Privacy Notice

Introduction

SEQ is committed to protecting and respecting your privacy and storing your personal information safely.

SEQ is a data controller, which means that we are responsible for how we hold and use information about you. We are required under data protection legislation to notify you of the information contained in this Privacy Policy. This Privacy Policy outlines how we collect, use, share and protect any personal information which you give us or which is given to us on your behalf or which is otherwise acquired about you.

PERSONAL INFORMATION means any information relating to an identified or identifiable natural person (known as a data subject).

IDENTIFIABLE NATURAL PERSON means one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.

SENSITIVE PERSONAL INFORMATION means data concerned with the racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, and the processing of genetic data, biometric data for the purpose of uniquely identifying a natural person, data concerning health or data concerning a natural person’s sex life or sexual orientation..

We recommend that you print a copy of this Privacy Policy for your future reference. If you do not agree to this Privacy Policy then you must not use this website (”the Site”) or upload personal information or other material to the Site or otherwise provide personal information to SEQ.

This Privacy Notice sets out how we may collect, use, share and store your personal information. This includes informing you of your rights regarding your personal information that we hold. By way of examples, we may receive that personal information:

  • from you or from someone on your behalf;
  • from a referring facility e.g. a hospital;
  • from allied healthcare professionals e.g. your GP;
  • through contracts or other legal arrangements you have with us or our partners on behalf of us; or
  • to enable us to comply with our contractual/legal obligations;.
  • from third parties who you have given consent to pass this information on to us.

The Laws and Regulations

The laws that govern personal data in Isle of Man are:

  • REGULATION (EU) 2016/679 OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC (General Data Protection Regulation) (“GDPR”);
  • The Data Protection Act 2018

The independent authority that upholds information rights in the public interest in the Ireland is the Data Protection Commission (“the DPC”). Further information can be found at www.gov.im/about-the-government/data-protection-gdpr-on-the-isle-of-man/

Who Is SEQ

SEQ Limited

Address: Nerin House, 26 Ridgeway Street, Douglas, Isle of Man IM1 1EL

Email:   enquiries@nerin.co.im

Phone:    +44 1624 692999

Website:  http://www.seq.co.im/

In this Policy we will refer to SEQ as “SEQ”, “the Company”, “us” or “we”.

Information we may collect from you

SEQ may collect, use, share and store personal information about you which may be provided by you or by someone on your behalf. We will only collect, use share and store your personal information when the law allows us to. Most commonly, we will collect, use, share or store your information in the following circumstances:

  • You have given explicit consent to the processing of your personal information for one or more specified purposes;
  • It enables us to provide information about our products and services and/or related products and services;
  • We require the personal information to perform a contract with you or to take steps prior to entering into such a contract with you;
  • To provide services to you after you have taken one of our educational certifications/qualifications including validation of your certification/qualification by us
  • We need to obtain and process the personal information to comply with our legal obligations;
  • It is necessary to protect your vital interests or that of another natural person;
  • It is necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in us;
  • Where we have a legitimate interest (or there is a legitimate interest of a third party) and your interests and fundamental rights do not over rise those interests.

Information you give us

You may give us information about you with your consent, for example:

  • By filling in a form or sending us an e-mail
  • Participating in our
  • Applying for a job at SEQ.

This information may be personal, financial, educational, or related to your employment history.

You may give us information for legal reasons, such as to enter into a contract with us or when you are taking a job at SEQ.

Information we collect about you

To view our Site you do not have to provide any personal information. However, we do use Cookies (see ).[Please note that similar to most professional websites, we do not actually store user passwords as provided by the user, but rather store a cryptographic transformation of the password in order to protect the ].

Our server logs automatically collect information, such as your IP address, your device type and ID, your browser type and language, the pages on the Site visited, and the date and time of your visit and your location when visiting the Site. This helps us to gather statistics on the Site and to track users’ movements around the Site in order to customise and improve the Site. It also allows us to customise the advertising on the

We may use standard Internet tools, such as web beacons and cookies, which collect information that tracks your use of the Site and enables us to customise our services and advertisements.

COOKIES

Cookies are small text files that are stored in the hard drive of your computer by websites that you visit. We use cookies to improve your experience and to provide advertising on the Site. In particular, cookies are used to keep a record of your preferences.

 

We also use temporary session cookies which enable a visitor’s web browser to remember which pages on this website have already been visited. Please see our separate Cookies Policy which can be found here: [more information on the type of cookies we use and why.

Most web browsers automatically accept cookies, but, if you wish, you can change the settings on your browser to refuse all cookies. However, you should note that disabling cookies may result in some parts of the Site not working efficiently or in slower downloads.

Information we receive from other sources

We may receive information about you if you use any of the other we operate, any other services we provide, or from our business partners instructed to collect information on our behalf.

We also work with third parties (including, for example, business partners, sub-contractors in technical, payment and delivery services, advertising networks, analytics providers, search information providers, credit reference agencies, background checking agencies) and may receive information about you from them as part of the service we provide you, or for legal reasons.

Why does SEQ collect personal information?

We need all the categories of information in the list below primarily to allow us to perform a contract with you marked *[MARK THOSE WITH AN *] and to enable us to comply with legal obligations marked ** [MARK THOSE WITH AN **]. In some cases we may use your personal information to pursue legitimate interests of our own or those of third parties, marked *** [ MARK THOSE WITH AN ***] provided your interests and fundamental rights do not override those interests. The situations in which we will process your personal information are listed below. We have indicated by asterisks the purpose or purposes for which we are processing or will process your personal information, as well as indicating which categories of data are involved.

Some of the above grounds for processing will overlap and there may be several grounds which justify our use of your personal information.

If you fail to provide personal information

If you fail to provide personal information when requested, we may not be able to enter into a contact with you or perform the contract we have entered into with you, or we may be prevented from complying with our legal obligations. It may also result in your inability to obtain certain services or use certain features of the Site.

Change of purpose

We will only use your personal information for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If we need to use your personal information for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

Please not that we may process your personal information without your knowledge or consent, in compliance with the above rules, where this is requested or permitted by law.

Who might SEQ share your information with?

SEQ may share your personal information with third parties, either because you have explicitly consented to allow us to do so or we are    required by law or it is necessary to administer the working relationship with you or where we have another legitimate interest in doing so.

 

We require third parties to respect the security of your data and to treat it in accordance with the

For example, we may share your personal information with:

  • Our group companies, which means our subsidiaries, or our ultimate holding company and its subsidiaries. We will share your personal information with other group companies as part of our regular reporting activities on company performance, in the context of a business reorganisation or group restructuring exercise, for system maintenance support and hosting of data and Competent Authorities in accordance with the law.
  • Subcontractors and third parties for the purpose of the performance of a contract that we hold with them or that we hold with you;
  • With other third parties because you have given explicit consent;
  • With third parties who provide services because you have purchased goods or services or you are legally entitled to these services;
  • In order to comply with the law;

All our third-party service providers and other group companies are required to take appropriate security measures to protect your personal information in line with their policies.

Other reasons SEQ may share your personal information with a third party

If SEQ or substantially all of its assets are acquired by a third party, personal data held by SEQ about its customers will be one of the transferred assets. In addition, SEQ will share your personal data with third parties for the following reasons:

  • To enforce or apply our Website Terms of Use, Terms and Conditions of contract, or other agreements;
  • To protect the rights, property or safety of SEQ, our customers or others;
  • We will exchange information with other companies or organizations to prevent fraud or to reduce our credit risks.

Aggregated or anonymized data with personal information removed

SEQ may, from time to time, provide third parties with data that has been aggregated or anonymized.

This means that your personal information that could be used to identify you have been removed from the data. Data provided to third parties in this way is not personal data; however, you do keep your right to object to this use.

Security

We have put in place measures to protect the security of your information. Details of these measures are available upon request from enquiries@nerin.co.im .

Third parties will only process your personal information on our instructions and where they have agreed to treat the information confidentially and to keep it secure.

We have put in place appropriate security measures to prevent your personal information from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal information to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal information on our instructions and they are subject to a duty of confidentiality.

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

Where we store your personal data

We primarily store and process your personal data in the EU/European Economic Area (“EEA”). If we do transfer your personal data outside the EEA it will be because you have explicitly consented or because we have a legal reason to do so.
Some examples of reasons your data may be processed outside of the EEA include:

 

  • Technical support services
  • Communication with our subsidiaries, or our ultimate holding company and its subsidiaries,

If your personal data cannot be processed within the EEA, we will:

  • Comply with all other data protection principles

Where possible, be to a country that is on the list of the EU Commissions’ countries that provide adequate protections for the rights and freedoms of data subjects

  • Make sure we have assessed the adequacy of protections in all other cases.

Transmission and storage of your personal data

Unfortunately, the transmission of information via the internet is not completely secure. Although we use best practice to ensure your data is encrypted to the standard required in the GDPR to protect your personal data, we cannot guarantee the security of your data as it is transmitted and stored.

How long will you keep my personal information?

SEQ will not retain your personal information for longer than required to fulfil the purpose we collected it for including for the purposes of satisfying any legal, accounting, or reporting requirements. Details of retention periods for different aspects of your personal information are available from enquiries@nerin.co.im.

To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm form unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.

In some circumstances we may anonymise your personal information so that it can no longer be associated with you, in which case we may use such information without further notice to you.

In general we will keep your personal information:

  • For as long as required by law
  • Until we no longer have a valid reason for keeping it
  • Until you request us to stop using it.
  • We may keep just enough of your personal information to ensure that we comply with your requests not use your personal information or comply with your right to erasure. For example, we must keep your request to be erased even if it includes your personal data until such time as you are no longer our customer.

If you have questions about our Record Management Policy, we can provide you a copy. Please contact enquiries@nerin.co.im.

Your Rights

We recognise that you may have certain rights at law in relation to Personal Information that we hold about you. If you:-

  • require details of the Personal Information that we hold about you;
  • require copies of the Personal Information that we hold about you;
  • require Personal Information to be erased;
  • require the processing of your data to be restricted;
  • object to the processing of your Personal Information;
  • object to automated decision making and profiling;
  • require a transfer of your Personal Information;
  • consider that information held about you is incorrect, incomplete or inaccurate;

please complete our Request Form. Further details about these rights are contained below in the section headed Legal Rights and also in the Request Form.  We will then consider your request and we will comply with your request to the extent that we are obliged by applicable law to so do. If you are registered with us please supply details of your username and email address which you supplied when registering. Please note that to protect your privacy we may require further information to verify your identity.

You will not have to pay a fee to access your personal information (or to exercise any of the other rights). However, we may charge a reasonable fee if your request for access is clearly unfounded or excessive. Alternatively, we may refuse to comply with the request in such circumstances.

In the limited circumstances where you may have provided your consent to the collection, processing and transfer of your personal information for a specific purpose, you have the right to withdraw your consent for that specific processing at any time. To withdraw your consent, please contact enquiries@nerin.co.im. Once we have received notification that you have withdrawn your consent, we will no longer process your information for the purpose of purposes you originally agreed to, unless we have another legitimate basis for doing so in law.

Legal rights

The right to be informed

SEQ is publishing this Privacy Policy to keep you informed as to how we collect, use, share and store your personal information. We strive to be transparent about how we use your personal information.

The right of access

You have the right to require details of the personal information we hold about you and to obtain copies of it.  If you want to exercise this right, please complete our Request Form.

The right to rectification

If the personal information SEQ holds about you is incorrect, inaccurate or not complete, you have the right to ask us to rectify it. If that personal information has been passed to a third party with your consent or for legal reasons, then we must also ask them to rectify the personal information unless this proves impossible or involves a disproportionate effort.  If you want to exercise this right, please complete our Request Form.

The right to erasure

This is sometimes called ‘the right to be forgotten’.  If you want to exercise this right and we do not have a legal reason to continue to process and hold your personal data,   please complete our Request Form.

The right to object to or restrict processing

You have the right to object to us processing your personal information or to restrict how we process your personal information. This means we are permitted to store the data but not further process it. We keep just enough data to make sure we respect your request in the future.  If you want to exercise this right, please complete our Request Form.

The right to data portability

SEQ must allow you to obtain and reuse your personal information for your own purposes across services in a safe and secure way without this effecting the usability of your data. If you want to exercise this right, please complete our Request Form.This right only applies to personal data that you have provided to us as the data controller. The data must be held by us on consent or for the performance of a contract.

The right to object

You have the right to object to us using automated decision making and profiling. If you want to exercise this right, please complete our Request Form.

The right to withdraw consent

If you have given us your consent to process your personal information but change your mind later, you have the right to withdraw your consent at any time, and SEQ must stop processing that personal information. If you want to exercise this right, please complete our Request Form.

The right to complain to a Supervisory Authority

You have the right to complain to the DPC if you feel that SEQ has not responded to your requests to solve a problem. You can find their contact details here: http://www.gov.im/about-the-government/data-protection-gdpr-on-the-isle-of-man/

Links to Other Websites

From time to time, the Site may contain links to and from websites of our partner networks, advertisers, d affiliates and other third parties. We do not exercise any control or supervision over the content of these linked sites. Accordingly, this Privacy Policy does not cover these third party websites. If you follow a link to any of these websites, please note that these websites may have their own privacy notices and that we do not accept any responsibility or liability for any such notices. Please check these notices, where available, before you submit any personal data to these websites.

Changes to Our Privacy Notice

Please note that we may, at our absolute discretion, change, modify, add to or delete portions of this Privacy Policy at any time. When we do this, we will notify you of these changes by inserting an “updated” icon next to the link for the Privacy Policy on each page of the Site for one month from the date of the change. In addition, if appropriate, we will send a copy of the revised Privacy Policy with an explanation as to what will be the likely impact of these changes to the address we have on record for you (which may be an email address). If you no longer accept this Privacy Policy or any changes or variations to this Privacy Policy you must cease providing personal information. Your continued provision of personal information is deemed to be acceptance of this Privacy Policy and any changes thereto.

This notice was last updated in May 2018.