Legal and Privacy

Inivata Limited and its wholly-owned subsidiary Inivata Incorporated (“Inivata”) is committed to protecting the privacy and security of your personal information. Inivata is committed to protecting your privacy online and we appreciate that you do not want your personal information distributed indiscriminately.

Inivata has developed this Privacy Policy (“Policy”) to inform you of the data Inivata collects, what Inivata does with your information, what Inivata does to keep it secure as well as the rights and choices you have over your personal information. This Policy does not govern our collection of personal information through any website or other means, other than through www.inivata.com (“Site”). The Site is operated by or on behalf of Inivata Limited and our U.S. subsidiary, Inivata, Incorporated.

Data Protection Legislation

Throughout this document we refer to “Data Protection Legislation” which means the Data Protection Act 2018 which incorporates the General Data Protection Regulation (GDPR), the Privacy and Electronic Communications (EC Directive) Regulations 2003 and any legislation implemented in connection with the General Data Protection Regulation which is the governing legislation that regulates data protection across the EEA. This includes any replacement legislation coming into effect from time to time.

For the purposes of Data Protection Legislation, Inivata Limited is the (“data controller”). This means that Inivata is responsible for deciding how Inivata holds and uses personal information about you.  Inivata are required under data protection legislation to notify you of the information contained in this privacy policy.

Information Inivata May Collect From You

Inivata only collects information that it knows will genuinely use and in accordance with the Data Protection Legislation.  The type of information that Inivata collects on you, and you voluntarily provide to us on this website includes:

  • Information (such as your name, email address, postal address and telephone number) that you provide by completing forms on the Site to request any information about Inivata or our products or services;
  • IP address
  • Communications you send to Inivata, for example to report a problem or to submit queries, concerns or comments regarding the Site or its content;
  • Employment details if you send a CV, resumé or other details of your employment history in connection with an advertised job vacancy or a general enquiry regarding employment opportunities with Inivata.

You are under no obligation to provide any such information. However, if you choose to withhold requested information, Inivata may not be able to provide you with certain services.

When you visit the Site, Inivata may, by means of cookies and/or other similar technologies, automatically collect additional information about you – such as the type of internet browser or mobile device you use, any website from which you have come to the Site, your IP address (the unique address which identifies your computer or mobile device on the internet), your browser type, browser language, the date and time of your request, the operating system of your computer or mobile device, the name of your internet service provider or mobile carrier, the length of time spent on the Site, the pages you looked at on the Site, other websites you visited before and after visiting the Site, the type of internet browser you have, the frequency of your visits to the Site, and other relevant statistics, including the following:

  • Links. The Site may include links in a format that enables us to keep track of whether these links have been followed by IP addresses. Inivata uses this information to improve the quality of our products and design.
  • Location Information. Inivata may receive location data passed to us from location-enabled devices or that you have enabled, from your browser, or from third party services. URLs. When you visit or access the Site, Inivata automatically receives the URL of the site from which you came and the site to which you are going when you leave the Site. Additionally, advertisers receive the URL of the page you were on when you click on an ad on the Site.
  • Web Beacons. Web beacons (also known as “pixel tags” or “clear GIFs”) are 1×1 single-pixel graphics that allow us to count the number of users who have visited or accessed the Site and to recognize users by accessing our cookies. Inivata may employ web beacons to facilitate Site administration and navigation, to track the actions of users of the Site, to compile aggregate statistics about Site usage and response rates, and to provide an enhanced online experience for visitors to the Site. Inivata may also include web beacons in HTML-formatted e-mail messages that Inivata sends to determine which e-mail messages were opened.
  • Aggregate Information. Inivata may compile certain personal information and other information collected through the Site on an aggregate basis. This information may include, without limitation, the number of people who have visited the Site and other user demographics. Such aggregate information does not identify you individually.

Cookies and other technologies

When you interact with the Site, Inivata tries to make that experience simple and meaningful. When you visit the Site, a web server sends a cookie or other similar technology to your computer or mobile device (as the case may be). Cookies are small pieces of information which are issued to your computer or mobile device (as the case may be) when you visit a website and which store and sometimes track information. A number of cookies Inivata uses last only for the duration of your web session and expire when you close your browser. Other cookies are used to remember you when you return to the Site and will last for longer. The cookies and/or other similar technologies Inivata uses collect information, such as the type of internet browser or mobile device you use, any website from which you have come to the Site, your IP address and/or the operating system of your computer or mobile device. Most web and mobile device browsers automatically accept cookies but, if you prefer, you can change your browser to prevent that or to notify you each time a cookie is set. You can also learn more about cookies by visiting www.allaboutcookies.org which includes additional useful information on cookies and how to block cookies using different types of browser or mobile device. Please note, however, that by blocking or deleting cookies used on the Site, you may not be able to take full advantage of the Site.

Legal Basis for Processing Your Information

If your personal information is protected by the Data Protection Legislation, the lawful bases for processing your personal data are:

(i)                  To perform a contract Inivata has entered into, or is about to enter into,

(ii)                Where the processing of your data is necessary for our legitimate interests (or those of a third party and your interests and fundamental rights are not overridden by those interests),

(iii)               Where Inivata needs to comply with a legal or regulatory obligation, and

(iv)               Where you have given your consent to the processing of your personal data including for marketing purposes.

Inivata processes data in accordance with the legitimate interests of Inivata Limited in managing its business.  When Inivata processes your personal data for our legitimate interests or the interests of a third party, Inivata will take reasonable measures to prevent unwarranted harm to you.

Our Legitimate interests include:

  • Customer Relations
  • Marketing
  • Product Development
  • Operational Management including HR

Uses of Your Information

Inivata uses your personal information to:

  • Respond to your questions and feedback;
  • Enable us to provide you with the services and information offered through the Site and which you request;
  • Contact you by email, postal mail or telephone with information about this Site, our products or our services;
  • Audit the downloading of data from the Site;
  • Improve the layout and/or content of the pages of the Site and customise them for users;
  • Carry out research on our users’ demographics
  • For such purposes as you may authorize at the time you submit the information.
  • To evaluate you for employment; and
  • To carry out our legal and regulatory obligations

Inivata collects information on job applicants when they submit information to Inivata including the applicant’s name, address, email, and phone number along with information about their suitability for the position. Inivata will process similar information if you make your application via a recruitment agency. If you wish to amend the personal data, Inivata holds on you, please contact DPO@Inivata.com.

You can opt out of communications from Inivata about our products and services by following the unsubscribe instructions on the communications sent to you. You can also opt out of these communications at any time by contacting Inivata using the Contacting Us details at the end of this Policy.

Information Sharing

Inivata Limited, will process some of your personal data locally. However, as an international organisation, many of our business activities may also be carried out by processing or consolidating information about you in specific or centralised databases and systems located at specific secured facilities within Inivata Incorporated in the U.S.

Inivata Incorporated and those other systems and databases will only collect, receive, use, share, or otherwise process such personal data in accordance with applicable laws, this privacy policy, and our Inivata Group Data Protection Policy.

Inivata may disclose aggregate statistics about visitors to the Site in order to describe our services to prospective partners and other reputable third parties and for other lawful purposes, but these statistics will include no personally identifiable information (“PII”).

Inivata may share personal information with our subsidiaries and affiliates for the purposes for which you provided the information or as reasonably necessary for our internal administrative and business purposes.

In the event that Inivata undergoes re-organisation or all or a part of our business is sold to a third party, you agree that any personal information Inivata holds about you may be transferred to that re-organised entity or third party, whether such acquisition is by way of merger, consolidation, or purchase of all or a portion of our assets, or in connection with any bankruptcy or reorganization proceeding brought by or against us.

Inivata may disclose your personal information if required to do so by law or if Inivata believes that such action is necessary to prevent fraud or cybercrime or to protect the Site or the rights, property, or personal safety of any person pursuant to legal process, in response to a request from government officials or law enforcement authorities, or as necessary or appropriate in connection with an investigation of illegal activity.

Inivata may compile personal information and other information collected through the Site on an aggregate basis. This information may include, without limitation, the number of users who have registered for the Site, demographic information about users of the Site, and individual purchase preferences. Such aggregate information does not identify you individually. Inivata may use aggregate information and share aggregate information with third parties for any of the purposes specified in this Policy, and for any other lawful purpose.

External links

The Site may, from time to time, contain links to external sites. Inivata are not responsible for the privacy policies or the content of such sites. When you click on one of these links, you will no longer be transacting business through the Site. Third party sites maintain their own privacy policies, and Inivata does not exercise any control over any of the third-party websites.. If you visit a website that is linked to this Site, you should consult that website’s privacy policy before providing any personal information.

Security

Inivata places great importance on the security of all personal information associated with our users. Inivata have security measures in place to attempt to protect against the loss, misuse, and alteration of personal information under our control. For example, our security and privacy policies are periodically reviewed and enhanced as necessary and only authorised personnel have access to personal information.

Inivata takes security measures to protection your information including:

  • Limiting access to our buildings to those that Inivata believes are entitled to be there (by use of passes, key card access and other related technologies);
  • Implementing access controls to our information technology
  • Inivata uses appropriate procedures and technical security measures (including strict encryption, anonymisation, and archiving techniques) to safeguard your information across all our computer systems, networks, websites, mobile apps, offices and stores.
  • Never asking you for your passwords;
  • Advising you never to enter your account number or password into an email or after following a link from an email.

You should bear in mind that submission of information over the internet is never entirely secure. Inivata cannot guarantee the security of information you submit via the Site whilst it is in transit over the internet and any such submission is at your own risk.

It is advisable to close your browser when you have finished your user session to help ensure others do not access your personal information if you use a shared computer or a computer in a public place.

Storage of Your Information

Your personal information which Inivata collects is sent to and stored on secured servers located in the European Union. Such storage is necessary in order to process the information. Personal information submitted may be transferred by us to our other offices and/or to the third parties mentioned in the circumstances described above (see Information sharing), which may be situated outside the European Economic Area (EEA) and may be processed by staff operating outside the EEA. These countries may not have similar data protection laws to the EEA. Where Inivata transfers your personal information to territories outside the EEA, Inivata will take all reasonable steps to ensure that your privacy rights continue to be protected by using the appropriate safeguards and legal mechanisms that allows us to do so. By using the Site, you agree to this storing, processing, and/or transfer.

When Inivata Limited transfers personal data out of the EEA, Inivata ensures a similar degree of protection is in place in the destination country by ensuring one of the following safeguards is implemented:

(i)                  Countries that have been deemed to provide an adequate level of protection for personal data by the European Commission,

(ii)                Specific contracts approved by the European Commission which give pe-) controller the same protection it has in the EEA, including the “(EU-)controller to (Non-EU/EEA-) controller” Decision 2004/915//EC (see Article 46 GDPR).  or

(iii)               Countries possessing a suitable framework recognised by the relevant authorities or courts as providing an adequate level of protection for personal data.

How Long will Inivata Keep Your Information?

Inivata will retain a record of your personal information in order to provide you with a high-quality and consistent service. Inivata will always retain your personal information in accordance with the Data Protection Legislation, and never retain your information for longer than is necessary. Unless otherwise required by law, your data will be stored in accordance with our retention policy.  For further information on our retention policy, please send queries to DPO@Inivata.com.

Your Rights

If your personal information is protected by GDPR, you may have certain rights granted to you by GDPR.

Right to Access Your Personal Information. You have the right to access the personal information that Inivata holds about you in many circumstances, including a copy of your medical record where available by making a request (“Subject Access Request”).  If Inivata agrees that it is are obligated to provide personal information to you (or someone else on your behalf), Inivata will provide it free of charge and aim to do so within 1 Calendar month from when your identity has been confirmed. Inivata will ask for proof of identity and sufficient information about your interactions with us in order to locate your personal information.

Right to Correct Your Personal Information. If any of the personal information Inivata holds about you is inaccurate or out of date, you may ask us to correct it.

Right to Stop or Limit Processing of Your Data. You have the right to object to Inivata processing your personal information if: (1) Inivata is not entitled to use it anymore, (2) if Inivata are keeping it too long, or (3) have its processing restricted in certain circumstances.

If you would like to exercise any of these rights, please contact us as set out below. Inivata will make reasonable efforts to comply with the aforementioned requests, unless such requests are prohibited by law or there is a legitimate purpose to retain your personal information, in which case Inivata will inform you without undue delay. Inivata reserves the right to verify your identity before Inivata processes any request relating to your personal information.

More Information About Your Privacy Rights

The Information Commissioner’s Office (ICO) regulates data protection and privacy matters in the UK. The ICO makes information accessible to consumers on its website and it ensures that the registered details of all data controllers, such as Inivata are publicly available. You can access them at https://ico.org.uk/for-the-public.

You can make a complaint to the ICO at any time about the way Inivata uses your information. However, Inivata hopes that you consider raising any issue or complaint with Inivata first. Your satisfaction is extremely important to us, and Inivata will always do our very best to solve any problems you may have.

Choice and Opt-Out

Subject to your choices, Inivata may also send you direct marketing communications via email. You may unsubscribe from marketing communications by clicking the “Unsubscribe” link contained in each of Inivata’s email marketing communications.

Inivata may send you email service communications relating to the services Inivata provides (e.g. to inform you about changes to the service you requested from Inivata, revisions of Inivata’s terms and conditions, or this Policy). As such service communications are necessary for the purposes of providing you with Inivata’s services or complying with Inivata’s legal obligations, you will not be able to opt-out from receiving them.

California Privacy Rights

Shine the Light. Under California’s “Shine the Light” law, California residents who provide certain personally identifiable information in connection with obtaining products or services for personal, family, or household use are entitled to request and obtain from Inivata once per calendar year information about the information that Inivata shared with other businesses for their own direct marketing uses. If applicable, this information would include the categories of information and the names and addresses of those businesses with whom Inivata shared information for the immediately prior calendar year. To obtain this information, please contact Inivata at DPO@inivata.com with “Request for California Privacy Information” in the subject line and in the body of Your message. Inivata will provide the requested information to you at your email address in response. Please be aware that not all information sharing is covered by the “Shine the Light” requirements, and only information on covered sharing will be included in Inivata’s response. Inivata may ask for additional information to verify your identity.

Consumer Rights Notice. Under California Civil Code Section 1789.3, Inivata is required to provide California residents with the following specific consumer rights information:

  • This website is owned and operated by Inivata Limited.
  • Unless otherwise expressly stated, this website is provided without charge.
  • To file a complaint regarding this website or to receive further information regarding use of this website, please contact Inivata via email at DPO@inivata.com. You also may contact the Complaint Assistance Unit of the Division of Consumer Services of California’s Department of Consumer Affairs in writing at 400 R Street, Suite 1080, Sacramento, California 95814 or by telephone at (916) 445-1254 or (800) 952-5210.

Do Not Track Signals. Some web browsers may transmit “do not track” signals to websites with which the web browser communicates. The Site does not currently respond to “do not track” signals.

Children’s Online Privacy

Inivata does not sell or offer products or services to children. As such, this Site is designed for adult user interaction. Inivata does not intentionally collect personal information from minors, as defined in territories we operate. If you are a parent or legal guardian of a minor and believe that the minor has disclosed personal information to Inivata, please contact Inivata using the contact details provided in this Policy.

Changes to this Policy

Inivata reserves the right to change this Policy from time to time by changing it on the Site and we may provide you notice of these changes by any reasonable means, including by providing notice through the Site. By continuing to access, browse, or use the Site, you confirm your acceptance of the revised Policy. Inivata strongly recommends that you periodically visit this page of the Site to review this privacy policy.

Contacting Us

Please submit any questions, concerns or comments you have about this Policy or any requests concerning your personal data by email to DPO@inivata.com

This Policy was last updated on 2 May 2019.