Spectrum Biomedical UK Limited Privacy Policy

We are Spectrum Biomedical UK Limited (trading as Spectrum Therapeutics Ltd) (Spectrum Therapeutics, we, us, our) a company registered in England and Wales with company number 11544382 with registered office address Unit 5 Century Court, Westcott Venture Park, Aylesbury, England, HP18 0XB.

This Privacy Policy sets out the way we use your personal data collected through this website or when you contact us: what we collect, how we collect it, how we use it, why we use it, who we share it with and the rights to which you may be entitled. We have tried to explain this in the most accessible way we can here, but if you have any questions at all you’re welcome to contact us at info@spectrumtherapeutics.com. 

We collect your personal data:

• when you visit this website
• when you create an account on this website to gain access to our information portal
• when you complete contact forms on this website
• when you correspond with us by post, telephone, email or otherwise, including correspondence we may have with you regarding our products
• from other publicly available sources such as confirming your registration number with the General Medical Council register
• from cookies as described under the heading Cookies

We may collect the following types of personal data:

• your name, contact details and date of birth
• your business details such as the name and contact details of your medical practice
• your medical speciality and areas of interest
• your medical professional registration number which we may verify using publically available sources if required
• details of any email or other communications you send us
• call notes relating to your interaction with our team by telephone
• information about your patients and their experience with Spectrum Therapeutics products if you report an adverse reaction to one of our products (please see the Special category personal data section below for further details).
• technical information relating to your browser or device such as browser type and IP address, as set out in further detail in the section headed Cookies 

If you do not provide this information you may not be able to access our information portal or otherwise receive educational information in relation to our products and services and educational webinars.

You can also sign up to our mailing lists to receive educational information relating to our products and services as well as details of our educational webinars. You may unsubscribe from these mailing lists at any time by contacting us by email at info@spectrumtherapeutics.com or using the unsubscribe link in our emails to you.

We will not request from you, and do not knowingly collect, any special category personal data such as health information about you or your patients. Please do not include any special category data in your communications with us.

If you disclose any special category personal data to us it will be processed in accordance with this Privacy Policy and applicable privacy law.  Unless we are required to disclose such special category personal data to relevant regulatory and governmental bodies we will delete such information if it has been identified in our systems.

If you submit special category personal data to us, you confirm to us that you consent and have obtained all necessary consents or are otherwise permitted to disclose such information to us under applicable privacy laws and have provided the relevant individual to which the personal data relates with a copy of this Privacy Policy.

Where special category personal data relates to an adverse reaction to our products we may be required by applicable law to disclose such personal information to relevant regulatory and governmental bodies such as the Medicines and Healthcare Products Regulatory Agency and Home Office.

We do not knowingly collect personal data from children who are 18 or younger.  Please do not use this website if you are under the age of 18.  The parent or guardian can contact us on info@spectrumtherapeutics.com  if a child has provided us with personal data and we will then delete any personal data relating to that child. 

Spectrum Therapeutics collects your personal data in order to:

• register you as an authorised medical professional to gain access to our information portal
• manage and administer your access to our information portal
• verify your medical professional registration number using publically available sources 
• provide educational materials and product information relevant to Spectrum Therapeutics products to authorised medical professionals only

• administer our business and this website
• undertake research and/or analysis of the level of engagement or interest in our products or otherwise in connection with the development of our products or business
• enable you to participate in any Spectrum Therapeutics activities such as clinical trials, patient support programs, and educational programs such as webinars
• conduct market research
• respond to messages, queries, feedback or complaints

• enable Spectrum Therapeutics to comply with any legal or regulatory obligation on us (e.g. product recall) or reporting requirements (e.g. making any required notification relating to adverse product reactions)
• establish, exercise or defend legal claims
• send you communications required by law or necessary to inform you about changes to the products and services we provide. Service messages won’t contain promotional content and therefore would not require prior consent
• any other reasonable purpose to which you consent or which we are required to undertake in order to fulfil our legal obligations to you or third parties

The legal bases (this is the legal requirement we must satisfy to process your personal data) we rely on to process your personal data are:

• consent e.g. the consent you give to wishing to receive educational materials and information relating to our educational programs such as webinars relevant to Spectrum Therapeutics products
• legitimate interest (please see below for further details of our legitimate interests)
• compliance with a legal obligation or regulatory requirement e.g. where we are required to make a notification regarding adverse product reactions

Our legitimate interests for using your personal data are to:

• ensure effective administration and management of your relationship with us, including your access to the information portal through our website
• manage, administer and operate our business effectively, including the operation of our website and information portal
• confirm medical professionals who register for an account with us are registered on the General Medical Council register
• provide educational materials and product information requested by medical professionals and enable participation by medical professionals in Spectrum Therapeutics activities such as educational webinars
• carry out research, development, and analysis on what educational materials, services or products medical professionals want or are interested in and how we can further improve and develop our educational materials, products, services and website
• understand and respond to messages, queries, feedback and complaints
• ensure network and information security
• maintain suppression records to ensure we have a record of any unsubscribes from our mailing lists
• transfer personal data in relation to the sale, transfer or re-organisation of all or part of our business and the acquisition of business
• enforce our legal rights and manage any dispute and legal claims and take legal or other professional advice

We do not knowingly collect any special category personal data such as health information of patients.  If you do provide special category personal data to us our lawful bases for processing such special category personal data are:

• Explicit consent where you have collected that from your patient for us to process such personal data
• Public interest in the area of public health e.g. ensuring quality and safety of Spectrum Biomedical medicinal products where processing is carried out by, or under the responsibility of, a healthcare professional such as a Doctor or medical laboratory technician

You may have the following rights in relation to your personal data:

• Right of access – you may have the right to request a copy of the personal data we have about you and to request supporting information explaining how the personal data is used;
• Right of rectification – you may have the right to request that we rectify inaccurate personal data about you;
• Right of erasure – you may have the right to request that we erase personal data about you;
• Right to restrict processing – in some situations, you may have the right to request that we do not use the personal data you have provided (for example, if you believe it to be inaccurate);
• Right to data portability – you may have the right to receive your personal data in a structured, commonly used and machine-readable format and to transmit such information to another controller;
• Right to withdraw consent – whenever you have given us your consent to use your personal data, you have the right to change your mind at any time and withdraw that consent;
• Right to object – where we are processing your personal data based on a legitimate interest (or those of a third party) you may challenge this. However, we may be entitled to continue processing your personal data based on our legitimate interests or where this is relevant to legal claims.

To protect the confidentiality of your information, we will ask you to verify your identity before proceeding with any request you make under this Privacy Policy. If you have authorised a third party to submit a request on your behalf, we will ask them to prove they have your permission to act. 

To make a request, please contact info@spectrumtherapeutics.com.

We share your personal data with our employees, contractors and consultants as well as our Canopy Growth affiliates and other third parties who require such information to assist us with our compliance with applicable laws, providing our website or managing our relationship with you, including third parties that provide services to us or on our behalf. In particular:

• We may share personal data about you with other members of the Canopy Growth group including Canopy Growth Corporation Canada, Canopy Growth Corporation Germany and Spectrum Therapeutics Germany so we can provide the best service across our group. We will also share personal data relating to adverse product reactions with other members of the Canopy Growth group.
• We may also share your personal data with certain contractors or service providers. This includes IT specialists, database providers, market research consultants, professional advisors, backup and disaster recovery specialists and email providers. Our suppliers and service providers will be required to meet our standards on processing information and security. The information we provide them, including your personal data, will only be provided in connection with the performance of their function. 
  

Your personal data may be transferred to other third party organisations in certain scenarios:

• If we're discussing selling or transferring part or all of our business – the information may be transferred to prospective purchasers under suitable terms of confidentiality;
• If we are reorganised or sold, information may be transferred to a buyer who can continue to provide services to you;
• If we're required to by law, or under any regulatory code or practice we follow, or if we are asked by any public or regulatory authority – for example the Home Office and Medicines and Healthcare Products Regulatory Agency as well as regulatory bodies in Canada;
• If we are defending a legal claim your information may be transferred as required in connection with defending such claim.

Your personal data may be shared if it is made anonymous and aggregated, as in such circumstances the information will cease to be personal data.

We store your personal data in the UK. When we share your personal data it may be transferred outside the UK. For example, Spectrum Therapeutics may disclose your personal data to Canopy Growth Corporation in Canada and Spectrum Therapeutics in Germany, other affiliates worldwide and other overseas organisations when necessary for our business operations.

We will only transfer your personal data outside of the UK where appropriate safeguards required by privacy laws are in place which includes countries with an adequacy decision or ensuring standard contractual clauses approved by the European Commission are in place. To request a copy of the standard contractual clauses please contact us at info@spectrumtherapeutics.com.

We will keep your personal data for as long as it is reasonably necessary. It will depend on factors such as whether you have signed up for an account to view our information portal or recently requested educational information from us. We will also retain your information as necessary to comply with legal, regulatory, accounting or reporting requirements.

Spectrum Therapeutics website may contain links to other websites that may contain different privacy policies and terms of use. To the maximum extent permitted by law, we cannot and do not assume any responsibility for the privacy practices, policies or actions of the third parties that operate these websites. Spectrum Therapeutics is not responsible for how such third parties collect, use or disclose your personal information. You should review the privacy policies of these websites before providing them with your personal data. 

A cookie is a small text file that is stored by your browser and allows it to remember information between web pages and browser sessions. Cookies can only store text, which is generally anonymous and usually encrypted.  There are two main types of cookies:

• Session cookies: specific to a particular visit and limited to sending session identifiers (random numbers generated by the server) so you don't have to re-enter information when you navigate to a new page.  Session cookies are not permanently stored on your device and are deleted when the browser closes.
• Persistent cookies: record information about your preferences and are stored in your browser cache or mobile device.

Spectrum Therapeutics only uses essential cookies. This means using cookies that are essential to operate our website and to enable you to navigate and use the website as well as to facilitate the transmission of communications through our website (for example, when you submit information through the "contact us" form).  The information collected relates to the operation of the website and enables us to provide the website to you as well as facilitate communications through the website.

You may not be able to take advantage of all the features of our website and there may be issues with website functionality if you delete or refuse essential cookies.

Spectrum Therapeutics uses cookies to enable some basic website functionality that is strictly necessary for the operation of our website. The information collected through these cookies is only used for website functionality and is not shared with any third parties.

This Privacy Policy may change from time to time and is available on our website. You can tell when this Privacy Policy was last updated by looking at the date at the top of the Privacy Policy. If we make changes to this Privacy Policy, we will post the updated version on our website.

If we make a change that significantly affects your rights or, to the extent we are permitted to do so, significantly changes how or why we use personal data, we will notify you by way of a prominent posting on this website prior to the change becoming effective.

If you have an account with us, we may also notify you about changes to this Privacy Policy by e-mail to the email address you used to sign up for your account.

Any changes to this Privacy Policy will become effective upon posting. We encourage you to review this website from time to time for the latest information.

If you have any queries or complaints about our Privacy Policy or processing of personal data, please contact us at info@spectrumtherapeutics.com.