PRIVACY POLICY & COOKIE POLICY 

INTRODUCTION Important information and who we are Welcome to Card Medic Limited’s Privacy and Data Protection Policy (“Privacy Policy”). At Card Medic Limited (“we”, “us”, or “our”) we are committed to protecting and respecting your privacy and Personal Data in compliance with the United Kingdom General Data Protection Regulation (“GDPR”), the DPA 2018 and all other mandatory laws and regulations of the United Kingdom. This Privacy Policy explains how we collect, process and keep your data safe. The Privacy Policy will tell you about your privacy rights, how the law protects you, and inform our employees and staff members of all their obligations and protocols when processing data. The individuals from which we may gather and use data can include: Customers Suppliers Business contacts Employees/Staff Members Third parties connected to your customers and any other people that the organisation has a relationship with or may need to contact. This Privacy Policy applies to all our employees and staff members and all Personal Data processed at any time by us. Who is Your Data Controller Card Medic Limited is your Data Controller and responsible for your Personal Data. We are not obliged by the GDPR to appoint a data protection officer and have not voluntarily appointed one at this time. Therefore, any inquiries about your data should either be sent to us on email at info@cardmedic.com or sent in a letter to Card Medic Limited, Oxford Centre for Innovation, New Road, Oxford, OX1 1BY. You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance. Processing Data on Behalf of a Controller and Processors’ responsibility to you In discharging our responsibilities as a Data Controller we have employees who will deal with your data on our behalf (known as “Processors”). Therefore, the responsibilities described below may be assigned to an individual, or may be taken to apply to the organisation as a whole. The Data Controller and our Processors have the following responsibilities: Ensure that all processing of Personal Data is governed by one of the legal bases laid out in the GDPR (see 2.2 below for more information on those bases); Ensure that Processors authorised to process Personal Data have committed themselves to confidentiality or are under an appropriate statutory obligation of confidentiality; Implement appropriate technical and organisational measures to ensure a level of security appropriate to the risk associated with the processing of Personal Data; Obtain the prior specific or general authorisation of the Controller before engaging another Processor; Assist the Controller in the fulfilment of the Controller's obligation to respond to requests for exercising the data subject's rights; Make available to the Controller all information necessary to demonstrate compliance with the obligations laid down in the GDPR and allow for and contribute to audits, including inspections, conducted by the Controller or another auditor mandated by the Controller; Maintain a record of all categories of processing activities carried out on behalf of a Controller; Cooperate, on request, with the supervisory authority in the performance of its tasks; Ensure that any person acting under the authority of the Processor who has access to Personal Data does not process Personal Data except on instructions from the Controller; and Notify the Controller without undue delay after becoming aware of a Personal Data Breach; LEGAL BASIS FOR DATA COLLECTION Types of Data / Privacy Policy Scope “Personal Data” means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data). We may collect, use, store and transfer different kinds of Personal Data about you which we have grouped together below. Not all of the following types of data will necessarily be collected from you but this is the full scope of data that we collect and when we collect it from you: Profile/Identity Data: This is data relating to your first name, last name, occupation and your image/photograph. Contact Data: This is data relating to your place of work addresses, email addresses. Marketing and Communications Data: This is your preferences in receiving marketing information and other information from us. Billing Data: This is information relating to your place of work payment details and your billing addresses. Financial Data: These are your place of work banking details e.g. account number and sort code. Transactional Data: This is information of details and records of all payments you have made for our services or products. Technical Data: This is your IP address, browser type and version, time zone setting and location, operating system and platform, and other technology on the devices you use to engage with us. Customer Support Data: This includes feedback and survey responses. Usage Data: information about how you use our website, products and services. We also collect, use and share Aggregated Data such as flashcard usage, content preferences and user types. 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. 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. We may also aggregate data to enable research or analysis so that we can better understand and serve you and others. For example, we may conduct research on your demographics and usage. Although this aggregated data may be based in part on Personal Data, it does not identify you personally. We may share this type of anonymous data with others, including service providers, our affiliates, agents and current and prospective business partners. For the purposes of our business we also collect what is known under the GDPR as special categories of Personal Data. We may collect the following types of special Personal Data: Health Data: Information about health, including any medical condition, health and sickness records Genetic information and biometric data In order to collect this special kind of data we need enhanced legal justifications beyond the ordinary legal justifications under the GDPR. We explain which justifications we rely on in paragraph 2.2 below. The Legal Basis for Collecting That Data There are a number of justifiable reasons under the GDPR that allow collection and processing of Personal Data. The main avenues we rely on are: “Consent”: Certain situations allow us to collect your Personal Data, such as when you tick a box that confirms you are happy to receive email newsletters from us, or ‘opt in’ to a service. “Contractual Obligations”: We may require certain information from you in order to fulfil our contractual obligations and provide you with the promised service. “Legal Compliance”: We’re required by law to collect and process certain types of data, such as fraudulent activity or other illegal actions. “Legitimate Interest”: We might need to collect certain information from you to be able to meet our legitimate interests - this covers aspects that can be reasonably expected as part of running our business, that will not have a material impact on your rights, freedom or interests. Examples could be your address, so that we know where to deliver something to, or your name, so that we have a record of who to contact moving forwards. For the special categories of data that we collect, the enhanced legal justification we rely on is: processing is necessary to protect the vital interests of the data subject or of another natural person where the data subject is physically or legally incapable of giving consent (“Incapacity”); processing is necessary for the purposes of preventive or occupational medicine, for the assessment of the working capacity of the employee, medical diagnosis, the provision of health or social care or treatment or the management of health or social care systems and services on the basis of Union or Member State law or pursuant to contract with a health professional and subject to the conditions and safeguards referred to in paragraph 3 (“Medical”); processing is necessary for reasons of public interest in the area of public health, such as protecting against serious cross-border threats to health or ensuring high standards of quality and safety of health care and of medicinal products or medical devices, on the basis of Union or Member State law which provides for suitable and specific measures to safeguard the rights and freedoms of the data subject, in particular professional secrecy (“Public Health”); processing is necessary for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes in accordance with Article 89(1) based on Union or Member State law which will be proportionate to the aim pursued, respect the essence of the right to data protection and provide for suitable and specific measures to safeguard the fundamental rights and the interests of the data subject (“Research”) HOW WE USE YOUR PERSONAL DATA Our Uses We will only use your Personal Data when the law allows us to. Set out below is a table containing the different types of Personal Data we collect and the lawful basis for processing that data. Please refer to section 2.2 for more information on the lawful basis listed in the table below. Examples provided in the table below are indicative in nature and the purposes for which we use your data may be broader than described but we will never process your data without a legal basis for doing so and it is for a related purpose. For further inquiries please contact us.