NuCanna Privacy Policy – Page 1 NuCanna – [Updated 03/03/2019]

Welcome to NuCanna and the NuLife Group’s privacy policy

Your privacy is really important to us. We want you to feel confident that your details are secure with us, and we want to help make your experience on the Internet and our websites as enjoyable and easy as possible. We take many steps to ensure your data is safely stored and we will never sell your information on to third parties.

Who are we?
We are the owners of the website NuCanna.org. We are NUCANNA Ltd, a company incorporated in England and Wales under company number 11268627, with our registered address as set out below.

Who’s the Data Controller?
For the purposes of data protection laws, we are the “data controller” of all personal information that we collect, use and/or otherwise process about you under this Privacy Policy.

How to contact us

If you have any questions about this Privacy Policy or the ways in which we handle your personal information you may contact us as follows:

The Data Protection Officer

NuCanna Ltd
International House
776-778 Barking Road
London
E13 9PJ

email: info@nucanna.org – please title your email Privacy Policy

Description of Users and Acceptance of Terms
This Privacy Policy applies to visitors to the Websites, who view only publicly-available content (“Visitors”), and users who register with us (“Registered Users”) and wish to purchase a product or service through one of our Websites.

By visiting any of our Websites, Visitors are agreeing to the terms of this Privacy Policy and the accompanying Terms of Use.

By registering with us and purchasing a product or service through one of our Websites, each Registered User is agreeing to the terms of this Privacy Policy, the accompanying Terms of Use.

By providing us information offline, you are also agreeing to the terms of this Privacy Policy

 OUR PRIVACY POLICY

This privacy notice explains how we collect and use your personal data and tells you about your privacy rights. Not only do we want you to feel reassured, we are also under a legal obligation to let you know what personal information we collect about you, what we use it for and on what basis. We always need a good reason and we must also explain to you your rights in relation to that information. You have the right to know what information we hold about you and to have a copy of it, and you can ask us to change or sometimes delete it.

The NuCanna Privacy Policy aims to demonstrate our firm commitment to privacy and security. This Privacy Policy describes how NuCanna collects needed information from all users of our Internet services (the “Services”) including those who access some of our Services but do not create accounts (“Visitors”) as well as those who may purchase Products and/or pay a monthly service fee to subscribe to the Service (“Members”). This policy also describes what we do with the information we collect, and the choices our Visitors and Members have concerning the collection and use of such information.

We ask that you read this Privacy Policy carefully and make the correct choices for you. We are happy to provide any additional information or explanation needed and/or answer any questions you may have. Our contact details are listed above.

Data Subject’s Rights.

Under GDPR you have a number of Rights which we have outlined below:

  • Right of Access.
    You are entitled to access your personal data so that you are aware of and can verify the lawfulness of the processing.  This is achieved by logging into the www.nucanna.org website. Alternatively, this can be achieved through the mechanism of Subject Access Rights (SAR) and you have the right to obtain:

    • Confirmation that your data is being processed;
    • Access to your personal data (a copy); and
    • Other supplementary information, which corresponds to the information in this privacy notice.
  • Right of Rectification. You are entitled to have personal data rectified if it is inaccurate or incomplete. This can be achieved directly through logging into the www.nucanna.org website and amending the details about yourself.  Alternatively, NuCanna Ltd will respond within one month of your email request.
  • Right of Erasure.  You may request the deletion or removal of personal data where there is no compelling reason for its continued processing. The Right to Erasure does not provide an absolute ‘right to be forgotten,’.  However, you do have a right to have personal data erased and to prevent processing in specific circumstances:
    • Where the personal data is no longer necessary in relation to the purpose for which it was originally collected/processed;
    • When you withdraw consent (and this is the basis of processing);
    • When you object to the processing and there is no overriding legitimate interest for continuing the processing;
    • The personal data was unlawfully processed;
    • The personal data has to be erased in order to comply with a legal obligation; and
    • The personal data is processed in relation to the offer of information society services to a child, which NUCANNA Ltd does not provide.
  • Right to Restrict Processing.  Under GDPR, you have a right to ‘block’ or suppress processing of personal data. When processing is restricted, NUCANNA Ltd is permitted to store the personal data, but not further process it. In this event exactly what is held and why will be explained to you.
  • Right to Data Portability.  You may request to obtain and reuse your personal data for your own purposes across different services.  This allows you to move, copy or transfer personal data easily from one IT environment to another in a safe and secure way, without hindrance to usability. The Right to Data Portability only applies:
    • To personal data you have provided to NUCANNA Ltd;
    • Where the processing is based on your consent or for the performance of a contract; and
    • When processing is carried out by automated means.

In these circumstances NUCANNA Ltd will provide a copy of your data free of charge, without undue delay and within one month. If there is a delay to this, you will be informed.

  • Right to Object. You have the right to object to:
    • Processing based on legitimate interests or the performance of a task in the public interest/exercise of official authority (including profiling);
    • Direct marketing (including profiling); and
    • Processing for purposes of scientific/historical research and statistics.
  • Identify Verification.  To protect your personal data, NUCANNA Ltd will seek to verify your identity before releasing any information, which will normally be in electronic format.
  • Fees and Timings.  We will comply with your requests unless we have a lawful reason not to do so. 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 may refuse to comply with your request in these circumstances. We will 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.

Storing your data

When storing and using your information, we need a legal basis for doing it.
NUCANNA Ltd processes personal data for a number of different purposes. NUCANNA Ltd will only process your personal data where there is a legal basis for doing so under data protection laws and the table below identifies these (more than one lawful basis may apply in some situations). In summary, the relevant legal bases are:

  • (a) Consent: you give consent for us to process your data for a specific purpose.
  • (b) Contract: the processing is necessary for a contract or agreement with you.
  • (c) Legal Obligation: the processing is necessary to comply with the law.
  • (d) Legitimate Interests: the processing is necessary for legitimate interests pursued by NuCanna Ltd or another organisation.
  • The purposes for which we process personal data and the legal bases for doing so in each case are:

Legitimate Interest.

NuCanna Ltd’s ‘Legitimate Interest’ is to collect your personal data when you visit this website, for the purposes of:

  • Email addresses for communications and marketing purposes;
  • Financial information for payment and receipt of commissions;
  • Address information for delivery;

Involved 

  • Pre-contract actions, such as adding items to a shopping cart.

Consent.

  • Signing up for a newsletters and other communications.
  • Nominating third parties for us to contact to use our services and site.

How we collect information

When you browse our site or mobile application;

  • When you ‘follow’, ‘like’, post to, or interact with our social media accounts
  • When you contact us via our call centres, press office, social media, website, email or Live Chat;
  • When you apply for a job or offer services with us by email, via the site.
  • When you register an account with us.

Information that we get from third parties, including:

  • A person nominating your business or services on your behalf.
  • Employers and referees. If you are applying to add your business or services to our site we may contact your given referees to provide information about you and your application;
  • Social media plugins. We currently use social media plugins from the following service providers who are based both inside and outside the EU: Facebook, Twitter, LinkedIn Instagram and YouTube. By providing your social media account details you are authorising that third-party provider to share with us certain information about you
  • We might also receive information about you from third parties if you have indicated to such third party that you would like to hear from us.
  • Third parties and marketing. We might rely on third parties under contract to help us manage our marketing communications but we won’t share your information with any third parties for their marketing purposes.
  • Alternatively, we may obtain personal details from third parties. For example, where we acquire third party marketing data or information from, or derived from, public sources such as the electoral roll. This includes your name, address and other contact information, such as your email address and phone numbers.
  • If you work for one of our business customers (or nominated project or initiatives) we will record your business’s name, your position in the business and the business’s address, email address and telephone numbers.


The Information We Collect/or Receive; the Purpose of Collection and Use

In the course of operating the Websites and/or interacting with you, we will collect (and/or receive) the following types of information.

Contact Information.
When you sign up to receive any of our newsletters, respond to a survey, register for a class, purchase any product or service, or sign up to become our affiliate partner, you may be required to provide us with certain information about yourself, such as your name, address, e-mail address, address, social media information, phone number, PayPal address, credit card details and Tax ID# (only if you sign up to become our affiliate partner) (the “Contact Information”). The Contact Information is used to provide the requested product or service or information and to contact you for purposes of direct marketing of our current and future products and services.

If you land on one of our pages through an affiliate partner link and provide us Contact Information (e.g., to request information, purchase a product or service), we may share your name and e-mail address to such affiliate partner to let him/her know that you were referred and in case (s)he has offered you any bonuses or rewards for following their referral link. We have no control over how affiliate partners may use your information after it has been received and we are not responsible for fulfilling any bonuses that such affiliate partners may have offered you; where applicable, please check such affiliate partners’ privacy policies and terms of use for more information on how they may use your personal information.

Order Information.
When you place an Order, you must provide us with certain information about the products and services you are seeking to purchase.  Such information is collectively called the “Order Information.”  The Order Information is used to fulfill your Order.

Billing Information.
When you wish to purchase a product or service, you will be required to provide certain information in addition to the Personal Information and Order Information noted above.  Such information may include a debit card number, credit card number, expiration date, billing address, activation codes, and similar information. Such information is collectively called the “Billing Information.” Billing Information is collected and processed by our third-party payment processor operating as our agent We do not directly obtain or process any Billing Information.
We may also receive information from third parties, such as banks and credit reference agencies when we obtain authorisation for a payment you make or when undertaking an identity check.

Customer records
Records of products and services that you have used. You provide much of this information yourself when you use our services. We will also generate information in the course of providing our services.

Contact History
These are details of any enquiry complaint or claim you have made to NUCANNA Ltd and may include copies of correspondence and call recordings. You will provide us this information when you contact us to make an enquiry or complaint. We will also create records relating to this contact.

Proof of delivery information
Records of delivery including the signature, name and address people who sign for or accept a delivery on your behalf. You provide this information if you accept delivery of a mail item, including when you accept delivery of an item for another person, such as a neighbor.

Other Information.
In addition to the information noted above, we may collect additional information (collectively, the “Other Information”).  Such Other Information may include:

  1. From You.Additional information about yourself that you voluntarily provide to us (e.g., via a survey), such as household income range, gender, product and service preferences, and other information that does not identify you personally.
  2. From Your Activity.Information that we automatically collect when you use the Websites, including, without limitation:
  • IP addresses, which may consist of a static or dynamic IP address and will sometimes point to a specific identifiable computer or device; browser type and language; referring and exit pages and URLs; date and time; amount of time spent on particular pages; what sections of the Websites you visit; and similar data; and
  • Information about your device, including the type of device; universally unique ID (“UUID”); advertising identifier (“IDFA”); MAC address; operating system and version (e.g., iOS, Android or Windows); carrier and country location; hardware and processor information (e.g., storage, chip speed, camera resolution, NFC enabled); network type (WiFi, 3G, 4G, LTE); and similar data.
  1. From Cookies.  Information that we collect using “cookie” technology.  Cookies are small packets of data that a website stores on your computer’s or mobile device’s hard drive so that your computer will “remember” information about your visit.  We may use both session cookies (which expire once you close your web browser) and persistent cookies (which stay on your computer until you delete them) to help us collect Other Information and to enhance your experience using the Websites.  If you do not want us to place a cookie on your hard drive, you may be able to turn that feature off on your computer or mobile device. Please consult your Internet browser’s documentation for information on how to do this and how to delete persistent cookies.  However, if you decide not to accept cookies from us, the Websites may not function properly. For more information visit www.nucanna.org/cookies

What we collect when you interact with our sites and apps

As you may already know, most sites and apps collect certain information automatically in log files about the way in which you interact with them. This includes your IP address, geographical location, device information (such as your hardware model, mobile network information, unique device identifiers), browser type, referral source, length of visit to the site or app, number of page views, the search queries you make, and similar information.

This information will be collected by us or by a third party site analytics service provider and will be collected using cookies.

As we’ve described above, we use this information to help improve our functionality and services, run diagnostics, analyse trends, track visitor movements, gather broad demographic information and personalise our services.

  1. Third-Party Analytics.  We use third-party analytics services (such as Google Analytics) to evaluate your use of the Websites, compile reports on activity, collect demographic data, analyze performance metrics, and collect and evaluate other information relating to the Websites and mobile and Internet usage.  These third parties use cookies and other technologies to help analyze and provide us the data. By accessing and using the Websites, you consent to the processing of data about you by these analytics providers in the manner and for the purposes set out in this Privacy Policy. Please be advised that if you opt out of any service, you may not be able to use the full functionality of the Websites.

Below is a list of analytics providers that we use; however, such list may be subject to change based on how we wish to understand the user experience and we will endeavor to update it diligently. You may use the accompanying links to learn more about such providers and, if available, how to opt-out from their analytics collection.

For Google Analytics, please visit: https://www.google.com/analytics

For zoho Analytics please visit: https://www.zoho.com/analytics

2. From Other Sources.We also may collect or receive information from third parties, such as Facebook and/or other third-party social media sites.

Information Collected by or Through Third-Party Advertisers/Remarketers

We may share Other Information about you with third parties, including, but not limited to, advertising and remarketing providers, or other brand partners, for purposes of personalizing or otherwise understanding how you engage with ads or other content. For example, when a browser visits a site, pixel tags enable us and these third-parties to recognize certain cookies stored within the browser to learn which ads or other content bring a user to a given site. These third parties may use cookies, pixel tags (also called web beacons or clear gifs), or other technologies to collect Other Information in furtherance of such purposes, including to tailor, target (i.e., behavioral, contextual, retargeting, and remarketing), analyze, report on, and/or manage advertising campaigns or other initiatives. In addition, we may receive Other Information from these third parties, including through their service providers, such as advertising identifiers, IP addresses, and post-conversion data.

Below is a list of advertising/remarketing providers that we use; however, such list may be subject to change based on the campaigns that we run and we will endeavor to update it diligently. You may use the accompanying links to learn more about such providers and, if available, how to opt-out from their targeted ads or other personalization features. Please note you will not necessarily be opted-out of advertising or content generally; you may still receive generic ads or content.

For Facebook, please visit: http://www.facebook.com/about/privacy

For Twitter, please visit: https://twitter.com/en/privacy

For Google, please visit: https://support.google.com/ads/answer/2662922?hl=en

In addition, you may opt-out of interest-based advertising by participating providers by visiting http://www.networkadvertising.org and http://www.aboutads.info/choices
for details on how to do so.

Information Collected Through the Websites that is Not Covered by this Privacy Policy

You may post and/or share information, including but not limited to, comments using forums and other similar features available through the Websites. NONE of the information you provide using these features is protected by this Privacy Policy. THIS PRIVACY POLICY DOES NOT APPLY TO ANY INFORMATION (INCLUDING PERSONAL INFORMATION) THAT YOU PROVIDE USING ANY SUCH FEATURES. ALL SUCH INFORMATION IS PUBLIC INFORMATION AND MAY BE SEEN, COLLECTED OR USED BY ANY USER OF THE WEBSITES. Please note that if you post and/or share information on our Websites through your Facebook account, such information will be subject to Facebook’s privacy policy.

Aggregate Data

In an ongoing effort to better understand our visitors, customers, and our products and services, we may analyze the Order Information and Other Information in aggregate form in order to operate, maintain, manage, and improve the Websites and/or our products and services.  This aggregate information does not identify you personally. We may share this aggregate data with our affiliates, agents, and business partners. We may also disclose aggregated user statistics in order to describe our products and services to current and prospective business partners and to other third parties for other lawful purposes.

Additional Uses

We also use information collected pursuant to this Privacy Policy to provide our services; to process Orders; to administer our rewards and promotional programs; to maintain and improve our Websites and services to you; to solicit your feedback; and to inform you about our products and services and those of our third-party marketing partners.

Sharing with Third Parties

Like many businesses, we contract with other companies to perform certain business-related services. We may disclose your information, including personal information in some cases, to certain types of third-party companies, but only to the extent needed to enable them to provide such services, including, without limitation, technical assistance, order fulfillment, customer service, marketing assistance, payment processing, survey collection, promotional and marketing assistance, and business operations. These other companies will have access to your information, including personal information in some cases, only as necessary to perform their functions and to the extent permitted by law. We may also disclose your information, including any personal information, to any of our parent companies, subsidiaries, affiliates, joint ventures, or other companies under common control with us in order to support delivery of our products and services.

Business Transfer

In the event of a merger, dissolution, or similar corporate event or the sale of all or substantially all of our assets, we expect that the Information that we have collected and/or received, including personal information, would be transferred to the surviving entity in a merger or to the acquiring entity.  All such transfers shall be subject to our commitments with respect to the privacy and confidentiality of such personal information as set forth in this Privacy Policy.

Disclosures to Public Authorities

In certain situations, we may be required to disclose personal data in response to lawful requests by public authorities, including to meet national security or law enforcement requirements. We may also disclose personal information to other third parties when compelled to do so by government authorities or required by law or regulation including, but not limited to, in response to court orders and subpoenas.

Opt-Out for Direct Marketing

You may opt out at any time from the use of your personal information for direct marketing purposes by e-mailing the instructions to this email address: info@nucanna.org. Please title Opt out, and allow us a reasonable time to process your request.

Accessing and Modifying Personal Information and Communication Preferences

Upon request to info@nucanna.org we will provide you with confirmation as to whether we are processing your personal information, and have the data communicated to you within a reasonable time. You have the right to correct, amend, or delete your personal information where it is inaccurate or has been processed in violation of this Privacy Policy. We may require payment of a non-excessive fee to defray our expenses in this regard.  Please allow us a reasonable time to respond to your inquiries and requests.

In addition, you may manage your receipt of marketing and non-transactional communications by clicking on the “unsubscribe” link located on the bottom of any NuCanna marketing email.  Customers cannot opt out of receiving transactional e-mails related to their account or their Orders. We will use commercially reasonable efforts to process such requests in a timely manner. You should be aware, however, that it is not always possible to completely remove or modify information in our subscription databases.

Information You Share on Public Forums

We feature or may in the future feature public forums such as message boards or web logs, webinars, classes, telephone conferences, or coaching calls, user comments, chat rooms, and similar activities (collectively, “Public Forums”). You may voluntarily post and share information through such Public Forums. NONE of the information you provide to through the Public Forums or through use of these features are protected by this Privacy Policy including any personal information. THIS PRIVACY POLICY DOES NOT APPLY TO ANY INFORMATION (INCLUDING PERSONAL INFORMATION) THAT YOU PROVIDE USING ANY SUCH FEATURES. ALL SUCH INFORMATION IS PUBLIC INFORMATION AND MAY BE VIEWED, COLLECTED, USED, MODIFIED AND/OR DISCLOSED FOR ANY PURPOSE BY US, ANY USER OF THE PUBLIC FORUM, AND THE PUBLIC.

You should think carefully before disclosing any information in any Public Forum.

How We Protect the Information

We take commercially reasonable steps to protect the Information from loss, misuse, and unauthorized access, disclosure, alteration, or destruction, taking into account the risks involved in processing and the nature of such data, and in compliance with applicable laws and regulations.  Please understand, however, that no security system is impenetrable. We cannot guarantee the security of our databases, nor can we guarantee that the Information that you supply will not be intercepted while being transmitted to and from us over the Internet. In particular, e-mail sent to or from the Websites may not be secure, and you should therefore take special care in deciding what information you send to us via e-mail.

Retention of Personal Information

We will retain your personal information in a form that identifies you only for as long as it serves the purpose(s) for which it was initially collected as stated in this Privacy Policy, subsequently authorized, or as allowed under applicable law.

Children 

We do not knowingly collect personal information from children under the age of 13 through the Websites.  If you are under 13, please do not give us any personal information. We encourage parents and legal guardians to monitor their children’s Internet usage and to help enforce our Privacy Policy by instructing their children to never provide personal information through the Websites without their permission.  If you have reason to believe that a child under the age of 13 has provided personal information to us, please contact us, and we will endeavor to delete that information from our databases.

External Websites

The Websites may contain links to third-party websites, you should always check the applicable third-party privacy policy and terms of use when visiting any other websites.
We have no control over the privacy practices or the content of any of our business partners, advertisers, sponsors, or other websites to which we provide links.  As such, we are not responsible for the content or the privacy policies of those third-party websites.

Changes to This Privacy Policy

This Privacy Policy is effective as of the date stated at the top of this Privacy Policy.  We may change this Privacy Policy from time to time. By accessing the Websites and/or using our services after we make any such changes to this Privacy Policy, you are deemed to have accepted such changes.  Please be aware that, to the extent permitted by applicable law, our use of the Information is governed by the Privacy Policy in effect at the time we collect the Information. Please refer back to this Privacy Policy on a regular basis.

How to Contact Us

If you have questions about this Privacy Policy, please contact us via:

Email: info@nucanna.org
Or write to us at:

NuCanna Ltd.
776-778 Barking Road
London
E13 9PJ