Privacy Policy

This section summarises how we obtain, store and use information about you. It is intended to provide a very general overview only. It is not complete in and of itself and it must be read in conjunction with the corresponding full sections of this Privacy Policy.

Data controller: Neonatal Palliative Care How we collect or obtain information about you: when you provide it to us (e.g. by contacting us or providing information through our contact form), from your use of our website, using cookies, and occasionally, from third parties.

Information we collect:

Name, email address, IP address, information from cookies, information about your computer or device (e.g. device and browser type), information about how you use our website (e.g. which pages you have viewed, the time when you view them and what you clicked on and the geographical location from which you accessed our website (based on your IP address).

How we use your information:

For administrative and business purposes (particularly to contact you), to improve our business and website, to advertise our services, to analyse your use of our website, and in connection with our legal rights and obligations.

Disclosure of your information to third parties:

Only to the extent necessary to run our business, to our service providers, where required by law or to enforce our legal rights and obligations.

Do we sell your information to third parties (other than in the course of a business sale or purchase or similar event):

No

Use of automated decision-making and profiling:

We use automated decision-making and profiling through our use of remarketing advertisements and web analytics.
For further information, please see the main section below entitled Our use of automated decision-making and profiling.

How long we retain your information:

For no longer than necessary, taking into account any legal obligations we have (e.g. to maintain records for tax purposes), any other legal basis we have for using your information (e.g. your consent, performance of a contract with you or our legitimate interests as a business) and certain additional factors described in the main section below entitled How long we retain your information. For specific retention periods in relation to certain information which we collect from you, please see the main section below entitled How long we retain your information.

How we secure your information:

Using appropriate technical and organisational measures such as storing your information on secure servers, encrypting transfers of data to or from our servers using Secure Sockets Layer (SSL) technology, only granting access to your information where necessary.

Use of cookies:

We use cookies on our website including functional, analytical and marketing cookies. For more information, please visit our 'cookies policy'.

Transfers of your information outside the European Economic Area:

In certain circumstances, we will transfer your information outside of the European Economic Area, including to the United States of America. Where we do so, we will ensure appropriate safeguards are in place, including, for example, that the third parties we use who transfer your information outside the European Economic Area have self-certified themselves as compliant with the EU-U.S. Privacy Shield.

Your rights in relation to your information:

  • to access your information and to receive information about its use
  • to have your information corrected and/or completed
  • to have your information deleted
  • to restrict the use of your information
  • to receive your information in a portable format
  • to object to the use of your information
  • to withdraw your consent to the use of your information
  • not to have significant decisions made about you based solely on automated processing of your information, including profiling
  • to complain to a supervisory authority

Sensitive personal information:

We do not knowingly or intentionally collect what is commonly referred to as 'sensitive personal information'. Please do not submit sensitive personal information about you to us. For more information, please see the main section below entitled Sensitive Personal Information.

Our details

The data controller in respect of our website is Neonatal Palliative Care.

Information we collect when you visit our website

We collect and use information from website visitors in accordance with this section and the section entitled Disclosure and additional uses of your information.

Web server log information

We use our own server to host our website. Our website server automatically logs the IP address you use to access our website as well as other information about your visit such as the pages accessed, information requested, the date and time of the request, the source of your access to our website (e.g. the website or URL (link) which referred you to our website), and your browser version and operating system.

Our server is located in the United Kingdom.

Use of website server log information for IT security purposes

Our third-party hosting provider collects and stores server logs to ensure network and IT security and so that the server and website remain uncompromised. This includes analysing log files to help identify and prevent unauthorised access to our network, the distribution of malicious code, denial of services attacks and other cyber-attacks, by detecting unusual or suspicious activity.

Unless we are investigating suspicious or potential criminal activity, we do not make, nor do we allow our hosting provider to make, any attempt to identify you from the information collected via server logs.

Legal basis for processing:

compliance with a legal obligation to which we are subject (Article 6(1)(c) of the General Data Protection Regulation).

Legal obligation:

We have a legal obligation to implement appropriate technical and organisational measures to ensure a level of security appropriate to the risk of our processing of information about individuals. Recording access to our website using server log files is such a measure.

Legal basis for processing:

Our legitimate interests (Article 6(1)(f) of the General Data Protection Regulation).

Legitimate interests:

We have a legitimate interest in using your information for the purposes of ensuring network and information security.

Information we collect when you contact us

We collect and use information from individuals who contact us in accordance with this section and the section entitled Disclosure and additional uses of your information.

Email

When you send an email to the email address displayed on our website we collect your email address and any other information you provide in that email (such as your name, telephone number and the information contained in any signature block in your email).
Legal basis for processing: our legitimate interests (Article 6(1)(f) of the General Data Protection Regulation).
Legitimate interest(s): responding to enquiries and messages we receive and keeping records of correspondence.
Legal basis for processing: necessary to perform a contract or to take steps at your request to enter into a contract (Article 6(1)(b) of the General Data Protection Regulation).
Reason why necessary to perform a contract: where your message relates to us providing you with goods or services or taking steps at your request prior to providing you with our goods and services (for example, providing you with information about such goods and services), we will process your information in order to do so.

Transfer and storage of your information

We use a third-party email provider to store emails you send us. Our third-party email provider is Microsoft 365 (Microsoft, Inc.).
Microsoft may transfer and store emails you send us outside the European Economic Area. Where they do so, they will put appropriate safeguards in place.
For further information about the safeguards used when your information is transferred outside the European Economic Area, see the section of this privacy policy below entitled Transfers of your information outside the European Economic Area.

Phone

When you contact us by phone, we collect your phone number and any information provide to us during your conversation with us.
Legal basis for processing: our legitimate interests (Article 6(1)(f) of the General Data Protection Regulation). Legitimate interest(s): responding to enquiries and messages we receive and keeping records of correspondence.
Legal basis for processing: necessary to perform a contract or to take steps at your request to enter into a contract (Article 6(1)(b) of the General Data Protection Regulation). Reason why necessary to perform a contract: where your message relates to us providing you with goods or services or taking steps at your request prior to providing you with our goods and services (for example, providing you with information about such goods and services), we will process your information in order to do so).
Transfer and storage of your information
Information about your call, such as your phone number and the date and time of your call, is processed by our third-party telephone service provider and stored in the United Kingdom.

Post

If you contact us by post, we will collect any information you provide to us in any postal communications you send us.
Legal basis for processing: our legitimate interests (Article 6(1)(f) of the General Data Protection Regulation). Legitimate interest(s): responding to enquiries and messages we receive and keeping records of correspondence.
Transfer and storage of your information
Information you submit to us by post will be stored in the United Kingdom.
Information collected or obtained from third parties
This section sets out how we obtain or collect information about you from third parties.

Information received from third parties

Generally, we do not receive information about you from third parties. The third parties from which we receive information about you will generally include other businesses and clients we work with from time to time who may recommend our services to you. These could be businesses in any industry, sector, sub-sector or location.
It is also possible that third parties with whom we have had no prior contact may provide us with information about you.
Information we obtain from third parties will generally be your name and contact details, but will include any additional information about you which they provide to us.
Legal basis for processing: necessary to perform a contract or to take steps at your request to enter into a contract (Article 6(1)(b) of the General Data Protection Regulation). Reason why necessary to perform a contract: where a third party has passed on information about you to us (such as your name and email address) in order for us to provide services to you, we will process your information in order to take steps at your request to enter into a contract with you and perform a contract with you (as the case may be).

Legal basis for processing: consent (Article 6(1)(a) of the General Data Protection Regulation).

Consent:

Where you have asked that a third party to share information about you with us and the purpose of sharing that information is not related to the performance of a contract or services by us to you, we will process your information on the basis of your consent, which you give by asking the third party in question to pass on your information to us.

Legal basis for processing: our legitimate interests (Article 6(1)(f) of the General Data Protection Regulation).

Legitimate interests:

Where a third party has shared information about you with us and you have not consented to the sharing of that information, we will have a legitimate interest in processing that information in certain circumstances. For example, we would have a legitimate interest in processing your information to perform our obligations under a sub-contract with the third party, where the third party has the main contract with you. Our legitimate interest is the performance of our obligations under our sub-contract.
Similarly, third parties may pass on information about you to us if you have infringed or potentially infringed any of our legal rights. In this case, we will have a legitimate interest in processing that information to investigate and pursue any such potential infringement.

Where we receive information about you in error:

If we receive information about you from a third party in error and/or we do not have a legal basis for processing that information, we will delete your information.
Information obtained by us from third parties

In certain circumstances (for example, to verify the information we hold about you or obtain missing information we require to provide you with a service) we will obtain information about you from certain publicly accessible sources, both EU and non-EU, such as Companies House, online customer databases, business directories, media publications, social media, and websites (including your own website if you have one) and any affiliates.
Legal basis for processing: necessary to perform a contract or to take steps at your request to enter into a contract (Article 6(1)(b) of the General Data Protection Regulation). Reason why necessary to perform a contract: where you have entered into a contract or requested that we enter into a contract with you, in certain circumstances, we will obtain information about you from public sources in order to enable us to understand your business and provide services to you or services to a sufficient standard.
For example, we would obtain and/or verify your email address from your website or from a directory where you ask us to send you information by email but we do not possess the information or we need to confirm that we have recorded your email address correctly.
Legal basis for processing: our legitimate interests (Article 6(1)(f) of the General Data Protection Regulation). Legitimate interests: in certain circumstances, we will have a legitimate interest in obtaining information about you from public and private sources. For example, if you have infringed or we suspect that you have infringed any of our legal rights, we will have a legitimate interest in obtaining and processing information about you from such sources in order to investigate and pursue any suspected or potential infringement.
Our use of automated decision-making and profiling
We use automated decision-making and profiling. We do not consider that this has any legal effect on you or similarly significantly affects you.
You have the right to object to our use profiling described in this section. You can do that by opting-out of cookies and similar technologies in accordance with the method described in the relevant section below. If you do not want us to process your actual IP address (usually the IP address assigned to you by your Internet Service Provider) when you visit our website, you can use a Virtual Private Network (VPN) or a free service such as Tor.
You can find out more about our use of cookies and similar technologies (including the legal basis on which we use them) and how to opt out from them in our cookies policy, which is available here: https://neonatalpalliativecare.org/cookies

Logic involved:

By targeting individuals based on those whom we believe would be interested in our services, we are able to more effectively advertise our services, making our advertising more cost-effective and relevant.

Significance and envisaged consequences:

Advertisements will be displayed to you on Twitter if you meet the relevant criteria which form the basis of our advertising campaign. If you click on any relevant advertisements displayed to you on Twitter, your behaviour will be tracked using code and cookies we have installed on our website (if you have consented to the use of such technologies on our website) and your actions on our site will be tracked and the information shared with Twitter (you can access Twitter's privacy policy here: https://twitter.com/en/privacy).

How to object:

If you accepted the use of Twitter cookies using our cookie tool, you can use our cookie tool to turn it off and stop it processing your information as well.
Legal basis for processing: our legitimate interests (Article 6(1)(f) of the General Data Protection Regulation).

Legitimate interest:

Marketing our goods and services effectively.

Transfers of your information outside the European Economic Area
Your information will be transferred and stored outside the European Economic Area (EEA) in the circumstances set out below.
We will also transfer your information outside the EEA or to an international organisation in order to comply with legal obligations to which we are subject (compliance with a court order, for example). Where we are required to do so, we will ensure appropriate safeguards and protections are in place.

Email

Information you submit to us by email is transferred outside the EEA and stored on our third-party email provider's servers. Our third-party email provider is: Microsoft 365.
Microsoft may transfer and store emails you send us outside the European Economic Area. Where they do so, they will put appropriate safeguards in place.
You can access their privacy policy here: https://privacy.microsoft.com/en-gb/privacystatement

Google Analytics

Information collected by Google Analytics (your IP address and actions you take in relation to our website) is transferred outside the EEA and stored on Google's servers. You can access Google's privacy policy here: https://www.google.com/policies/privacy/

Country of storage:

United States of America. This country is not subject to an adequacy decision by the European Commission.

Safeguard(s) used:

Google has self-certified its compliance with the EU-U.S. Privacy Shield which is available here: https://www.privacyshield.gov/welcome. The EU-U.S. Privacy Shield is an approved certification mechanism under Article 42 of the General Data Protection Regulation, which is permitted under Article 46(2)(f) of the General Data Protection Regulation. You can access the European Commission decision on the adequacy of the EU-U.S. Privacy Shield here: http://ec.europa.eu/justice/data-protection/international-transfers/adequacy/index_en.htm

In accordance with Article 77 of the General Data Protection Regulation, you also have the right to lodge a complaint with a supervisory authority, in particular in the Member State of your habitual residence, place of work or of an alleged infringement of the General Data Protection Regulation.
For the purposes of the UK, the supervisory authority is the Information Commissioner's Office (ICO), the contact details of which are available here: https://ico.org.uk/global/contact-us/

Further information on your rights in relation to your personal data as an individual
The above rights are provided in summary form only and certain limitations apply to many of these rights. For further information about your rights in relation to your information, including any limitations which apply, please visit the following pages on the ICO's website:
https://ico.org.uk/for-organisations/guide-to-the-general-data-protection-regulation-gdpr/individual-rights/; and
https://ico.org.uk/for-the-public/is-my-information-being-handled-correctly/

You can also find out further information about your rights, as well as information on any limitations which apply to those rights, by reading the underlying legislation contained in Articles 12 to 22 and 34 of the General Data Protection Regulation, which is available here: https://eur-lex.europa.eu/legal-content/EN/TXT/PDF/?uri=CELEX:32016R0679

Verifying your identity where you request access to your information

Where you request access to your information, we are required by law to use all reasonable measures to verify your identity before doing so.
These measures are designed to protect your information and to reduce the risk of identity fraud, identity theft or general unauthorised access to your information.

How we verify your identity

Where we possess appropriate information about you on file, we will attempt to verify your identity using that information.
If it is not possible to identity you from such information, or if we have insufficient information about you, we may require original or certified copies of certain documentation in order to be able to verify your identity before we are able to provide you with access to your information.
We will be able to confirm the precise information we require to verify your identity in your specific circumstances if and when you make such a request.
Your right to object to the processing of your information for certain purposes

Sensitive Personal Information

'Sensitive personal information' is information about an individual that reveals their racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, genetic information, biometric information for the purpose of uniquely identifying an individual, information concerning health or information concerning a natural person's sex life or sexual orientation.
We do not knowingly or intentionally collect sensitive personal information from individuals, and you must not submit sensitive personal information to us.
If, however, you inadvertently or intentionally transmit sensitive personal information to us, you will be considered to have explicitly consented to us processing that sensitive personal information under Article 9(2)(a) of the General Data Protection Regulation. We will use and process your sensitive personal information for the purposes of deleting it.

Changes to our Privacy Policy

We update and amend our Privacy Policy from time to time.

Minor changes to our Privacy Policy

Where we make minor changes to our Privacy Policy, we will update our Privacy Policy with a new effective date stated at the beginning of it. Our processing of your information will be governed by the practices set out in that new version of the Privacy Policy from its effective date onwards.
Major changes to our Privacy Policy or the purposes for which we process your information
Where we make major changes to our Privacy Policy or intend to use your information for a new purpose or a different purpose than the purposes for which we originally collected it, we will notify you by email (where possible) or by posting a notice on our website.
We will provide you with the information about the change in question and the purpose and any other relevant information before we use your information for that new purpose. Wherever required, we will obtain your prior consent before using your information for a purpose that is different from the purposes for which we originally collected it.

Children's Privacy

Because we care about the safety and privacy of children online, we comply with the Children's Online Privacy Protection Act of 1998 (COPPA). COPPA and its accompanying regulations protect the privacy of children using the internet. We do not knowingly contact or collect information from persons under the age of 18. The website is not intended to solicit information of any kind from persons under the age of 18.
It is possible that we could receive information pertaining to persons under the age of 18 by the fraud or deception of a third party. If we are notified of this, as soon as we verify the information, we will, where required by law to do so, immediately obtain the appropriate parental consent to use that information or, if we are unable to obtain such parental consent, we will delete the information from our servers. If you would like to notify us of our receipt of information about persons under the age of 18, please do so by sending an email to info@neonatalpalliativecare.com.
NHS Privacy Notice

As part of our work, we may process data for the NHS. This has special privacy concerns that are addressed within the NHS Privacy Notice.
California Do Not Track Disclosures
“Do Not Track” is a privacy preference that users can set in their web browsers. When a user turns on a Do Not Track signal in their browser, the browser sends a message to websites requesting that they do not track the user. For information about Do Not Track, please visit www.allaboutdnt.org
At this time, we do not respond to Do Not Track browser settings or signals. In addition, we use other technology that is standard to the internet, such as pixel tags and other similar technologies, to track visitors to the website. Those tools may be used by us and by third parties to collect information about you and your internet activity, even if you have turned on the Do Not Track signal. For information on how to opt out from tracking technologies used on our website, see our cookies policy which is available here: https://neonatalpalliativecare.org/cookies

Copyright

The copyright in this Privacy Policy is either owned by, or licensed to, us and is protected by copyright laws around the world and copyright protection software. All intellectual property rights in this document are reserved.