Data Privacy Statement
1.0Purpose and Scope:
2.0Authority and Responsibilities:
This procedure is the responsibility of the Quality Departments and the General and/or Operations manager and/or the HR Department within the subsidiaries of Pride Mobility Products Europe and the European Union Authorized Representative.
The GDPR Officer or any designee is responsible for ensuring that this notice is placed in front of potential data subjects prior to the relevant Pride subsidiary is collecting/processing their personal data. All Employees/Staff who interact with data subjects are responsible for ensuring that this notice is drawn to the data subject’s attention and their consent to the processing of their data is secured
GDPR: General Data Protection Regulations - Regulation on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC (Data Protection Directive)
This policy applies to all the websites we operate, our use of emails and text messages for marketing purposes, and any other methods we use for collecting information. It covers what we collect and why, what we do with the information, what we won’t do with the information, and what rights you have.
Who we are
In this policy, whenever you see the words (We’, ‘Us’ or ‘Our’), it refers to any subsidiary within Pride Mobility Products Europe.
All the European Union locations within the European Union are subsidiaries within Pride Mobility Products Europe falling under Pride Mobility Products Corporation, they are all established as a medical device company distributing and assembling of Mobility Scooters, Lift Chairs and Wheelchairs (both manual and electrical). It has now moved on to include manufacturing to its scope.
All the subsidiaries within Pride Mobility Products Europe may collect and process the following data about you:
Personal information, such as name, postal address, phone number, email address, that you provide by filling in forms on Our websites (if applicable) or when you contact us via telephone and includes information provided when you:
- enquire about Our services;
- enquire about a specific product;
- request a call back
- respond to a campaign;
- submit a question to Us or provide Us with feedback.
What is Personal Information?
Under the EU’s General Data Protection Regulation:
Personal Data is defined as “any information relating to an identified or identifiable natural person ('data subject'); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person”.
How We use the information We collect
We may process your personal data for our legitimate business interests. “Legitimate Interests” means the interests of our company in conducting and managing our business and providing you with the best services and products in the most secure way. These interests include:
- To provide you with information about Our products, services, offers or technical developments that you request from Us or which we feel may interest you, where you have consented to be contacted for such purposes;
- To contact you regarding your opinions on Our solutions and services which may be used for marketing, research and analysis, where you have consented to be contacted for such purposes.
- To help Us identify you when you contact or visit Us.
- For general administration purposes.
- To help Us improve the quality of Our solutions and services
- To help Us recover debts.
- When you communicate with us for customer service or other purposes (e.g., by emails, faxes, phone calls, tweets, etc.), we retain such information and our responses to you in the records of your account.
When we process your personal data for our legitimate business interests we always ensure that we consider and balance any potential impact on you and your rights under data protection laws.
If you have any concerns about the processing described above, you have the right to object to this processing. For more information on your rights please see “Your Right” section below. Please note we will only hold this information five (5) years, unless required for Regulatory investigation, which may require an extension to this period.
Choice / opt-in and opt-out
Whenever the processing of your personal data requires your consent then you will be given the opportunity to opt-in or opt-out to having your contact details used as set out above, at the time your details are submitted.
For example, when you request product information, you can tell Us when you provide your details if you do not want to receive any other information from our subsidiaries or Our strategic partners, or you can let Us know how best to get in touch with you with information that may be of interest.
If you do not wish Us to use your data as set out above, or to pass your details on to third parties for accreditation of certification purposes, please leave the relevant boxes, situated on the form which We used to collect your data, blank/unticked.
If you no longer wish to receive email or other promotional materials from Us, you may opt-out of receiving these communications at any time by one of the following methods:
- by replying to the email with ‘unsubscribe’ in the subject line;
- by using the opt out boxes on the response form and submitting it;
- by writing to the physical address of the relevant Pride subsidiary;
- by calling the relevant Pride subsidiary
Please be aware that if you opt out of marketing communications received from us you may miss out on important information regarding contract renewals or changes to (services names may differ by subsidiary) we provide.
The range of products and services offered by each subsidiary within Pride Mobility Products Europe, Include, but is not limited to:
- New Product ranges.
- Innervation and Technology upgrades.
Sharing your information
We may share your information for any of the purpose set out above with strategic partners of service providers who perform services on Our behalf, such as marketing, Certification or Accreditation.
We may also disclose your personal information to third parties, if We are under a duty to disclose or share your personal data for legal or regulatory purposes, in relation to existing or future legal proceedings, for the prevention of fraud/loss or to protect the rights, property, safety of our company, Our customers or others.
Information is stored by Us on computers. We may transfer the information to other offices and to other reputable third-party organisations as explained above – they may be situated inside or outside the European Economic Area. We may also store information in paper files.
Each subsidiary within Pride Mobility Products Europe have security protocols and policies in place to manage and record your data privacy and preferences correctly and that your data is stored securely to protect against its loss, misuse and alteration. Documentation can be supplied on request from our GDPR Officer or designee via e-mail or can be viewed on our website privacy page.
Each subsidiary within Pride Mobility Products Europe take steps to ensure that any businesses that we share your data with will have security protocols and policies in place to manage and record your data privacy and preferences correctly and that your data is stored correctly.
Unfortunately, the transmission of data across the internet is not completely secure and whilst we do our best to try to protect the security of your information We cannot ensure or guarantee that loss, misuse or alteration of data will not occur whilst data is being transferred.
We will keep your information only for as long as We need it to provide you with the goods, services or information you have required, to administer your relationship with Us, to comply with the law, or to ensure We do not communicate with people that have asked Us not to. When We no longer need information, We will always dispose of it securely, using specialist companies to do this work for Us.
Job applicants, current and former Pride Mobility Products Ltd employees
When individuals apply to work for any subsidiary within Pride Mobility Products Europe, we will only use the information they supply to us to process their application and to monitor recruitment statistics. Where we want to disclose information to a third party, for example where we want to take up a reference or obtain a ‘disclosure’ from the Barring Services we will not do so without informing them beforehand unless the disclosure is required by law.
Personal information about unsuccessful candidates will be destroyed or deleted.
Once a person has taken up employment with any subsidiary within Pride Mobility Products Europe, we will compile a file relating to their employment. The information contained in this will be kept secure and will only be used for purposes directly relevant to that person’s employment. Once their employment has ended for whatever reason, we will retain the file in accordance with the requirements of our retention schedule and then delete it.
Under the data protection legislation, you have the right to request copies of your data, request rectification of your data, request erasure of your data, object to Us processing your data, the right to prevent your data being used for direct marketing, request us to restrict the process and where our systems allow, the right to access a copy of the information We hold about you (a subject access request).
If you wish to exercise any of these rights please contact the GDPR Officer or designee in writing or via e-mail.
For more information about your rights under the GDPR, please contact your National Competent Authority.
This document is reviewed periodically and at least annually to ensure compliance with the following prescribed criteria.
- General Data Protection Regulation
- Legislative requirements defined by National laws, where appropriate
Upon completion, the following records shall be controlled in accordance with Document Management: Records, Matrix, Retention, Digital Imaging and Destruction, EU-QAP/0400
- Data Privacy Notice, EU-GDPR/1100-1
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Compliance Officer EU AR: Dragana Milincic
Compliance Officer EU AR: Kelly Livingston