Privacy

StrongRoom AI is committed to providing quality services to you and this policy outlines our ongoing obligations to you in respect of how we manage your Personal Information.

STRONGROOM AI UK PRIVACY POLICY

1. ABOUT THIS POLICY

1.1 This Privacy Policy (Policy) describes how Strong Room Technology Pty Ltd (StrongRoom AI, we, our or us), collects, discloses, handles and protects the privacy of personal information. This Policy applies to personal information in relation to which StrongRoom AI is the controller and is therefore responsible.

1.2 StrongRoom AI provides technology to its customers (including pharmacies, aged care facilities and hospitals) that use personal (including sensitive health) information to streamline our customers’ services, including managing patient medication efficiently and transparently.

1.3 We are committed to protecting privacy and understand the importance of protecting personal information. This Policy outlines the types of personal information that we usually collect, the purposes for which we collect it, to whom we disclose it, how we hold and keep it secure, and your rights in relation to your personal information, including how to complain and how we deal with complaints.

1.4 We handle personal information in accordance with this Policy and applicable legislation, including the Data Protection Act 2018 and UK GDPR.

1.5 In this Policy, personal information means any information that relates to an identified or identifiable individual. It does not include information that is de-identified.

1.6 We may change this Privacy Policy from time to time by publishing changes on our website at www.strongroom.ai/en-gb/ (Site).

2. TYPES OF PERSONAL INFORMATION WE COLLECT

2.1 StrongRoom AI may collect personal information from and about users of our Site and services (including our customers’ representatives, employees and contractors), as well as individuals with whom we otherwise interact. The types of personal information we collect depends on the dealings we have with an individual. For example:

(a) For users of our Site:
(i) identifiers (eg name, alias, email address, phone number, company name, unique personal identifier, internet protocol address, referral information, other similar identifiers);
(ii) commercial information (eg company name, position, business contact details, other similar information);
(iii) internet or other electronic network activity information (eg internet protocol address, browser type, cookies used for identification, and information regarding a consumer’s interaction with the Site);

(b) For customers and our customers representatives (including employees and contractors):
(i) your name, employer, position and business contact details;
(ii) if you elect to enable the functionality, biometric data (ie facial & fingerprints) for use of our software; and
(iii) your preferences;
(iv) technical data (e.g. includes internet protocol address, login data, browser type and version, time zone setting, browser plug-in types and versions, and operating system);
(v) usage data (e.g. information about how and when you use our Site, services and the Site); and
(vi) location data (e.g. including your device and/or browser location, your location, your employment locations and any additional location data stored within your Google account if you link this to the Site).

(c) For job applicants and contractors:
(i) your name, date of birth and contact details (eg address, email address and phone number);
(ii) your employment and academic history and professional references;
(iii) your bank account details; and
(iv) background checks.

2.2 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 information but is not considered personal information in law as this data will not directly or indirectly reveal your identity. For example, we may aggregate your data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect aggregated data with your personal information so that it can directly or indirectly identify you, we treat the combined data as personal information which will be used in accordance with this Policy.

3. WAYS WE COLLECT YOUR PERSONAL INFORMATION

3.1 We may collect personal information from or about you in different ways depending on your dealings with us, including:

(a) from you directly when you interact with us, e.g. from our discussions with you, when you complete a form, from your emails or from your interaction with our Site;

(b) through third parties with whom we interact in order to provide our services;

(d) from publicly available sources, including social media.

3.2 If you apply for a job or contract position with us, we may also collect personal information about you from third parties and publicly available sources, including:

(a) recruiters;

(b) government departments to verify your entitlement to work in the United Kingdom or other relevant location;

(d) academic institutions;

(e) your current or previous employers; or

(f) your referees.

4. LEGAL BASIS FOR COLLECTING AND USING YOUR PERSONAL INFORMATION

4.1 We will only collect and use your personal information as a controller when the law allows us to and we are required by law to have a lawful basis for doing so. Specifically, at least one of the following lawful bases will apply:

(a) Performance of Contract

4.2 We will use your personal information where we need to in order to perform the contract we are about to enter into or have entered into with you.

(a) Legitimate Interests

4.3 We will use your personal information 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.

4.4 “Legitimate Interest” means our interest in conducting and managing our business to enable us to give you the best service and the most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal information for our legitimate interests. We do not use your personal information 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).

(a) Legal Obligations

4.5 We will use your personal information where it is necessary for compliance with a legal obligation in the UK or EU that we are subject to.

(a) Consent

4.6 Generally, we will not rely on consent as a legal basis for processing your personal information as a controller, although we will obtain your consent before processing any special category data (for example, data relating to race, ethnicity, political, religious or philosophical beliefs, trade union membership, health data and/or sexual orientation). You have the right to withdraw consent at any time by contacting us.

Special Category Personal Data

4.7 Where we use any “special category personal data”*, in addition to one of the legal bases noted above, we also note that we have a further legal basis for such use. This will most commonly be one of the following:

(a) Explicit Consent: Where you have given your explicit consent to the processing;

(b) Vital Interests: The processing is necessary to protect your vital interests or those of another natural person where you are physically or legally incapable of giving consent;

(c) Made public by the data subject: Processing relates to special category personal information that you have made public;

(d) Legal claims and judicial acts: The processing is necessary for the establishment, exercise or defence of legal claims; or

(e) Substantial public interest: The processing is necessary for reasons of substantial public interest (e.g. regulatory requirements, preventing or detecting unlawful acts). *When we refer to “special category personal data”, we mean personal information that reveals racial or ethnic origin, political opinions, religious beliefs, philosophical beliefs or trade union membership, genetic data, biometric data (where used for identification purposes), data concerning health, sex life or sexual orientation of an individual.

5. PURPOSES FOR WHICH WE COLLECT AND USE PERSONAL INFORMATION

5.1 We collect and use your personal information for the following purposes:

(a) to provide and update our services (performance of a contract with you);

(b) to manage and conduct our business (performance of a contract with you, necessary for our legitimate interests (to study how users use our services, to develop them, to grow our business and to inform our business strategy));

(c) to offer or promote our products and services (necessary for our legitimate interests (to study how users use our services, to develop them, to grow our business and to inform our business strategy);

(d) to obtain feedback (necessary for our legitimate interests (to study how users use our services, to develop them, to grow our business and to inform our business strategy));

(e) to help us manage, develop and enhance our services, including our websites and applications (necessary for our legitimate interests (to define types of users for our services, to keep our Site updated and relevant, to develop our business and to inform our business strategy));

(f) to consider your suitability for employment (necessary for our legitimate interests (to grow and develop our business by recruiting new staff)); and

(g) to comply with our legal obligations, resolve any disputes, and enforce our agreements and rights with third parties.

5.2 With our customer’s consent, we may also de-identify personal information that we hold for our business purposes, including:

(a) conducting data analytics activities about our services;

(b) generating insights and benchmarks for our customers;

(d) marketing and improvement of our services; and

(e) training of our algorithms and our artificial intelligence models.

6. IF YOU FAIL TO PROVIDE YOUR PERSONAL INFORMATION

6.1 Where we need to use personal information by law, or under the terms of a contract we have with you, and you fail to provide that information 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 access to the Site). In this case, we may have to cancel a service or account you have with us, but we will notify you if this is the case at the time.

7. DIRECT MARKETING

7.1 We may use your personal information to identify a product or service that you may be interested in. We may, with your consent, use the personal information we have collected about you to contact you from time to time whether by email to tell you about new products or services and special offers that we believe may be of interest to you.

7.2 You can withdraw your consent to receiving direct marketing communications from us at any time by unsubscribing from the mailing list by contacting us using the details set out in this Policy.

8. CHANGE OF PURPOSE

8.1 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 you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.

8.2 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 note that we may process your personal information without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

9. DISCLOSING YOUR PERSONAL INFORMATION

9.1 We do not sell personal information that we hold to third parties, but in the course of providing our products and services, we may disclose your personal information as follows:

(a) to third parties in order to provide our services (including via third party partnerships);

(b) our affiliate and subsidiary companies under common ownership, management or control with us;

(d) anyone to whom part of or all of our assets or businesses are transferred or sold;

(e) our professional advisers, including lawyers, accountants and auditors; and

(f) government agencies, regulatory bodies, law enforcement agencies or other similar entities.

9.2 We require all third parties to respect the security of your personal information and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal information for their own purposes and only permit them to process your personal information for specified purposes and in accordance with our instructions.

10. SECURITY AND STORAGE

10.1 We store your personal information electronically. Electronic information is stored by our third party storage providers.

10.2 We take reasonable and appropriate steps (including organisational and technological measures) to protect your personal information from misuse, interference and loss, as well as from unauthorised access, modification or disclosure.

11. COOKIES

11.1 Please see our Cookie Policy for further details on our use of 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 the Site may become inaccessible or not function properly.

12. ACCESS TO AND CORRECTION OF YOUR INFORMATION

12.1 Under certain circumstances, you have rights under data protection laws in relation to your personal information. We have summarised these below. For more information, please see the ICO website here: https://ico.org.uk/your-data-matters/.

(a) Request access to your personal information (commonly known as a “data subject access request”). This enables you to receive a copy of the personal information we hold about you and to check that we are lawfully processing it.

(b) Request correction of your personal information. This enables you to have any incomplete or inaccurate information we hold about you corrected, though we may need to verify the accuracy of the new information you provide to us.

(c) Request erasure of your personal information. This enables you to ask us to delete or remove personal information 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 information 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 information 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.

(d) Object to processing of your personal information. You can object to processing of your personal information 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 information 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.

(e) Request restriction of processing your personal information. This enables you to ask us to suspend the processing of your personal information 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.

(f) Request transfer of your personal information. We will provide to you, or a third party you have chosen, your personal information 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.

(g) Right to withdraw consent. You can withdraw consent at any time where we are relying on consent to process your personal information. 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.

12.2 If you wish to exercise any of the rights set out above, please contact us. 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.

12.3 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 is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances.

12.4 We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal information (or to exercise any of your other rights). This is a security measure to ensure that personal information 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.

13. INTERNATIONAL TRANSFERS
13.1 We may transfer your personal information outside of the UK, for example where our external third-party suppliers are located. Whenever we transfer your personal information out of the UK, we ensure a similar degree of protection is afforded to it by:

(a) ensuring we will only transfer your personal information to countries that have been deemed to provide an adequate level of protection for personal information; or
(b) putting in place specific contracts approved for use in the UK which give personal information the same protection it has in the UK.
13.2 Please contact us if you want further information on the specific mechanism used by us when transferring your personal information out of the UK.

14. DATA RETENTION

14.1 We will only retain your personal information 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. Please note that we may retain your personal information 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.

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

15. COMPLAINTS

15.1 You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK regulator for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.

15.2 You can make a complaint in writing to us using the details set out in this Policy. We will respond to you within a reasonable period of time to acknowledge your complaint and inform you of the next steps we will take in dealing with your complaint.

16. CONTACT US
If you have a question or comment regarding this Policy or wish to make a complaint or exercise your privacy rights, please address your correspondence to our Human Resources Manager at office@strongroom.ai.