In situations where Proximie acts as the Controller the Controller is:
Proximie Limited, (company number: 10509541) with a registered office address at: 3rd Floor 1 Ashley Road, Altrincham, Cheshire, United Kingdom, WA14 2DT.
Proximie is registered with the Information Commissioner’s Office (registration number ZA508920).
What Personal Information Does Proximie Collect, For What Purpose and What is the Legal Basis or Bases Relied Upon?
We collect information in a variety of ways including information that you provide to us or that is automatically collected during your interaction with the Services. When we collect your personal information for this, we must tell you the types of personal information that are collected, our reason (purpose) for our collection and processing of that information, and the legal basis/ bases that we rely on for such collection and processing to occur. The below table sets this out and describes the five types of personal information we process, the associated purpose and the corresponding legal bases.
We may also use your personal information that we process to protect against and prevent fraud, claims, and other liabilities and to comply with or enforce applicable legal requirements, industry standards, and our policies and terms with you or our customers. We use personal information for these purposes when it is necessary to protect, exercise or defend our legal rights, or when we are required to do so by applicable law.
How Does Proximie Protect Personal Information?
Proximie takes security of personal information seriously and Proximie maintains appropriate policies, practices, technical controls, and security measures to safeguard personal information. These controls and measures are in place to protect personal information from being accidentally destroyed, misused, or disclosed and to ensure that such personal information is processed in accordance with applicable data protection laws, rules, and regulations. These measures include appropriate IT and software security and physical controls. Additionally, Proximie holds data only for as long as is necessary to accomplish the purpose, in line with Proximie’s data retention and disposal policy. Proximie also retains personal information when we have a legitimate interest to do so (such as improving and developing Services) and for regulatory and legal compliance, and legal claims. Personal information will only be processed by those that need to know such information and only to the extent required to accomplish the purpose. When we share your personal information with the organisations listed below and where required to do so, we enter contracts with them to safeguard your personal information, such as data protection agreements. Further details of Proximie’s personal information security measures are available in our Security Addendum, which is available on request and subject to entry into a Non-Disclosure Agreement.
Who Does Proximie Share My Personal Information With?
Subject to applicable law, Proximie may share your personal information with the following and for the following reasons:
- Affiliates. We may share your information with members of our corporate group including Proximie SAL in Lebanon and Proximie Inc in the United States as described in this Privacy Notice. Further details of the Proximie organisations can be found at: https://www.proximie.health/contact/ .
- Authorities. Your personal information may be disclosed or transferred to governing or public bodies to comply with: (i) our legal obligations; (ii) regulators; (iii) contracts; (iv) in response to a court order, administrative or judicial process; (v) or where legally compelled to do so.
- Corporate transactions. We may disclose your information to third parties in connection with a corporate transaction, such as a merger, sale of assets or shares, reorganisation, financing, change of control, or acquisition of all or a portion of our business.
- Service Providers. Proximie shares your personal information with companies and organisations we use to support us in providing and managing the Services. These Service Providers provide or support Proximie with analytics, advertising, authentication and verification, cloud hosting, content delivery, payment, marketing, promotion, events, monitoring, user experience, and customer/ technical support services.
Global Operations & Worldwide Transfers.
Subject to compliance with applicable law, Proximie may transfer your personal information outside of your home country, including for further processing to our Affiliates and our Processors, including out Service Providers. Such transfers may be to countries where data protection laws are not equivalent to those in your home country, including to the United States and Lebanon. Proximie will ensure adequate safeguards are put in place where your personal information is transferred between countries. This includes, but is not limited to, the use of and reliance upon UK/EU Standard Contractual Clauses, adequacy decisions, or your explicit consent. If you are located in Australia or New Zealand, you should refer to the Country Specific Addendum below for further information.
Your Data Protection Rights.
If your personal information was provided to Proximie by or on behalf of one of our customers and you wish to exercise any rights you may have under the applicable data protection laws, you should raise such questions with the customer in the first instance as they are the ones responsible for your personal information.
In relation to personal information Proximie collects as Controller, the following is a summary of your data protection rights. To exercise these rights please contact Proximie via the details provided below in “Contact Proximie”. You may have the right to:
- Access and obtain a copy of your personal information;
- Require Proximie to change and/or correct incorrect or incomplete personal information;
- Request Proximie provide or transfer your personal information in a structured, commonly used and machine-readable format;
- Request that we stop contacting you for marketing purposes or follow-up on any recruitment or engagement process.
- In certain situations, ask that we erase or stop using your personal information or restrict further processing of your personal information, where applicable, or object to the processing of your personal information where there are no longer sufficient or legitimate grounds for Proximie to continue processing the information; and
- Where we rely on consent to process your personal information, decline consent and/or withdraw consent at any time. This will not affect the lawfulness of processing prior to such a withdrawal of consent.
Proximie will provide this information to you free of charge unless the request is ‘manifestly unfounded or excessive’, when we may choose to charge a reasonable administration fee or refuse to respond. We will endeavour to respond to your request, or provide the information requested as soon as possible. To ensure data security we may request evidence of identification in regard to the above rights.
We need certain types of information to provide the Services to you. As such, if you ask Proximie to delete this information you may no longer be able to access or use the Services.
Marketing Material
Where you have consented to us providing you with marketing material, you are free to withdraw this consent at any time. If you wish to stop receiving the information, you can unsubscribe at any time by:
- using the ‘unsubscribe’ link in emails that you receive from us;
- sending an email or letter using the details in the Contact Proximie section below.
Contact Proximie
If you have any questions or comments about this Privacy Notice or wish to exercise any of the rights above please email : dpo@proximie.health or write to us at:
ATTN: Proximie’s Data Protection Officer
3rd Floor 1 Ashley Road,
Altrincham, Cheshire,
United Kingdom, WA14 2DT
Additionally, those in the European Economic Area (“EEA”) may also contact our representative in the Union, Kaleidoscope Data Privacy Consultants Limited (KDPC IE), by sending an email to: EEA.proximie@kdpc.ie with dpo@proximie.health in cc.
Complaints
If you believe that Proximie has not complied with its data protection obligations, you should raise this in the first instance with Proximie. If the matter is not resolved to your satisfaction, you may complain to the relevant data protection supervisory authority in your country, such as the Information Commissioner’s Office in the United Kingdom. For further information please visit the ICO website, https://ico.org.uk/your-data-matters/raising-concerns or telephone: 0303 123 1113.
Country Specific Sections:
Australia:
Transfers and Disclosures to Third Countries:
Your personal information may be transferred to or otherwise disclose to recipients in countries outside Australia, including but not limited to the following countries: Lebanon, United Kingdom and the United States.
Storage:
Your information will likely be stored on infrastructure located within the United States, United Kingdom, Australia, Singapore, Lebanon, Japan, Germany, France.
Our obligations to you:
For Australian data subjects, our obligations under the Privacy Act 1988 (Cth) apply regardless of whether we process your data on our own or our customers’ behalf.
Complaints:
To contact us or submit a complaint regarding compliance with applicable Australian law, please contact us using the information above. We will work to respond as quickly as we can and within 30 days. If we cannot resolve the matter for you, you may make a complaint to the Office of the Australian Information Commissioner (OAIC). For further information, please visit the OAIC website at www.oaic.gov.au.
New Zealand:
Transfers and Disclosures to the Third Countries:
Your personal information may be transferred to or otherwise disclose to recipients in countries outside New Zealand, including but not limited to: Lebanon, United Kingdom and the United States.
Storage:
Your information will likely be stored on infrastructure located within the United States, United Kingdom, Australia, Singapore, Lebanon, Japan, Germany, France.
Complaints:
To contact us or submit a complaint regarding compliance with applicable New Zealand laws, please contact us using the information above. We will work to respond as quickly as we can. If we cannot resolve the matter for you, you may complain to the Office of the Privacy Commissioner. For more information, please visit the OPC website, https://privacy.org.nz.
