Privacy policy

Welcome to Cushla Health Systems’ (“Cushla”) privacy policy.

Cushla respects your privacy and is committed to protecting your Personal Data. This privacy policy will inform you as to how we look after your Personal Data when you visit our website ( www.cushla.io) and/or our mobile application (together referred to here as ‘Site’), regardless of where you visit it from, and tell you about your privacy rights and how the law protects you.

This privacy policy aims to give you information on how Cushla collects and processes: your Sensitive Person Data and your Personal Data through your use of the Site, including any data you may provide through the Site when you register, share data, respond to a survey, sign up to our newsletter, or purchase a product or service.

This Site is not intended for use by children. A parent, or holder of parental responsibility over the child may use this Site for and on behalf of their child and these terms apply to such use.

It is important that you read this privacy policy together with any other privacy policy or fair processing policy we may provide on specific occasions when we are collecting or processing Personal Data about you so that you are fully aware of how and why we are using your data. This privacy policy supplements other notices and privacy policies and is not intended to override them.

Cushla Health Systems is the controller and responsible for your Personal Data (collectively referred to as “Cushla”, “we”, ”us” or “our” in this privacy policy).

We have appointed a data protection officer (DPO) who is responsible for overseeing questions in relation to this privacy policy. If you have any questions about this privacy policy, including any requests to exercise your legal rights, please contact the DPO using the details set out below:

Full name of legal entity: Cushla Health Systems

Email address: ipmanager@cushla.io

Postal address: 31 Boroimhe Hazel, Swords, Co Dublin, Ireland

You have the right to make a complaint at any time to the Data Protection Commission (https://www.dataprotection.ie/) or other national regulator for data protection issues. We would, however, appreciate the chance to deal with your concerns before you approach the regulator so please contact us in the first instance.

We keep our privacy policy under regular review. This version was last updated on 5 th 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.

This Site may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our Site, we encourage you to read the privacy policy of every website you visit.

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 irreversibly removed (anonymous data). “Sensitive Personal Data” means special categories of data including data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, genetic data, biometric, data concerning health or data concerning a natural person’s sex life or sexual orientation.

Sensitive Personal Data

Strictly in accordance with Regulation (EU) 2016/679 General Data Protection Regulation and national legislation of no lesser standard, we will only collect, use, store and process your Sensitive Personal Data with your consent and strictly to perform the contract we are about to enter into or have entered into with you.

Personal Data

In compliance with Health Information and Quality Authority standards for health data, Regulation (EU) 2016/679 General Data Protection Regulation and national legislation of no lesser standard, we may collect, use, store and transfer different kinds of Personal Data about you, which we have grouped together as follows:

• identity data (including first name, maiden name, last name, username or similar identifier, marital status, title, date of birth and gender)
• contact data (including billing address, delivery address, email address and telephone numbers)
• financial data (including bank account and payment card details)
• transaction data (including details about payments to and from you and other details of products and services you have purchased from us)
• technical data (including 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 Site)
• profile data (including your username and password, purchases or orders made by you, your interests, preferences, feedback and survey responses)
• usage data (including information about how you use our Site, products and services)
• marketing and communications data (including your preferences in receiving marketing from us and our third parties and your communication preferences)

We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. 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. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific Site feature.

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.

Where we need to collect Personal Data by law, or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with goods or services). In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.

How is your Personal Data collected?

We use different methods to collect data from and about you including through:

• direct interactions, where you may give us your Personal Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes Personal Data you provide when you: apply for our products or services; create an account on our Site; subscribe to our service or publications; request marketing to be sent to you; enter a survey; or give us feedback or contact us.
• automated technologies or interactions as you interact with our Site, where 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. We may also receive Technical Data about you if you visit other websites employing our cookies. Please see our cookie policy below for further details.
• third parties or publicly available sources, where we will receive Personal Data about you from various third parties and public sources. This data may include: technical data from analytics providers; advertising networks and search information providers; contact, financial and transaction data from providers of technical, payment and delivery services; identity and contact data from data brokers or aggregators; identity and contact data from publicly available sources.

How we use your Personal Data

We will use your Personal Data only when the law otherwise allows us to. Most commonly, we will use your Personal Data 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 obligation.

We will get your consent before sending third party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us.

Purposes for which we will use your Personal Data

We have set out below, in a 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.

Note that we may process your Personal Data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your Personal Data where more than one ground has been set out in the table below.

Marketing

We strive to provide you with choices regarding certain Personal Data uses, particularly around marketing and advertising. We may use your Identity, Contact, Technical, Usage and Profile Data 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 for you (we call this marketing).

You will receive marketing communications from us if you have requested information from us. We will get your express opt-in consent before we share your Personal Data with any third party for marketing purposes.

You can ask us or third parties to stop sending you marketing messages at any time by logging into the Site and checking or unchecking relevant boxes to adjust your marketing preferences or by contacting us at any time.

Cookies

You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this Site may become inaccessible or not function properly. For more information about the cookies we use, please see Cookie policy.

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.

International transfers

Whenever we transfer your Personal Data we ensure a similar degree of protection is afforded to it by ensuring at least that we only transfer your Personal Data to countries that have been deemed to provide an adequate level of protection for Personal Data under Regulation (EU) 2016/679 General Data Protection Regulation; and use certain service providers, and specific contracts which give Personal Data the same protection it has in the EU.

Please contact us if you want further information on the specific mechanism used by us when transferring your Personal Data.

Data security

We have put in place appropriate security measures to prevent your Sensitive Personal Data and 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.

Data retention

We will only retain your 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. On termination of your contract with us, for whatever reason, we will retain your data for a period of 30 days. At the end of the 30 day period your data will be deleted.

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 you can ask us to delete your data: see your legal rights below for further information.

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.

Your legal rights

You have rights under data protection laws in relation to your Sensitive Personal Data and Personal Data including the right to: request access to, correction of and erasure of your Sensitive Personal Data and Personal Data; the right to object to the processing of your Sensitive Personal Data and Personal Data; the right to request restriction of processing your Sensitive Personal Data and Personal Data; the right to request transfer of your Sensitive Personal Data and Personal Data; and the right to withdraw consent. If you wish to exercise any of such rights, please contact us.

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.

On termination of your contract with us, subject to your request in writing and with reasonable notice, we will use all reasonable endeavours to transfer the Sensitive Personal Data and Personal Data that you have entered directly on to the Site. The format of any such data so transferred shall be at our sole discretion.