rights under Data Protection Laws. You can:

• Request access to your personal data: This is known as a "data subject access request" and enables you to receive a copy of the personal data Radii Devices hold about you.
• Request correction of your personal data: This enables you to have any incomplete or inaccurate information we hold about you corrected.
• 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. Note: We may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you at the time of your request.
• Object to processing of your personal data: This is where we are processing your personal data based on a legitimate interest or those of a third party and you may challenge this.  However, we may be entitled to continue processing your information based on our legitimate interests or where this is relevant to any legal claims.  See also Marketing and Content Updates.
• Request restriction of processing your personal information: 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 information's accuracy (b) where our use of the information is unlawful but you do not want us to erase it (c) where you need us to hold the information 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 information but we need to verify whether we have overriding legitimate grounds to use it.
• Request transfer of your personal information (“data portability”): This is where in some circumstances we will provide to you or a third party you have chosen your personal data in a structured, commonly used, machine-readable format.
• Right to withdraw consent: This is where we are relying on consent to process your personal data. This will not affect the lawfulness of any processing carried out before you withdraw your consent. Depending on the processing activity, if you withdraw your consent we may not be able to provide certain services to you. We will advise you if this is the case at the time you withdraw your consent.
• Automated decision making: This is where decisions are made about you by automated means. We do not carry out automated decision making which results in legal or similarly effect.

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. If you wish to update your personal data please contact us.

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. We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal information or to exercise any of your other rights. This is a security measure to ensure that personal information 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.

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.

If you wish to exercise any of the rights set out above, please contact us at info@radiidevices.com.

We would appreciate the chance to deal with your concerns in the first instance. If you have unresolved concerns and you live or work in the UK or believe that a personal data breach happened in the UK you have the right to complain at any time to the Information Commissioner's Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk).

If you live or work outside the UK or you have a complaint concerning our personal data processing activities you may lodge a complaint with another supervisory authority.  

This privacy notice may be changed from time to time in response to legal, technical or business developments. We will take appropriate measures to inform you when we update our privacy notice. We will obtain your consent to any material privacy notice changes if and where this is required by applicable Data Protection Laws.