Privacy Notice

Contents

• Who we are
• What Personal Data we may collect about you via this Site and what we use it for
• Cookies
• Legal basis for processing your Personal Data
• How we keep your Personal Data secure
• How long we keep your Personal Data for
• Who your Personal Data is shared with
• Location of Personal Data
• Children’s Personal Data
• Links to third party websites
• Your Personal Data Rights
• Contacting us
• In the event you have a complaint
• Review and update of Privacy Notices

1. Who we are

LIO, We, Us, Our refers to the following group of companies:

Holding company and main office (UK)
‍Oxehealth Limited t/a LIO
Registered in England and Wales, Company Registration Number 08163325
Address: Bee House, Eastern Avenue, Milton Park, Abingdon, England, OX14 4SB

Fully owned subsidiaries:
Oxehealth Inc d/b/a LIO
Registered in the United States of America, No. 3389479
Address: 9419 North Market Street, Suite 950 Wilmington, 19801 Delaware

Oxehealth AB
Registered in Sweden, Registration Number  559275-7487
Address: Nordenskiöldsgatan 11, 21119 Malmö

2. What Personal Data we may collect about you via this Site and what we use it for

We may collect Personal Data from you via this Site either through your entry of your data onto the Site or through our use of cookies (see the Cookies section below). Some sections of the Site may invite you to submit your Personal Data, e.g. to contact us with inquiries and comments. We may therefore collect and process Personal Data you provide to us such as:

• your name, organisation, job title, email address, and  phone number;
• records of your correspondence with us, if you have contacted us; and
• details of your visit to our Site and the resources that you access.

We may use Personal Data collected from you through the Site in the following ways:

• to ensure that the Site is presented to you in an effective manner and is customised to your preferences;
• to provide you with information that you have requested from us;
• to send you relevant marketing and other materials relating to us or to contact you for market research purposes.

3. Cookies

Cookies are small text files placed on your device when you visit a website. They help websites operate, remember user preferences, understand how visitors use the site, and support website security and performance.

LIO uses cookies and similar technologies on the LIO Site. Some cookies are strictly necessary for the Site to operate and do not require consent. Optional cookies, such as functionality, performance, analytics or targeting cookies, will only be used where you have given consent through our cookie management tool.

When enabled, cookies may be used to remember visitor preferences, analyse website traffic, understand how visitors use the Site, improve website performance, and measure the effectiveness of our communications. If LIO uses targeting or advertising cookies, these may be used to understand visitor interests, measure advertising effectiveness, or support relevant advertising on other websites.

You can accept, decline, or manage optional cookies at any time by using the cookie management tool available on the Site.

• Functionality cookies
  Functionality cookies are used to remember visitor information on the website, e.g. language, timezone, enhanced content.
• Performance and analytics cookies
  Performance and analytics cookies help us understand how visitors use the Site, such as which pages are visited and how visitors interact with the Site. These cookies support website improvement and performance measurement.
• Targeting cookies
  Targeting cookies may be used to identify visitors across websites, build a profile of visitor interests, measure advertising effectiveness, or show relevant content or adverts on other websites. Targeting cookies will only be used where enabled and consented to through the cookie management tool.

For further information about cookies, please visit www.aboutcookies.org.

4. Legal basis for processing your Personal Data

Our legal basis for processing your Personal Data may include:

• Your consent;
• Legitimate interest in operating and promoting our business;
• Taking steps at your request before entering into a contract;
• Performing a contract with your organisation; and
• Complying with legal or regulatory obligations.

If we collect your Personal Data with your consent, you may withdraw your consent at any time using the contact details provided in this notice.

5. How we keep your Personal Data secure

The security of all data held and processed by LIO is important to us. LIO has implemented an ISO 27001 and ISO 27701 certified information security and privacy management system which is audited to ensure that we have the appropriate technical and organisational controls in place to protect your Personal Data.

LIO maintains physical, electronic, and procedural safeguards in connection with the collection, storage, and disclosure of Personal Data. Our security and privacy procedures mean that we may request proof of identity before we disclose Personal Data to you.

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.

6. How long we keep your Personal Data for

We will retain Personal Data collected through the Site for as long as necessary to respond to your query and manage our relationship with you.

Where we have a lawful basis to send you marketing or other relevant communications, we will retain your contact details for as long as you continue to engage with us or until you object or unsubscribe.

We review marketing and website contact data at planned intervals and delete or anonymise it when it is no longer required, unless we need to retain it for legal, regulatory, contractual, audit or legitimate business purposes.

7. Who your Personal Data is shared with

LIO does not sell Personal Data to others and we will not share your Personal Data  with any third party except where:

• you have expressly consented for us to share your Personal Data with third parties;
• we are under a legal or regulatory obligation to disclose your Personal Data; or to protect the rights, property, or safety of our company, our clients or others;
• our company, or substantially all our company's assets are merged or acquired by a third party, in which case your Personal Data may form part of the transferred or merged assets;
• to provide aggregated or statistical information about use of the Site and related usage information with analytics and service providers; or
• we are using a third party service provider to provide services for, or on behalf of LIO, in such circumstances this will only be to trusted providers and subject to confidentiality arrangements.

8. Location of Personal Data

LIO is located in the United Kingdom with subsidiaries in the United States and Sweden. Depending on the scope of your interactions with LIO, your Personal Data may be stored in or accessed from multiple countries.

We may sometimes transfer to, store or host information with third party service providers based outside the UK, the European Economic Area (EEA), and/or the US including countries where the law may provide less protection for personal information.

When we transfer Personal Data to another country, we will do so in accordance with applicable data protection laws. Where required, we will use appropriate safeguards, such as adequacy regulations, standard contractual clauses, the UK International Data Transfer Agreement or Addendum, or another lawful transfer mechanism. We will also carry out a transfer risk assessment where required.

9. Children’s Personal Data

This Site is not directed to children under the age of 18, nor is data knowingly collected from children. If you are under 18, please do not use or provide any Personal Data on the Site. If we learn that we have collected or received Personal Data from a child without a parent’s or legal guardian’s consent, we will take steps to stop collecting that data and to delete it. If you believe we have mistakenly or unintentionally collected Personal Data of a minor without appropriate consent please contact us using the contact information below.

10. Links to third party websites

The Site may contain links to other websites of interest. However, once you have used these links to leave the Site, you should note that we do not have any control over that other website. Therefore, we cannot be responsible for the protection and privacy of any Personal Data which you provide while visiting such sites, and such sites are not governed by this Privacy Notice. You should exercise caution and look at the privacy notice applicable to the website in question.

11. Your Personal Data Rights

You may have certain legal rights relating to your Personal Data, subject to local data protection laws. Depending on the applicable laws these rights may include the right to:

• Access the personal data we hold about you.
• Learn more about how we process your personal data.
• Correct any inaccurate or incomplete personal data we hold about you.
• Request the deletion or erasure of your personal data where applicable.
• Restrict or object to the processing of your personal data including for direct marketing purposes.
• Obtain a copy of your personal data in a portable format or request that we transfer it to another provider.
• Opt out of certain types of processing, including the sale of personal data (note: we do not sell personal data) or sharing of your personal data for targeted advertising, where applicable under local laws.
• Not be subject to decisions based solely on automated processing, including profiling, which produce a legal or similarly significant effect on you.

To exercise any of these rights, please contact us using the contact details below. We will respond to your request as required by applicable law, typically within one month. In some cases, we may need additional time due to the complexity or volume of requests, in which case we will notify you.

Where permitted by law, we may require proof of your identity before fulfilling your request. In some cases, we may decline a request if it is manifestly unfounded, excessive, or otherwise not required by applicable law, but we will provide an explanation in such instances.

Direct Marketing
‍You have the right to object to the use of your personal information for direct marketing at any time. You do not need to provide a specific reason for such objection, and we will honour your request promptly.

Non Discrimination
‍LIO respects and upholds applicable data protection rights and ensures that no unfair treatment or discrimination occurs as a result of exercising those rights.

Automated Decision Making
We do not currently engage in decision-making based solely on automated processing, including profiling, that produces legal or similarly significant effects.

12. Contacting us

LIO is registered with the Information Commissioner's Office (ICO) in the UK and has appointed a Data Protection Officer (DPO) to oversee compliance with all data protection laws in the jurisdictions in which we operate. You can find details of our registration and the data protection officer on the ICO’s register of fee payers.

To exercise your rights regarding your Personal Data, make a complaint as described in section 13, or ask a question about this Privacy Notice or our privacy practices, please email us at privacy@oxehealth.com, call us at +44-1865-900599, or write to us at:

Oxehealth Data Protection Officer
Bee House
140 Eastern Avenue
Milton Park
Oxfordshire, OX14 4SB
United Kingdom

When you contact us please indicate what country and state you reside in so we can address your inquiry appropriately.

13. In the event you have a complaint

If you have a complaint or concern about how we process your Personal Data, or about how we have handled a request to exercise your Personal Data rights, please contact Oxehealth’s Data Protection Officer using the contact details above.

We will acknowledge receipt of your complaint within 30 days. We will take appropriate steps to investigate the complaint, keep you informed where appropriate, and provide an outcome without undue delay.

If you remain dissatisfied, you have the right to complain to the relevant supervisory authority. You may contact them as follows:

United Kingdom
‍Information Commissioner’s Office
Tel: 0303 123 1113
Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF
Live chat: https://ico.org.uk/global/contact-us/contact-us-public/public-advice/
‍Website: www.ico.org.uk 

Sweden
‍IMY - Swedish Authority for Privacy Protection
Integritetsskydd Myndigheten, Box 8114, 104 20 Stockholm, Sweden 
Tel: +46 (0)8 657 61 00 (Monday to Friday 9am to 12pm)
Email: imy@imy.se 
Website: www.imy.se

United States
If you are based in the United States, you may contact the following organisations:

• Federal Trade Commission (FTC): File a complaint via https://reportfraud.ftc.gov
• Your State’s Attorney General: A directory of state Attorneys General is available at https://www.naag.org
• California residents: For complaints under the California Consumer Privacy Act (CCPA), you may contact the California Privacy Protection Agency (CPPA) via their website at www.ccpa.ca.gov 

14. Review and update of Privacy Notices

LIO will review and update our Privacy Notices from time to time to reflect changes in our practices, technologies, legal requirements and other factors. If we do, we will update the ‘effective date’ at the top of this page. We encourage you to periodically review this Privacy Notice to stay informed about our collection, processing and sharing of your Personal Data.