Privacy and Cookies

Introduction

SILVIBIO LTD (the “Company”) respects your privacy and is committed to protecting your personal data. This privacy policy will inform you about how we look after your personal data when you share it with us or visit our website and tell you about your privacy rights and how the law protects you.

1.Important information and who we are

Purpose of this privacy policy

This privacy policy aims to give you information on how we collect and process your personal data.

This policy ensures that we meet the Data Protection Principles which require us to ensure that personal information we collect is:

Handled fairly and lawfully
Kept and used only for limited purposes
Required for a valid legal reason
Correct and up to date
Handled confidentially
Stored securely
Not transferred to unapproved countries outside the European Economic Area (EEA)

Who we are

The Company is the controller and responsible for your personal data (collectively referred to as “we”, “us” or “our” in this privacy policy).

If you have any questions about this privacy policy, including any requests to exercise your legal rights, please contact us using the details set out below.

Contact details

If you have any questions about this privacy policy or our privacy practices, please contact us in the following ways:

Postal address:

Midlothian Innovation Centre

Pentlandfield

Roslin

Midlothian

EH25 9RE

Email address: alicja@silvibio.co.uk

If you have any concerns about our use of your personal information, you can make a complaint to us using the contact details above.

You can also make a complaint to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues.

Helpline number: 0303 123 1113

ICO website: https://www.ico.org.uk

Please contact us in the first instance as we would appreciate the chance to deal with your concerns before you approach the ICO.

Your acceptance of this privacy policy and our right to change it

By providing your personal information to us, you understand that we will collect and use your information in the ways set out in this policy.

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.

We may make changes to this privacy policy from time to time. If we do so, we will post the changes on this page and they will apply from the date on which they are posted.

Third-party links

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. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy policy of every website you visit.

2. The data we collect about you

If you communicate with us using information from the ‘Contact Us’ link on our website or by post or telephone, we will ask you for information such as your email address, the type of product you subscribe to and/or purchase from us and the type of customer you are (e.g. personal subscriber, registrant, website visitor etc.). You may also choose to provide additional personal information, for example, in the form of an attachment by email or by post.

If you visit our website, we may automatically collect technical and usage data (see Cookie Policy).

Like many companies, we use “cookies” on our website(s). Cookies are bits of text that are placed on your computer’s hard drive when you visit a website. We use cookies to tell us, for example, whether you have visited us before or if you are a new visitor and to help us identify site features in which you may have the greatest interest. Cookies may enhance your online experience by saving your preferences while you are visiting a particular site. Most browsers will tell you how to stop accepting new cookies, how to be notified when you receive a new cookie, and how to disable existing cookies. Please note, however, that without cookies you may not be able to take full advantage of all our website features.

3. 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 it is necessary for our legitimate interests and your interests and fundamental rights do not override those interests.
Where we need to comply with a legal or regulatory obligation.
Where we need to execute a contract that we are about to enter into or have entered into with you or your organisation.

Purposes for which we will use your personal data

Depending on your relationship with the Company, we need to collect, hold and process personal data about you in order to:

protect and support our business and personnel
to comply with legal and regulatory requirements.

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 us.

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.

Please be advised that we do not use any automated decision mechanisms in relation to personal data.

4.Disclosures of your personal data

In certain circumstances we may share your personal data with our professional advisors and service providers who provide the Company with support and other services essential to the functioning of our business.

In the event of a change to our organisation, personal data will be shared with third parties to whom we may choose to sell, transfer or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. 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 policy.

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-party service providers 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.

5. How we protect your personal data

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 instruction, 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.

6. How we store personal data, and the periods for which we store it

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 if we reasonably believe there is a prospect of litigation in respect to our relationship with you or your employer or organisation.

In some circumstances you can ask us to delete your data: see Section 8 (Your legal rights) below for further information.

7. International transfers

We share your personal data with our website provider, Wix.com, Inc which is based in the US. This will involve transferring your data outside the European Economic Area (EEA).

Where we use providers based in the US, we may transfer data to them if they are part of the Privacy Shield which requires them to provide similar protection to personal data shared between Europe and the US.

Wix.com, Inc is certified under the EU-US Privacy Shield Framework as set forth by the U.S. Department of Commerce, regarding the collection, use, and retention of personal information transferred from the European Union to the United States, and therefore adheres to the Privacy Shield Principles. For further details, see European Commission: EU-US Privacy Shield (https://ec.europa.eu/info/law/law-topic/data-protection/international-dimension-data-protection/eu-us-data-transfers_en) .

Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.

In addition, SilviBio uses Subprocessors to support delivery of our services. A subprocessor is a third party data processor who has, or potentially will have, access to our process customer data. Below you can find a list including the identity, location and role of each Subprocessor.

Prior to engaging any third party Subprocessor, SilviBio evaluates their security and privacy posture.

8. Your legal rights

Under certain circumstances, you have rights under data protection laws in relation to your personal data.

You may be entitled to:

request access to your personal data (commonly known as a “data subject access request”) which enables you to receive a copy of the personal data we hold about you
request the correction of your personal data;
request the deletion of your personal data in certain circumstances, for example where there is no good reason for us continuing to process it;
request the restriction of the processing of your personal data in certain circumstances;
object to the processing of your personal data. In this case, we will no longer process your personal data unless there are compelling legitimate grounds for doing so or where it is necessary in relation to a legal claim; and
request the transfer of certain personal data to you or to a third party (in a structured, commonly used, machine-readable form).

If you would like more information about your rights, to exercise these rights, or if you have any concerns about the processing of your personal data, please contact us. If you choose to exercise your rights, we will respond in accordance with, and to the extent required by, our legal obligations.

If you believe that we have illegally processed your personal data, or if you have suffered as a result of unlawful processing of your personal data, you can present a claim to your local supervisory authority.

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. Alternatively, we could refuse to comply with your request in these circumstances.

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). 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.

We try to respond to all legitimate requests within one month from the day on which we receive a request. All requests will be considered carefully, and we will endeavour to comply with all legitimate requests so far as possible. Occasionally it could 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.

9. Policy Review

This policy will be reviewed as appropriate and updated when required.