NABLA WEBSITE PRIVACY AND COOKIES POLICY

Date of policy: November 20th 2021

PART A NABLA WEBSITE AND PLATFORM PRIVACY POLICY

  1. 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 Website and/or 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 website located at https://www.nabla.com/en/ (the Website)

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.

  1. 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.

  1. Contact details

Our contact details are:

  1. 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 Website. The new policy may be displayed on-screen and you may be required to read and accept the changes to continue your use of the Website.

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.

  1. Third party links

Our Website may, from time to time, contain links to and from the websites of our partner networks, and affiliates. Please note that these websites 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.

  1. The data we collect about you

Depending on the level of your engagement with the Website, 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, position.

This is information you provide to us when you apply for a job with us on the Website.

Contact Data:

Includes email address and telephone numbers. It also includes the content of your resume when applying for a job on the Website.

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 Website, 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.

Please see our cookies policy at Part B below for more details about why and how we use cookies and other tracking technologies.

Usage Data:

Includes details of your use of the Website 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 Website.

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 only 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 Website 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.

  1. How is your personal data collected?

Most of the personal data that we process about you will be provided by you, for example when applying for a job with us on the Website. 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 Website 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.

  1. Cookies

We use cookies and/or other tracking technologies to distinguish you from other users of the Website and to remember your preferences. This helps us to provide you with a good experience when you use the Website and also allows us to improve the Website. For detailed information on the cookies we use, the purposes for which we use them and how you can exercise your choices regarding our use of your cookies, see our cookie policy at Part B below.

  1. 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:

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 apply for a job 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 Website and/or our Terms of Service or this privacy policy

Identity

Contact

Profile

Qualifications and Professional

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 Website, 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

  1. 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:

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.

  1. 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.

  1. 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 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.

  1. Your legal rights

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

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

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.

  1. 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.

  1. 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.


PART B - NABLA COOKIES POLICY

Date of policy: 1 October 2021

This cookies policy explains how Nabla uses cookies and other tracking technologies on the Website. This cookies policy is to be read alongside our privacy policy above which explains how we use personal information.

  1. What are web cookies?

Web cookies are small files that are placed on your computer or mobile device by a website when you visit it. They contain details of your browsing history on that website and distinguish you from other users. Cookies send data back to the originating website on each subsequent visit or allow another website or app to recognise the cookie. Cookies are useful because they allow a website or app to recognise a user’s device and, for instance, remember your preferences and generally improve your online user experience. Like most websites and apps, we use cookies.

Although this cookies policy refers to the general term “cookie”, which is the main method used by the Website and the Platform to store information, the browser’s local storage space is also used for the same purpose and we may use other tracking technologies through the Website and the Platform. As a result, the information included in this cookie policy is likewise applicable to all such tracking technologies that we use.

  1. Why do we use cookies?
  1. What cookies do we use?

The table below provides more information about the cookies and other tracking technologies we use and why.

Name of cookie

Owner

Purpose of the cookie

Duration

Netlify Analytics

Netlify

  • Measure performance of the Website (number of single users, number of pages seen…)

Session

  1. Cookie acceptance

By using the Website you have consented to our use of cookies as updated from time to time. In particular, you consent to cookies being stored on your computer and/or mobile device (unless rejected or disabled by your browser).

You can accept or refuse cookies through your internet browser or through the Website. The option to do this is usually found in the options, settings or preferences menu of your browser or mobile device. If you access the Website through different devices, computer profile or browser you will have to tell us your cookies preferences again.

  1. Updating our cookies policy

We may update our use of cookies from time to time and consequently, we may update this policy. We, therefore, recommend that you check this cookies policy regularly.