DATA PRIVACY MATTERS
This is your guide to how personal data is managed by Kora Healthcare. Please read it carefully.
Data privacy is taken very seriously at Kora Healthcare. It is important that you know exactly what we do with the personal information you and others provide to us, why we gather it and what it means to you. This document outlines our approach to Data Privacy to fulfil our obligations under the General Data Protection Regulation (2018). We also welcome it as an opportunity to reassure you of the importance we place on keeping your personal data secure, and of the strict guidelines we apply to its use. We want you to be clear on:
- Who we are
- The information we collect about you
- When and how we collect information about you
- When you ask us to provide you with certain product and services
- How we use your personal data*
- Who we share your information with and Disclosure of personal data to others
- International Transfers
- Data Security
- Updating your personal data
- How long we hold your information
- How to exercise your information rights (including the right to object)
- How to contact us and/or our Data Protection Officer
*This notice applies to all our products and services. Your product or service terms and conditions will specify which of our businesses is providing the relevant product or service to you. Please note that Kora Healthcare operates a number of websites under a number of domain names and other region specific aliases. If you have any questions about how your information is gathered, stored, shared or used, please contact our Data Protection Officer. You have a number of rights in relation to your information, including the right to object to processing of your personal information for direct marketing or where the legal basis for our use of your data is our legitimate business interests or performance of a task in the public.
Who we are
Kora Corporation Ltd (trading as Kora Healthcare)
Swords Business Park
Company Registration Number: 219439
Tel: 00353 1 8900460
The Information We Collect about You:
In general, you can browse our website without telling us who you are or revealing any personal information about yourself. We collect and use aggregated data such as statistical and analytical information about your visit. This information is collected on an aggregate and non-individual specific basis of all browsers, provides general and not individually specific information about the number of people who visit this website, the number of people who return to this site, the pages that they visit, where they were before they came to this site and the page in the site at which they exited. This information helps us diagnose any website faults and monitor traffic on our website so that we can manage the site’s capacity and efficiency. It also helps us to understand which parts of this site are most popular and generally to assess user behaviour and characteristics in order to measure interest in and use of the various areas of the site.
When engaging with Kora Healthcare or browsing our websites, we will collect and gather information under specific categories of personal data. There are a number of reasons for gathering information about you. For example, there are a few places where we give you an opportunity to provide us with a small amount of personal information about yourself such as your name, contact details and email address, so that we know how to get in touch with you, offer you products and services and give you the best possible customer service. Where data is submitted it will be used for the stated purpose and any reasonably incidental purposes only. The information we collect falls into various categories:
- Such as first name, surname, gender, date of birth, salutation.
- Such as address, e-mail address, telephone number, delivery address.
Marketing and Communications Data
- Such as your preferences in receiving marketing communications from us and third parties and your communication preferences.
- Such as when you purchase/purchased or were supplied with a product and your repeat purchase history.
Sensitive categories of data
- We may hold information about you which includes sensitive personal data, such as health information. We only hold this data when we need to for the purpose of the product or service we provide to you or where we have a legal obligation to do so. Examples of when we use this type of data included: Medical information, for example, where you are reporting a product compliant, adverse reaction, or adverse event or any other quality or pharmacovigilance related information.
Information about you provided by others
- If you give us information about someone else, or someone gives us information about you, (for example if you doctor provides you information if there is a product compliant) we may add it to any personal information we already hold and use it in ways described in this Data Privacy Notice.
Information which you have consented to us using
- Your agreement to allow us contact you through certain channels to offer you relevant products and services.
Information from online activities
- We collect information about your internet activity using technology known as cookies, which can often be controlled through internet browsers.
When and how we collect information about you
As you use our services, purchase products, make enquiries and engage with us, information is gathered about you. We may also collect information about you from other people and other parties, for example, where you have chosen to make your information publically available, such as social media sites.
Where we need to collect personal data by law, or under the terms of a contract we have with you (e.g. a purchase that you have made) and you don’t provide that personal data when requested, we may not be able to perform the contract we have or are trying to enter in with you. In this case, we may not be able to provide all or part of the relevant service.
When you ask us to provide you with certain product and services
- When you use our website and online services provided by us.
- When you or others give us information verbally or in writing (such as records of your transactions or if you wish to make a complaint)
- When you use our products or services, including making transactions via our website, we gather details about if the transaction has been clear by the online merchant bank and where we can deliver the product or service to.
- When you subscribe to our website newsletter.
- When you submit responses or queries via our website.
- When you submit responses to surveys or polls or provide feedback or make available any other content on our website.
- When you submit your CV via our careers page.
- When you request marketing communications to be sent to you.
We may receive personal data about you from various third parties as set out below
Contact, Financial and Transaction Data from providers of technical, payment and delivery services such as Realex, Elavon and Docusign.
Contact and Profile Data from providers such as Survey Monkey, Mail Chimp and any other networks you choose to link your Kora Healthcare account with.
How we use your personal data
Whether we are using it to confirm your identity, to help in the processing of product transaction or to improve your experiences with us, your information is always handled with care and the principals outlined in this Data Privacy Notice are always applied.
We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:
- Where we need to perform the contract (e.g. product transaction) we are about to enter into or have entered into with
- Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
- Where we need to comply with a legal or regulatory obligation
- Where you have given us permission (which you may withdraw at any time)
Generally we do not rely on consent as a legal basis for processing your personal data other than in relation to sending direct marketing communications to you via email. You have the right to withdraw consent at any time by contacting us.
We do not request from you and we request that you do not provide any special categories/sensitive personal data (for example, personal data relating to racial or ethnic origin, political or religious opinions, membership of a trade union, physical or mental health or condition or sexual life or orientation). This type of personal data is subject to special protections under EU law.
We may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your personal data. Please contact us using firstname.lastname@example.org if you need details about the specific legal ground we are relying on to process your personal data.
We may use your identity, contact etc to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant to you. You will receive marketing communications from us if you have requested information from us or purchased services from us, or if you provided us with details when you entered a competition or registered for a promotion, and in each case, you have not opted out of receiving that marketing. You can opt out of any marketing communications from us at any time by using the “unsubscribe” function at the bottom of the marketing email we send you or by contacting us using email@example.com .
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 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 or regulation.
Who we share your information with and Disclosure of personal data to others
- if you have indicated at submission, or at any time during your time as a user of the website, that you are happy to receive information or promotions from selected third parties about goods and services which may be of interest to you, we will send you such offers or information. See Marketing above on how to change your preferences;
- any member of our group of companies, which means our subsidiaries, our ultimate holding company and its subsidiaries, where it is necessary to do so for the provision and administration of the services we provide to you;
- we contract with other entities that perform certain tasks on our behalf and who are under our control (“Service Providers”). This is required in order to provide and manage our websites and one or more services. Such service providers include; IT systems suppliers and support, data storage, IT developers, insurance, payment processors, analytics companies, website hosting providers and other service providers;
- professional advisors such as accountants, auditors, lawyers, bankers, insurers, and other outside professional advisors
- entities that regulate or have jurisdiction over Kora Healthcare. We will disclose your personal data in order to comply with any legal obligation, if we are ordered to do so by a court of competent jurisdiction, law enforcement, regulatory or administrative authorities or in order to enforce or apply our Terms and Conditions and other agreements, or to protect the rights, property, or safety of Kora Healthcare, our Customers, Website users or others. This includes exchanging personal data with third parties for the purposes of fraud protection and credit risk reduction.
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 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. Unless prevented by applicable law, we will notify you when your personal data may be provided to third parties in ways other than explained above, and you may have the option to prevent such sharing at the time that we notify you.
International data transfers
- Where the country has been deemed to provide an adequate level of protection for personal data by the European Commission. For further details, see European Commission: Adequacy of the protection of personal data in non-EU countries.
- We may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe. For further details, see European Commission: Model contracts for the transfer of personal data to third countries.
- Where service providers are based in the US, we may transfer data to them if they are part of the EU-U.S. Privacy Shield which requires them to provide similar protection to personal data shared between the Europe and the US. For further details, see European Commission: EU-US Privacy Shield.
We will provide you on request a list of the countries located outside the EEA to which personal data may be transferred, and an indication of whether they have been determined by the European Commission to grant adequate protection to personal data. Where applicable, you are entitled, upon request to receive a copy of the relevant safeguard (for example, EC model contractual clauses) that has been taken to protect personal data during such transfer.
We take our Date Security responsibilities seriously. We want you to have continuing trust in Kora Healthcare and in our products and, so, we have put in place physical, electronic, technical and managerial procedures to safeguard and secure your personal information. We have SSL certification on our website.
To prevent unauthorised access or disclosure of personal data under our control, Kora Healthcare has appropriate security management systems in place to safeguard the personal data we collect. Firewalls, intrusion detection and virus scanners are used on our websites. Encryption/password protection during transmission is also used on sections of the Website where security is particularly important. While Kora Healthcare makes reasonable efforts to protect all personal data, no data transmission over the Internet can be guaranteed to be 100% secure. As a result Kora Healthcare cannot ensure or warrant the security of any personal data you transmit to us, you do so at your own risk. You acknowledge that we are not responsible for any intercepted information sent via the Internet, and you hereby waive, release and discharge us from any and all claims arising out of or related to the use of intercepted information in any unauthorised manner.
Safe and Secure Trading
At Kora Healthcare we are aware that some people may be concerned about giving their credit card details via the Internet, so that’s why we trade using only the highest levels of credit card security over a PCI compliant and secure network providing you with the world renowned and trusted organisation, Realex.
All details are confidential whilst input on the website and only the products ordered, not the credit card details, are sent to Kora Healthcare using secure data encryption software. This means that all orders and personal data registered on our websites are coded and can only be decoded by Kora Healthcare.
As an extra security measure, your credit card details will not be retained on our servers and are only used in the Realex transaction order. This is why you must re-enter your card details each time you purchase anything from our websites
Updating your personal data
It is important that the personal data we hold is accurate and current. Please keep us informed, by using the Contact Us information below if any of your personal data changes during your relationship with us. It is your responsibility to keep your personal data up to date at all times.
Links to third party websites
When browsing our website we may display or give the option to link to a third party website for example news or social media. This information is disclosed for your convenience and information, however if you access some of the links and web addresses disclosed on these pages, you will leave our website. The website contains links to and from the websites of our partner networks, customers, advertisers and affiliates as well as third party websites to which we have no affiliation. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these websites or their policies.
How long we hold your information
We retain personal data for no longer than is allowed under data protection law and, in any case, no longer than such personal data is necessary for the purpose for which it was processed. 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, the purposes for which we process personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.
How to exercise your information rights (including the right to object)
The legal basis for using your information
Under certain circumstances you have rights under applicable data protection law in relation to personal data, namely:
- 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: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) 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; or (d) 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 if and to the extent we are relying on consent as the legal basis 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 products or services to you. We will advise you if this is the case at the time you withdraw your consent.
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 may refuse to comply with your request in these circumstances. 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.
In order to exercise one or more of your rights in respect of your personal data, you can do so contacting us at firstname.lastname@example.org. We will respond to your request(s) as soon as reasonably practicable, but in any case within the legally required period of time.
You have the right to make a complaint at any time to the Data Protection Commission, the Irish supervisory authority for data protection issues (www.dataprotection.ie). We would, however, appreciate the chance to deal with your concerns before you approach the Data Protection Commission so please contact us in the first instance at email@example.com
How to contact us and/or our Data Protection Officer
Please mark the email FAO: Data Protection Officer.
Address: The Data Protection Officer
Kora Corporation Ltd.
Swords Business Park,