1. Important information and who we are
Purpose of this policy
This policy gives you information on how we look after any personal data that we collect or receive about you and tells you about your privacy rights and how the law protects you. This policy also applies to information that we process about you when you visit our website at https://oxfordendovascular.com/ regardless of where you are located.
This website is not intended for children and we do not knowingly collect data relating to children.
Oxford Endovascular is the controller and responsible for your personal data.
If you have any questions about this policy, including any requests to exercise your legal rights, please contact
us using the details set out below:
Email address: email@example.com
Oxford Endovascular Limited
9400 Garsington Road
Oxford Business Park
You have the right to make a complaint at any time to your local data protection authority if you are in the UK or in the EEA. If you are in the UK, the regulator is the Information Commissioner’s Office (ICO) (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach a regulator so please contact us in the first instance.
Changes to the policy and your duty to inform us of changes
We keep this policy under regular review. This version was last updated on the 12 July 2021.
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 your relationship with us.
2. The data we collect about you
Personal data, or personal information, 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 as follows:
• Identity Data includes first name, last name, maiden name, title, job title and your organisation’s details.
• Contact Data includes your or your organisation’s address, email address and telephone number.
• Technical Data includes the 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 this website.
• Usage Data includes information about how you use this website and services.
• Marketing Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.
• Shareholder Data includes information relating to actual, potential or former individual shareholders of Oxford Endovascular, as well as representatives of institutional or corporate shareholders of Oxford Endovascular, which may include details of your participation in Oxford Endovascular’s affairs as an individual shareholder (where applicable) or representative of an institutional or corporate shareholder, such as attendance at and contribution to meetings, voting records etc, details of your respective shareholdings and any other information which is required to be recorded about you as a shareholder by law or which we hold in relation to your current or former shareholding or which we may acquire in connection with any discussions relating to potential shareholding.
We do not collect, use and share Aggregated Data such as statistical or demographic data for any purpose. We do not collect any Special Categories of Personal Data about you (i.e. details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data), except in very limited circumstances where you might voluntarily provide such information to us (for example, if you were to inform us of any on dietary requirements in connection with religious reasons, or particular access requirements due to any health reasons) in which case your provision of the information would indicate your consent to us using the information for the purposes given. Nor do we collect any information about criminal convictions and offences.
If you fail to provide personal data
Where we need to collect personal data by law, under the terms of a contract, or to provide a service to you, and you fail to provide that data when requested, we may not be able to perform the service (for example, so that you can take part in a questionnaire or a focus group).
3. How is your personal data collected?
We use different methods to collect data from and about you including through:
• Direct interactions. You may give us your Identity, Contact, Profile, Shareholder Data, Marketing Data by corresponding with us or during the course of your dealings with Oxford Endovascular. This includes personal data you provide or we receive when you:
• contact or correspond with us about our products or services;
• contact or correspond with us about products or services that you or the organisation that you represent provide;
• request marketing information to be sent to you;
• contact us generally; or
• (in the case of Shareholder Data) when you first subscribe to or discuss with us potentially subscribing to shares, and during any subsequent subscriptions and any exercise of your rights as a shareholder (or as a representative of a shareholder).
• Automated technologies or interactions. As you interact with this website we will automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies. Please see Cookies, below for more information.
• Third parties or publicly available sources. We will receive personal data about you from various third parties. We may also collect Technical Data from analytics providers and advertising networks.
4. How we use your personal data
Purposes for which we will use your personal data
We have set out below, in table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate. When we rely on legitimate interests 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. 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.
We may process your personal data for more than one legal basis depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal basis we are relying on to process your personal data where more than one basis has been set out in the table below. We may also process your personal data:
• to establish, exercise or defend legal claims; or
• as necessary to comply with our legal obligations.
|Purpose/Activity||Type of data||Legal basis for processing including
basis of legitimate interest
To manage our relationship with the following:
(c) Those who contact us through this website
(c) Any other personal information you provide to us relevant to the enquiry or issue raised
|(a) Performance of a contract if we have
entered into a contract with you
(b) Necessary for our legitimate interests (to provide or receive information, products or services requested)
To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)
(a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security and in the context of a business reorganisation or group restructuring exercise)
(b) Necessary to comply with a legal obligation
|To use data analytics to improve this website, marketing, and experiences||
Necessary for our legitimate interests (to keep this website updated and relevant, to develop our business and to inform our marketing strategy)
In respect of Shareholder Data, to manage our relationship with our shareholders and to administer our business
(a) Performance of a contract if we have entered into one with you (for example, shareholders agreement, investment agreement or deed of adherence)
(b) Necessary for our legitimate interests (for the proper administration of Oxford Endovascular, in connection with potential investments, undertaking due diligence exercises or compliance with applicable laws, regulations and procedures, and in respect of any other activities relevant to managing personal data relating to actual, potential and former shareholders) (c) Compliance with legal obligation (for example, to facilitate the payment of tax or to make a relevant filing at Companies House)
To manage particular access or dietary requirements
Any Special Category data you may voluntarily provide to us for this purpose
Marketing and Opting out
We strive to provide you with choices regarding certain personal data uses, particularly around marketing.
You can ask us to stop sending you marketing messages at any time by following the opt-out links on any
marketing message sent to you.
We will not share your personal data with any third party for marketing purposes.
Change of purpose
We will only use your personal data 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 you wish
to get an explanation as to how the processing for the new purpose is compatible with the original purpose,
please contact us.
If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal
basis which allows us to do so.
Please note that we may process your personal data without your knowledge or consent, in compliance with
the above rules, where this is required or permitted by law.
This helps us to provide you with a good experience when you browse this website and also allows us to improve this website. A cookie is a small file of letters and numbers that we store on your browser or the hard drive of your computer if you agree. Cookies contain information that is transferred to your computer’s hard drive.
We use the following cookies:
• Strictly necessary cookies. These are cookies that are required for the operation of this website. They include, for example, cookies that enable you to submit your details to us.
• Functionality cookies. These cookies are used to recognise you when you return to the website and remember your previously selected preferences (for example, language or location preferences).
• Advertisement cookies. These cookies collect information about your visit to this website, the content you viewed, the links you followed and information about your browser, device, and your IP address. They are used to provide visitors with relevant ads and marketing campaigns and track visitors across websites and collect information to provide customised ads to them.
• Analytics and performance cookies. These allow us to recognise and count the number of visitors and to see how visitors move around our website when they are using it. This helps us to improve the way this website works, for example by ensuring that users are finding what they are looking for easily.
You can block cookies by activating the setting on your browser that allows you to refuse the setting of all or some cookies. However, if you use your browser settings to block all cookies (including essential cookies) you may not be able to access all or parts of this website.
6. Disclosures of your personal data
We may share your personal data with the parties set out below for the purposes set out in the table in section 4 above.
• Vendors and service providers – we provide information to vendors and service providers who support our respective operations, such as by providing IT services
• Professional advisers and other external parties – including lawyers, bankers, auditors and insurers who provide professional services.
• Legal, supervisory, and regulatory authorities – we may share information with legal, supervisory and regulatory authorities and any government agencies and law enforcement bodies, or in response to a valid subpoena or legal process served by a third party, to comply with our legal obligations; protect the rights and property of Oxford Endovascular and our employees; and to detect and respond to suspected illegal activity and threats to the safety of any person, systems or services.
• Shareholders – we provide information to shareholders as part of our reporting activities. • In connection with any restructuring or investment – we provide information to third parties to whom we may choose to sell, transfer or merge parts of our business or our assets or who may choose (or contemplate) to invest in us. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this policy.
• Funds – we provide information to funds managed by shareholders of group companies.
• Group companies – we provide information to members of the same group as our shareholders, as well as their professional advisers.
We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.
|List of Cookies||Category||Necessity||Purpose||Duration|
|cookielawinfo-checkboxfunctional||Necessary||Required||This cookie stores if a visitor has accepted functional cookies.||1 year|
|cookielawinfo-checkboxnecessary||Necessary||Required||This cookie stores if a visitor has accepted necessary cookies."||1 year|
|cookielawinfo-checkboxperformance||Necessary||Required||This cookie stores if a visitor has accepted performance cookies."||1 year|
|cookielawinfo-checkboxanalytics||Necessary||Required||This cookie stores if a visitor has accepted analytics cookies.||1 year|
|cookielawinfo-checkboxadvertisement||Necessary||Required||This cookie stores if a visitor has accepted targeting cookies.||1 year|
|cookielawinfo-checboxothers||Functionality||Optional||This cookie is used to store the user consent for cookies, which have not been classified yet and therefore fall within the category Other and to keep records of these consents.||1 year|
|VISITOR_INFO1_LIVE||Advertisement||Optional||This cookie is set by Youtube. It is used to track the information of the embedded YouTube videos on a website.||5 months 27 days|
|test_cookie||Advertisement||Optional||This cookie is set by DoubleClick (which is owned by Google) to determine if the website visitor's browser supports cookies.||15 minutes|
|IDE||Advertisement||Optional||Used by Google DoubleClick and stores information about how the visitor uses the website and any other advertisement before visiting the website. This is used to present users with ads that are relevant to them according to the user profile.||1 year 24 days|
|GPS||Analytics||Optional||This cookie is set by Youtube and registers a unique ID for tracking visitors based on their geographical location.||30 minutes|
|YSC||Performance||Optional||This cookie is set by Youtube and is used to track the views of embedded videos.||Session|
7. International transfers
We may transfer your data out of the UK (including to the US, Mauritius, Cayman Islands, British Virgin Islands and China, where some of our service providers or shareholders are based) to countries where data protection laws do not afford the same degree of protection as within the UK, in which case we take measures to implement appropriate safeguards to protect your data. We may also transfer your personal data to countries (including Jersey where one of our shareholders is based or a member state of the EEA) that have been deemed to provide an adequate level of protection for personal data. Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the UK.
8. Data security
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.
We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
9. Data retention
How long will we use your personal data?
We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.
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 from 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, regulatory, tax, accounting or other requirements.
Details of retention periods for different aspects of your personal data are available in our retention policy which you can request from us by contacting us.
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.
10. Your legal rights
Under certain circumstances, you have rights under data protection laws in relation to your personal data. Please click on the links below to find out more about these rights:
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.
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.
• 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 services to you. We will advise you if this is the case at the time you withdraw your consent.
If you wish to exercise any of the rights set out above, please contact us using the details set out above.
No fee usually required
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances.
What we may need from you
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
Time limit to respond
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.