Privacy and Cookie policy
PATHOGENUS CONSULTING LTD. is dedicated to protecting the confidentiality and privacy of information entrusted to it. As part of this fundamental obligation, PATHOGENUS CONSULTING LTD. is committed to the appropriate protection and use of personal information (sometimes referred to as ‘personal data’, ‘personally identifiable information’ or ‘PII’) that has been collected online.
Generally, the intent is to collect only the personal information that is provided voluntarily by online visitors so that PATHOGENUS CONSULTING LTD. can offer appropriate information and/or services to those individuals and/or offer information about employment opportunities. Please review this privacy statement (‘Privacy Statement’) to learn more about how we collect, use, share and protect the personal information that we have obtained.
Index
1. Collection and use of personal information
1.1. What information we collect
1.2. The legal grounds we have to use your personal information
1.3. Automatic collection of personal information
1.3.1. IP addresses;
1.3.2. Cookies;
1.3.3. Google Analytics;
1.3.4. Web beacons;
1.3.5. Location-based tools.
1.4. Social media widgets and applications
1.5. Paediatrics and Adolescents
2. Sharing and transfer of personal information
2.1. Transfer within the network of PATHOGENUS CONSULTING LTD. firms;
2.2.Transfers to third parties.
3. Choices
4. Access
5. Data security and integrity
6. Links to other sites
7. Changes to this statement
8. Policy questions and enforcement
1. Collection and use of personal information
1.1 What information we collect
We obtain personal information about you, only where you choose to provide it — for example, contact mailboxes or as part of a registration for services. We may use your personal information to construct or complete your profile, possibly in combination with information already publicly available, so that we can offer services to you. If you choose to register or log in to a PATHOGENUS CONSULTING LTD. website using a third party single sign-in service that authenticates your identity and connects your social media login information (e.g. LinkedIn, Google, or X) with PATHOGENUS CONSULTING LTD., we will collect any information or content needed for the registration or log in that you have permitted the social media provider to share with us, including your name and email address. Other information collected will depend on the privacy settings you have set with your social media provider. Please review the privacy statement or policy of the applicable service.
When you register or submit personal information to PATHOGENUS CONSULTING LTD. we will store and use this information in the manner outlined in this Privacy Statement. Your personal information is not used for outside purposes, unless we obtain your permission or it is required or prescribed by Law or applicable professional standards. As an example, if you register to a PATHOGENUS CONSULTING LTD. website and provide information about your preferences we will use this information to personalise your user experience. Where you register or login using a third-party, single user sign-in, we may also recognise you as said user across multiple personal devices and, again, personalise your user experience across any and all PATHOGENUS CONSULTING LTD. sites. If you send us a resume or curriculum vitae (CV) to apply online for a position within PATHOGENUS CONSULTING LTD., we will use the information that you provide to match you with available PATHOGENUS CONSULTING LTD. job opportunities. We also use your personal information to optimise your visit to our website as far as possible and to further improve our services.
In the case where you have registered for specific services, we will store your email address temporarily until we receive confirmation of that information via email (i.e. where we send an email to the address provided as part of your registration). Where confirmation of that address is not received that data will be deleted (timelines may vary, average turnaround time will be 3 months or less).
PATHOGENUS CONSULTING LTD. generally collects only the personal information necessary to fulfil your request. Where additional (optional) information is sought, you will be notified of this at the point of collection.
We may process the following (types of) personal information when you visit our website:
· Name
· Email address
· Company name
· Job title
· Telephone number
· IP Address
· Login details
· Your interests and preferences
· Social media name
· Information on your surfing and viewing behaviour and possible your location and other cookie information.
1.2 The legal grounds we have to use your personal information
Privacy legislation, including the General Data Protection Regulation (GDPR), allows us to process personal information, so long as we have grounds under the law to do so. It also requires us to tell you what those grounds are. As a result, when we process your personal information, we will rely on one of the following processing conditions:
· Performance of a contract: this is when the processing of your personal information is necessary in order to perform our obligations under a contractual agreement;
· Legal obligation: this is when we are required to process your personal information in order to comply with a legal obligation, such as keeping records for tax purposes or providing information to a public body or law enforcement agency;
· Legitimate interests: we will process information about you where it is in our legitimate interest in running a lawful business to do so in order to further that business, so long as it doesn’t outweigh your interests; or
· Your consent: in some cases, we will ask you for specific permission to process some of your personal information, and we will only process your personal information in this way if you agree to us doing so. You may withdraw your consent at any time by contacting PATHOGENUS CONSULTING LTD. at: contact@pathogenus.com
Examples of the ‘legitimate interests’ referred to above are:
· To offer information and/or services to individuals who visit our website or offer information about employment opportunities;
· To prevent fraud or criminal activity and to safeguard our IT systems;
· To customise individual’s online experience and improve the performance usability and effectiveness of PATHOGENUS CONSULTING LTD.'s online presence;
· To conduct and to analyse our marketing activities;
· To meet our corporate and social responsibility obligations;
· To exercise our fundamental rights in the EU under Articles 16 and 17 of the Charter of Fundamental Rights, including our freedom to conduct a business and right to property.
In some cases, the personal data that we collect will also include special categories of data, such as diversity related information (including data about racial and ethnic origin, political opinions, religious beliefs and other beliefs of a similar nature, trade union membership and data about sexual life and sexual orientation), or health data and data about alleged or proven criminal offences in each case where permitted by law.
1.3 Automatic collection of personal information
In some instances, PATHOGENUS CONSULTING LTD. and its service providers uses cookies, web beacons and other technologies to automatically collect certain types of information when you visit us online, as well as through emails that we may exchange. The collection of this information allows us to customize your online experience, improve the performance, usability and effectiveness of PATHOGENUS CONSULTING LTD.'s online presence, and to measure the effectiveness of our marketing activities.
1.3.1 IP addresses
An IP address is a number assigned to your computer whenever you access the internet. It allows computers and servers to recognize and communicate with one another. IP addresses from which visitors appear to originate will be recorded for IT security and system diagnostic purposes. This information will also typically be used in aggregate form to conduct website trend and performance analysis.
1.3.2 Cookies
Cookies will typically be placed on your computer or internet-enabled device whenever you visit us online. This allows the site to remember your computer or device and serves a number of purposes.
On some of our websites, a notification banner will appear allowing you to provide and manage your consent to use cookies (cookie banner). Below is a summary of the categories of cookies that may be used on our websites, and how your consent may impact your experience of certain features as you navigate those websites:
· Strictly necessary cookies: Strictly necessary cookies are essential in order to enable users to move around the website and use its features, such as accessing secure areas of the website. These cookies must be enabled or the site will not function. Use of these cookies does not require your prior consent and cannot be blocked either.
· Performance cookies (sometimes also referred to as analytical cookies): Performance cookies are cookies used to gather data to enhance the performance of a website.
· Functionality cookies: Functionality cookies are used to remember customer selections that change the way the site behaves or looks. If you do not consent to use these cookies that will impact your experience on the website, and you may need to repeat certain selections each time you visit.
· Targeting cookies or advertising cookies: Targeting cookies are used to deliver content relevant to your interests. They are also used to limit the number of times you see certain marketing materials, as well as help measure the effectiveness of those marketing materials. If you do not provide consent for targeting cookies, your computer or other internet-enabled device will not be tracked for marketing-related activities.
In principle we will only use performance, functionality and targeting cookies based on your consent which you can provide and manage via the cookie banner (if applicable), or by updating your browser’s settings (often found in your browser’s Tools or Preferences menu) to not accept cookies. Note however that performance cookies that are configured in a privacy friendly manner do not require your prior consent and may be placed on some of our websites without your consent. If you wish to revoke your selection, you may do so by clearing your browser’s cookies, or by updating your preferences in the cookie banner (if applicable).
Further information about managing cookies can be found in your browser's help file or through sites such as www.allaboutcookies.org.
Cookies by themselves do not tell us your email address or otherwise identify you personally. In our analytical reports, we will obtain other identifiers including IP addresses, but this is for the purpose of identifying the number of unique visitors to our websites and geographic origin of visitor trends, and not to identify individual visitors.
1.3.3 Google Analytics
PATHOGENUS CONSULTING LTD. uses Google Analytics. More information about how Google Analytics is used by PATHOGENUS CONSULTING LTD. can be found here: http://www.google.com/analytics/learn/privacy.html To provide website visitors with more choice on how their data is collected by Google Analytics, Google have developed the Google Analytics Opt-out Browser Add-on. The add-on communicates with the Google Analytics JavaScript (ga.js) to indicate that information about the website visit should not be sent to Google Analytics. The Google Analytics Opt-out Browser Add-on does not prevent information from being sent to the website itself or to other web analytics services.
1.3.4 Web beacons
A ‘web beacon’ is a small image file on a webpage that can be used to collect certain information from your computer, such as an IP address, the time the content was viewed, a browser type, and the existence of cookies previously set by the same server. Where applicable PATHOGENUS CONSULTING LTD. only uses web beacons in accordance with applicable laws. PATHOGENUS CONSULTING LTD. or its service providers may use web beacons to track the effectiveness of third-party websites that provide us with recruiting or marketing services or to gather aggregate visitor statistics and manage cookies. You have the option to render some web beacons unusable by rejecting their associated cookies. The web beacon may still record an anonymous visit from your IP address but cookie information will not be recorded. In some of our newsletters and other communications, we will monitor recipient actions such as email open rates through embedded links within the messages. We collect this information to gauge user interest and to enhance future user experiences.
1.3.5 Location-based tools
PATHOGENUS CONSULTING LTD. may collect and use the geographical location of your computer or mobile device. This location data is collected for the purpose of providing you with information regarding services which we believe may be of interest to you based on your geographic location, and to improve our location-based products and services.
1.4 Social media widgets and applications
PATHOGENUS CONSULTING LTD. websites will typically include functionality to enable sharing via third party social media applications, such as the Facebook ‘Like’ button and Twitter widget. These social media applications will collect and use information regarding your use of PATHOGENUS CONSULTING LTD. websites (see details on 'Social Sharing' cookies above). Any personal information that you provide via such social media applications will often be collected and used by other members of that social media application and such interactions are governed by the privacy policies of the companies that provide the application. We do not have control over, nor responsibility for, those companies or their use of your information. For more guidance please refer to the third party's privacy statement.
In addition, PATHOGENUS CONSULTING LTD. websites may host blogs, forums, crowd-sourcing and other applications or services (collectively referred to as ‘social media features’). The purpose of social media features is to facilitate the sharing of knowledge and content. Any personal information that you provide on any PATHOGENUS CONSULTING LTD. social media feature will typically be shared with other users of that social media feature (unless otherwise stated at the point of collection), over whom we have limited or no control.
1.5 Paediatrics and adolescents
PATHOGENUS CONSULTING LTD. understands the importance of protecting children's privacy, especially in an online environment. In particular, our sites are not intentionally designed for or directed at children under the age of 16. It is our policy never to knowingly collect or maintain information about anyone under the age of 16, except as part of an engagement to provide professional services.
2. Sharing and transfer of personal information
2.1 Transfer within the network of PATHOGENUS CONSULTING LTD. firms
We may share information with other member firms of the PATHOGENUS CONSULTING LTD. network, its related entities and other member firms, where required or desirable to meet global legal and regulatory obligations. Other parts of the PATHOGENUS CONSULTING LTD. network may be used to provide services to us and you, for example hosting and supporting IT applications, provision of insurance for member firms and its clients, performing client conflicts and Anti-Money Laundering checks and balances, assisting with client engagement services and otherwise as required in order to perform PATHOGENUS CONSULTING LTD. business.
2.2 Transfers to third parties
We do not share personal information with third parties, except as necessary for our legitimate professional and business needs, in order to carry out your requests, and/or as required or permitted by law or professional standards. In addition, PATHOGENUS CONSULTING LTD. may transfer certain personal information outside of the EEA to outside companies working with us or on our behalf for the purposes described in this Privacy Statement. PATHOGENUS CONSULTING LTD. may also store personal information outside of the EEA. If we do this your personal information will continue to be protected by means of contracts we have in place with those organisations outside the EEA, for example containing standard data protection clauses which are in a form as approved by the European Commission.
PATHOGENUS CONSULTING LTD. will not transfer such personal information as you may provide to any third parties for said parties own direct marketing use.
3. Choices
In general, you are not required to submit any personal information to PATHOGENUS CONSULTING LTD. However, we may require you to provide an email address and other, similar data in order for you to receive additional information concerning our services and pricing. PATHOGENUS CONSULTING LTD. will request your consent prior to use of your personal information for purposes other than direct communication or business processes; you retain the right to agree to or decline those uses. If you opt-in for particular services or communications, such as an e-newsletter, you will be able to unsubscribe at any time by following the instructions included in each communication. If you decide to unsubscribe from a service or communication, we will try to remove your information promptly, although we may require additional information before we can process your request.
As described in ‘Cookies’ above, if you wish to prevent cookies from tracking you as you navigate our sites, you can reset your browser to refuse all cookies or to indicate when a cookie is being sent. Note, however, that some portions of our sites may not work properly if you elect to refuse cookies.
4. Access
If PATHOGENUS CONSULTING LTD. processes personal information about you, you have the following rights:
· Access and correction: you have the right to access to that data. This is sometimes called a ‘Subject Access Request’. If we agree that we are obliged to provide personal information to you, we will provide it to you free of charge. Before providing personal information to you, we may ask for proof of identity and sufficient information about your interactions with us that we can locate your personal information. If the information we hold about you is incorrect, you are entitled to ask us to correct any inaccuracies in the personal information.
· Object to processing: you have the right to object to us processing your personal information if entitlement to use is removed;
· Other Rights: in addition, you retain the right to have your information deleted if it is considered to have been held for an unreasonable length of time and/or have its processing restricted in certain circumstances and/or to obtain copies of information we hold about you in electronic form.
You can make a request or exercise these rights by contacting PATHOGENUS CONSULTING LTD. at contact@pathogenus.com and we will make all reasonable and practical efforts to comply with your request, so long as it is consistent with applicable law and professional standards.
5. Data security and integrity
PATHOGENUS CONSULTING LTD. has reasonable security policies and procedures in place to protect personal information from unauthorised loss, misuse, alteration, or destruction. Despite PATHOGENUS CONSULTING LTD.’s best efforts, security cannot be absolutely guaranteed against all threats. To the best of our knowledge and ability, access to personal information is limited to those who are identified and authorised as having a need to know, for business reasons only. Those individuals who have access to the data are required to maintain the confidentiality of such information.
PATHOGENUS CONSULTING LTD. makes all reasonable efforts to retain personal information only for so long: i) as the information is necessary to comply with an individual's request; ii) as necessary to comply with legal, regulatory, internal business or policy requirements; or iii) until that person asks that the information be deleted. The period for which data is retained will depend on the specific nature and circumstances under which the information was collected.
6. Links to other sites
Please be aware that PATHOGENUS CONSULTING LTD. websites may contain links to other sites, including sites maintained by other PATHOGENUS CONSULTING LTD. member firms that are not governed by this Privacy Statement but by other privacy statements that may differ. We encourage users to review the privacy policy of each website before disclosing any personal information.
7. Changes to this statement
PATHOGENUS CONSULTING LTD. may modify this Privacy Statement from time to time to reflect our current privacy practices. When we make changes to this statement, we will advise the ‘updated’ date at the top of this page. Any changes to the processing of personal data as described in this Privacy Statement affecting you will be communicated to you through an appropriate channel, depending on how we normally communicate with you.
8. Policy questions and enforcement
PATHOGENUS CONSULTING LTD. is committed to protecting the online privacy of your personal information. If you have questions or comments about our administration of your personal information, please contact us at contact@pathogenus.com . You may also use this address to communicate any concerns you may have regarding compliance with our Privacy Statement.
In any event, visitors retain the right to lodge a complaint with The Information Commissioner's Office (ICO)); the official office in charge of protecting personal information.
References in this Online Privacy Statement to ‘PATHOGENUS CONSULTING LTD.’, ‘we’, ‘our’ and ‘us’ are to PATHOGENUS CONSULTING LTD. and its subsidiaries, where applicable.
PATHOGENUS CONSULTING LTD. is registered in United Kingdom under number Company number 16206861