Privacy Notice

Effective from August 2024 
This privacy notice sets out how Pando collects, uses and protects your personal data, through your use of this website, our products and services or as an employee, including any data you may provide or participant in a research study.  This privacy notice is provided in a layered format so you can click through to the specific areas set out below. 

1. Who are we?
2. The types of data we collect about you
3. How is your personal data collected 
4. How we use your personal data
5. Disclosures of your personal data
6. International Transfers
7. Data Security
8. Data Retention
9. Your legal rights
10. Contact details and complaints
11. Changes to this Privacy Notice 
12. Third party links

1 – Who are we?

We are Beacon Medical Systems Limited, a company incorporated in England and Wales with registered number 14638585 and with a registered office at 5 New Street Square, London EC4A 3TW.  We trade under the name of Pando, Pando Messenger and Pando Insights, throughout this document we will refer to Beacon Medical Systems Limited as Pando and all references to “Pando”, “we”, “us” or “our” will be interpreted as referring to Beacon Medical Systems Limited.

We have appointed a data protection officer (DPO) who is responsible for overseeing questions in relation to this privacy notice.  If you have any questions about this privacy notice, including any requests to exercise your legal rights or duties (section 9) please contact the DPO using the information set out in the contact details and complaints section (section 10). 

This notice describes how we collect, store, disclose, transfer, protect and otherwise process your personal data and for what purposes. It also contains other important information, such as the lawful bases by which we process your personal data, how long we might retain your personal data, and the rights you have in relation to personal data we hold about you. It applies to the full range of services offered by Pando and the use of this website and the Pando Messaging Service (The Service) via the range of Pando Apps.

2 – Types of data we may collect about you.

We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:

• Identity Data includes first name, last name, any previous names, username or similar identifier, title, facility/affiliation, bio, notes and photo , special interests, specialty/ care setting date of birth, gender, job title, grade, GMC number, preferences
• Contact Data includes billing address, delivery address, email address and telephone numbers.
• Financial Data includes bank account and payment card details.
• Transaction Data includes details about payments to and from you and other details of products and services you have purchased from us.
• Technical Data includes 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, device ID and other technology on the devices you use to access this website. 
• Profile Data includes your username and password, purchases or orders made by you, your interests, preferences, feedback and survey responses. 
• Usage Data includes information about how you interact with and use our website, products and services. 
• Marketing and Communications Data includes 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 which is not personal data as it does not directly (or indirectly) reveal your identity. For example, we may aggregate individuals’ Usage Data to calculate the percentage of users accessing a specific website feature in order to analyse general trends in how users are interacting with our website to help improve the website and our service offering.

3 – How is your personal data collected

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

• Your interactions with us. You may give us your personal data by filling in online forms, signing up for our services 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;
  • register for our services on our website;
  • subscribe to our service or publications; 
  • request marketing to be sent to you;
  • enter a competition, promotion, 
  • complete a market research survey; or
  • give us feedback or contact us. 
• Automated technologies or interactions. As you interact with our website or App, we will automatically collect Technical Data about your equipment, browsing actions, App usage and patterns. We collect this personal data by using cookies, and other similar technologies. Please see our cookie policy for further details.
• Third parties or publicly available sources. We will receive personal data about you from various third parties and public sources as set out below: 
• Technical Data is collected from the following parties:
  • analytics providers such as Google based outside the UK; 
  • search information providers Google based outside the UK.
• Contact and Transaction Data is collected from providers of technical, payment and delivery services such as Stripe, AWS based inside the UK. Please note we DO NOT store or process any payment card details, this data is processed by our payment card services provider.
• Identity and Contact Data is collected from publicly available sources such as Companies House and the Electoral Register based inside the UK.

4 – How we use your personal data

The law requires us to have a legal basis for collecting and using your personal data. We rely on one or more of the following legal bases:

Performance of a contract with you: Where we need to perform the contract we are about to enter into or have entered into with you.

Legitimate interests: We may use your personal data where it is necessary to conduct our business and pursue our legitimate interests, for example to prevent fraud and enable us to give you the best and most secure customer experience. We make sure we consider and balance any potential impact on you and your rights (both positive and negative) before we process your personal data for our legitimate interests. We do not use your personal data 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).

Legal obligation: We may use your personal data where it is necessary for compliance with a legal obligation that we are subject to. We will identify the relevant legal obligation when we rely on this legal basis.

Consent: We rely on consent only where we have obtained your active agreement to use your personal data for a specified purpose, for example if you subscribe to an email newsletter.

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 the various categories of 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.

Pando acts as a data processor when processing patient data which means we only process patient data according to the instructions of the data controller – the organisations providing care, such as GP practice, hospital, hospice, pharmacy or care home.  They maintain the overall responsibility for patient data and the circumstances of any processing.  As such, Pando is acting under the instructions of the user’s organisation (the data controller they determine the lawful basis for processing.  In most cases the organisation relies on:

• Article 6 (1) (e) of the GDPR, – processing personal information that is necessary to provide a service which is in the public interest
• Article 9 (2) (h) of the GDPR – permits processing of health information which is necessary for the provision of health treatment.

The national data opt-out is a service that allows patients to opt out of their confidential patient information being used for research and planning. As a processor it is not Pando’s responsibility to process the opt out as that is the job of the data controller. However, you can find out more about opting out here.

When contacting Pando by telephone, email or live chat we retain details of your phone number, IP address, date, time and duration of the contact, we do not record the audio of the call itself but may make notes to help us answer your query.  The data is held on our CRM system.

When contacting Pando via social media either by direct message or private message, the data will be processed by our third party provider Slack and will also remain in the public domain by Twitter, Instagram, Linkedin, Facebook, Meta etc. We suggest you familiarise yourself with the privacy notice relevant to these platforms.

When contacting Pando via live chat the data provided will be processed via Pando third party CRM system provider, currently Intercom. 

Direct Marketing

During the process on our website when your personal data is collected, you will be asked to indicate your preferences for receiving direct marketing communications from Pando via email, SMS, telephone, post or via the Pando app.

We may also analyse your Identity, Contact, Technical, Usage and Profile Data to form a view which products, services and offers may be of interest to you so that we can then send you relevant marketing communications. 

Third-party marketing 

We will get your express consent before we share your personal data with any third party for their own direct marketing purposes. 

Opting out of marketing 

You can ask to stop sending you marketing communications at any time by logging into the website and checking or unchecking relevant boxes to adjust your marketing preferences OR by following the opt-out links within any marketing communication sent to you. 

If you opt out of receiving marketing communications, you will still receive service-related communications that are essential for administrative or customer service purposes.

Cookies

For more information about the cookies we use and how to change your cookie preferences, please see this link.

5 – Disclosure of your personal data

Pando processes personal data in the capacity of both a data controller and a data processor.  When we are a processor of personal data, we are doing so purely on the instructions of another organisation or company as they are the controller.For the purposes of Pando Messenger, we are the developers of the Pando App and operate the Pando Messaging Service. In this context, the medical establishment – eg, a Trust or a GP is the controller of the patient data (typically for direct care) that is entered into the Pando App and Pando is a controller of the users’ data. Where a Trust or GP for eg is the controller, to find out more about how your data is protected by them, or to exercise your rights under data protection law, you should contact them directly. We may share your personal data where necessary with external third parties who provide services to us, for . eg cloud service providers and technology services, or clinical research organisations. We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We have Data Processing Agreements in place with these third party providers and we do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.We do not sell your data to anyone and only share it with our contracted processors.

6 – International Transfers

We use International Data Transfer Agreements which give the transferred personal data the same protection as it has in the UK.We may transfer your personal data to service providers that carry out certain functions on our behalf. This may involve transferring personal data outside the UK to countries which have laws that do not provide the same level of data protection as the UK law.Whenever we transfer your personal data out of the UK to service providers, we ensure a similar degree of protection is afforded to it by ensuring that the following safeguards are in place: We will only transfer your personal data to countries that have been deemed by the UK to provide an adequate level of protection for personal data, orWe use International Data Transfer Agreements which give the transferred personal data the same protection as it has in the UK.

7 – Data Security

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, all data is password protected, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know, the data is backed up securely and encrypted both in transit and at rest when appropriate. They will only process your personal data on our instructions and they are subject to a duty of confidentiality. We have relevant data protection and security training in place with Data Privacy by design and default being an integral part of our development processes.  Pando submits DSP Toolkit annually to the level of Standards Exceeded and maintains Cyber Essentials Plus certification.

8 – Data Retention

Unless set out specifically in the table above at 4 we will only retain your personal 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. 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.

By law we have to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for six years after they cease being customers for tax purposes.

In some circumstances you can ask us to delete your data: see 9 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.

9 – Your legal rights

You have a number of rights under data protection laws in relation to your personal data. 

You have the right to:

• Request access to your personal data (commonly known as a “subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
• Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
• Request erasure of your personal data in certain circumstances. This enables you to ask us to delete or remove personal data 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 data 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 data 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.
• Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) as the legal basis for that particular use of your data (including carrying out profiling based on our legitimate interests). In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your right to object.You also have the absolute right to object any time to the processing of your personal data for direct marketing purposes (see OPTING OUT OF MARKETING in 4 for details of how to object to receiving direct marketing communications). 
• Automated decision making – you have the right not to be subjected to automated decision making and profiling in certain circumstances.  We do not use your personal data in any automated processes to make decisions about you.
• Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data 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.
• Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in one of the following scenarios:
  • If you want us to establish the data’s accuracy;
  • Where our use of the data is unlawful but you do not want us to erase it;
  • 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
  • You have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.If you wish to exercise any of the rights set out above, please contact us see Contact details (10). 
• No fee usually requiredYou 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.
• What we may need from youWe may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data 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.
• Time limit to respondWe 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. 

10 – Contact details and complaints

If you have any questions about this privacy notice or about the use of your personal data or you want to exercise your privacy rights, please contact our Data Protection Officer (DPO) by;

– emailing; dpo@hellopando.com or   

– write to us at 5 New Street Square, London EC4A 3TW

If you are a resident of the EU, please contact our representative at Information Governance Europe Ltd who has been appointed to act as our EU Representative. All requests, questions and comments should either be emailed to our representative at eurep@itgovernance.eu.

Postal address:

IT Governance Europe Ltd
The Mill,Newtown Link Rd
Stagreenan, Drogheda
Co. Louth, A92 CD3D
Ireland

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.

11 – Changes to the privacy notice and your duty to inform us of changes

We keep our privacy notice under regular review. This version was last updated in June 2024. 

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, for example a new address or email address.

12 – Third party links

This website 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 website, we encourage you to read the privacy notice of every website you visit.