Privacy policy

NABLA PLATFORM PRIVACY AND COOKIES POLICY

Date of policy: October 7th 2021

PART A NABLA PLATFORM PRIVACY POLICY

Purpose of this privacy policy.

Nabla respects your privacy and is committed to protecting your personal data. This privacy policy will inform you as to how we look after your personal data when you visit our Platform and tell you about your privacy rights and how the law protects you.

This privacy policy is provided in a layered format so you can click through to the specific areas set out below. This policy (together with our terms and conditions) applies to your visits to the platform located at pro.nabla.com (the Platform)

This policy sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us.

Please read the following carefully to understand our practices regarding your personal data and how we will treat it.

Data controller

Nabla Services Ltd is a company registered in England and Wales. Our company registration number is 13441595 and our registered office is at 8th Floor South, 11 Old Jewry, London, EC2R 8DU. We are a subsidiary company of Nabla Technologies SAS, a company established and operating in France.

Nabla Services Ltd is the data controller and is referred to in this privacy policy as “Nabla”, “we”, “us” or “ours”.

We are committed to protecting your personal data and respecting your privacy.

If you have any questions about this privacy policy, please contact us using the details set out below.

Contact details

Our contact details are:

Email address: dpo@nabla.com
Postal address: Nabla Services Ltd, 8th Floor South, 11 Old Jewry, London, EC2R 8DU

Changes to the privacy policy and your duty to inform us of changes

We keep our privacy policy under regular review. It may change and if it does, these changes will be posted on this page and, where appropriate, notified to you by email and/or when you next log into the Platform. The new policy may be displayed on-screen and you may be required to read and accept the changes to continue your use the Platform.

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 our relationship with you.

Third party links

Our Platform may, from time to time, contain links to and from the websites or applications of our partner networks, and affiliates. Please note that these websites or applications and any services that may be accessible through them have their own privacy policies and that we do not accept any responsibility or liability for these policies or for any personal data that may be collected through these websites or services. Please check these policies before you submit any personal data to these websites or use these services.

The data we collect about you

Depending on the level of your engagement with the Platform, we may collect, use, store and transfer different kinds of personal data about you as follows:

Identity Data:	Includes first name, last name, username or similar identifier, title, and date of birth. This is information you provide to us when you create an account on the Platform. Creating and maintaining an account is necessary to enable you to work with Nabla.
Contact Data:	Includes email address and telephone numbers. It also includes the content of your communications when using the Platform. We require this information to enable you to communicate with us and for our regulatory and legal compliance obligations.
Technical Data:	In relation to the use of the the Platform, this includes: the type of mobile device you use, a unique device identifier (for example, your device’s IMEI number, the MAC address of the device’s wireless network interface, or the mobile phone number used by the device), mobile network information, your mobile operating system, the type of mobile browser you use, time zone setting. In relation to the use of the Platform, this includes: internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access the Website and/or the Platform
Profile Data:	Includes your username and password. This is all data that relates to your interactions with us. It is necessary to provide you with your registered account service.
Usage Data:	Includes details of your use of the Platform, including but not limited to, traffic data and other communication data, and the resources that you access. We collect this data to monitor and measure the performance of the Platform.
Financial Data	Includes your bank account details. We collect this data to pay you when you provide services to Nabla.
Qualifications and Professional Data	Includes: (a) the qualifications you have been awarded, including the relevant institution(s), subject(s) and grade(s); (b) your registration with any professional body or register and any relevant renewal information; (c) your employment history and any cover or personal statement you provide to us; (d) details of relevant insurance policies you hold (e.g. general liability insurance, professional indemnity insurance and public liability insurance); and (e) details of any claims or complaints made against you in relation to your clinical practice. We collect this data to assess your application to work at Nabla and for our legal and regulatory compliance obligations.
Criminal Offence Data	We will require a Disclosure and Barring Service check (DBS Check) from you before you can work at Nabla.

We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific Platform feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy policy.

How is your personal data collected?

Most of the personal data that we process about you will be provided by you, for example during registration on the Platform or applying for a job or consulting contract with us. The provision of such information is voluntary, but if you cannot provide it to us, you may not be able to work with Nabla. Each time you visit the Platform we will automatically collect personal data including Technical Data and Usage Data. We collect this data using cookies and other similar technologies. Please see our cookie policy at Part B below for further details.

How we use your personal data

We will only use your personal data when the law allows us to do so. Most commonly we will use your personal data in the following circumstances:

Where you have consented before the processing. Consent means processing your personal data where you have signified your agreement by a statement or clear opt-in to processing for a specific purpose. Consent will only be valid if it is a freely given, specific, informed and unambiguous indication of what you want. You can withdraw your consent at any time by contacting us.
Where we need to perform a contract we are about to enter or have entered with you. Performance of contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.
Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests. Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.
Where we need to comply with a legal or regulatory obligation. Comply with a legal obligation means processing your personal data where it is necessary for compliance with a legal obligation that we are subject to.

The table below explains what we use (process) your personal information for (other than the special category of data) and our reasons for doing so.

Purpose/activity	Type of data	Lawful basis for processing
To register you as a new user	Identity Contact Qualifications and Professional Technical	Performance of a contract with you
To apply for a job or consulting contract with us	Identity Contact Qualifications and Professional Criminal Offence Data	Consent Necessary for our legitimate interests (for running our business and assessing new job applications in connection with the provision of healthcare services and the management of healthcare systems and services)
To manage our relationship with you including responding to your queries and requests, notifying you of changes to the Platform and/or our Terms of Service or this privacy policy	Identity Contact Profile Qualifications and Professional Financial	Performance of a contract with you Necessary to comply with legal obligations (to inform you of any changes to our terms and conditions)
To administer and protect our business and the Platform, including troubleshooting, data analysis and system testing	Identity Contact Technical	Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security)
To ensure that you are able to meet your regulatory obligations	Identity Contact Qualifications and Professional	Performance of a contract with you To comply with a legal or regulatory obligation or expectations
To enable public health authorities to carry out their functions	Identity Contact Qualifications and Professional	To comply with a legal or regulatory obligation or expectations

Disclosures of your personal data

The above purposes and activities may require us to pass on some of our personal data to the following third parties:

Our service providers acting as our processors, including:

Nabla Technologies SAS based in France – this is our holding company, which provides us with all back-office support and infrastructure, including data hosting services, IT services and technical support;
Google Ireland Limited, sub-processor providing of data hosting services in connection to the Website and/or the Platform to Nabla Technologies SAS;
Other suppliers, which we may appoint from time to time to provide various services to us, such as IT and system administration services.

Professional advisers acting as processors or joint controllers including lawyers, bankers, auditors and insurers who provide consultancy, banking, legal, insurance and accounting services; and
HM Revenue and Customs, regulators, local authorities and other public or regulatory authorities acting as processors or joint controllers who require reporting of processing activities in certain circumstances.

We only allow our service providers to handle your personal information if we are satisfied they take appropriate measures to protect your personal information. We also impose contractual obligations on service providers to ensure they can only use your personal information to provide services to us and to you and for no other reasons.

We may disclose and exchange information with law enforcement agencies and regulatory bodies to comply with our legal and regulatory obligations.

Data security

All information you provide to us is stored on our secure servers. Where we have given you (or where you have chosen) a password that enables you to access certain parts of our Platform, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.

Once we have received your information, we will use strict procedures and security features to try to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator when we are legally required to do so.

We do not transfer or process your personal data outside of the UK and/or the EEA.

We do transfer certain Aggregated Data to the USA (however for the avoidance of doubt, such does not contain any personal data) to help us improve our services to you and other users of the Website and the Platform.

Data retention

We retain your personal data for as long as we need it for the purposes we have collected it for, such as providing the Website and the Platform to you. We may retain your personal data for a longer period if you make a complaint under this privacy policy or our terms and conditions, or if we have a reasonable belief that litigation may arise in relation to our relationship with you. We may also be required to retain certain personal data from you to comply with our legal and regulatory requirements.

In some circumstances you can ask us to delete your data: see your legal rights section below for further information.

In some circumstances, we will anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.

Your legal rights

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

Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
Right to be informed. You have the right to be informed how your personal data will be used. This privacy policy as well as any additional information or notice that is provided to you either at the time you provided your details, or otherwise, is intended to provide you with this information.
Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios:

if you want us to establish the data’s accuracy;
where our use of the data is unlawful but you do not want us to erase it;
where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or
you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.

Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.

If you would like to exercise any of those rights, please contact us (see contact details in paragraph 3 above) and:

let us have enough information to identify you;
let us have proof of your identity and address (a copy of your driving licence or passport and a recent utility or credit card bill); and
let us know what right you want to exercise and the information to which your request relates.

We try to respond to all legitimate requests within one month. 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.

How to complain

If you are unhappy with the way in which we have handled your personal please get in touch with us by sending an email to dpo@nabla.com.

You are also entitled to make a complaint to the Information Commissioner’s Office (“ICO”) (https://ico.org.uk) – however we would appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.

Changes to this privacy policy

We keep this privacy policy under regular review and may update it from time to time without notice to you, so please check it regularly. We will however aim to bring any significant changes to your attention.