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ExR Solutions Limited

Privacy Policy


Last updated: June 2024


EXR Solutions Limited ("we", "our", "us" or "ExR") is committed to protecting and respecting your privacy. This policy sets out the basis on which any information from which an individual can be identified ("personal data") and which we collect or otherwise obtain will be processed by ExR. Please read the following policy carefully to understand our views and practices regarding your personal data and how we will treat it.

Whilst we endeavour to give information regarding our data protection practices directly to all individuals whose personal data we hold, we do from time to time acquire personal data in an indirect or incidental way. Therefore, one of the purposes of the policy is to provide privacy information to such individuals with whom we do not have a direct relationship.

We may hold your personal data because:

  • we obtain it directly from you, as described further in Section 1 of this policy;

  • we obtained it from a third party, as described further in Section 2 of this policy;

  • of our use of cookies on our website, [exr.education] (the "Website"), as described further in Section 9 of this policy; or

  • it is publicly available.

    • For the purpose of the Data Protection Legislation (being: (i) the United Kingdom General Data Protection Regulation; (ii) the Data Protection Act 2018; and (iii) all other legislation relating to the processing of personal data and/or privacy that is applicable to ExR), the data controller of any personal data that we hold is ExR Solutions Limited of 1 Pickle Mews, London, SW9 0FJ, United Kingdom.

    By visiting and/or accessing services, via our headset app "ExR"/"ExR Education" (the "App") or on our Website, or by otherwise engaging with ExR, you acknowledge that we may collect, use and transfer your personal data as set out in this privacy policy.


    1. PERSONAL DATA THAT WE COLLECT FROM YOU

    When you visit or otherwise use the App or the Website or any services that we provide, we may collect and process the following personal data about you:

  • personal data that you provide when registering creating an account on the Website, including your name, email address and organisation, healthcare trust or company; and

  • details of your visit to the Website or the App, including traffic data, location data, weblogs and other communication data, as well as information regarding the resources and sections of the Website and/or App that you access.

    • We may also collect personal data about you when you interact or otherwise engage with ExR via any of the following means:

  • when you contact us by email; and

  • when electing to receive (or not receive) marketing communications from ExR, details of your communication preferences will be retained by us.

    • We do not collect any special category data about you.


    2. INFORMATION THAT WE RECEIVE FROM OTHER SOURCES

    From time to time, we may receive personal data from third parties. If you are engaged by one of our suppliers or an organisation which otherwise has a business relationship with ExR, we may receive details such as your name and contact details.

    As noted above in Section 1 of this policy with respect to personal data that we collect directly from you, the personal data that we receive from third-party sources will not include special category data.


    3. USE OF YOUR PERSONAL DATA

    We may use your personal data to:

  • provide you with services that you have requested we perform, or otherwise carry out our obligations arising from any contract(s) you have entered into with ExR;

  • carry out our internal business affairs;

  • send business or marketing communications which we think may be of interest to you or which you have otherwise indicated a preference to receive (each of which shall contain a mechanism via which you may unsubscribe from receiving any such further communications); and

  • ensure that the content of the Website and the App is presented in the most effective manner for you and for your device, and to perform statistical analysis in respect of your use of the Website and/or the App.

    • We primarily process your personal data as described above for the purpose of pursuing our legitimate business interests. In some instances, we may rely on having obtained your express consent to the relevant processing – where this is the case, you will be made aware and will be provided with the opportunity to withdraw your consent to the processing, should you wish to do so. We may also process your personal data where this is necessary for the performance of a contract to which ExR is a party.


    4. SHARING YOUR PERSONAL DATA

    Where it is necessary to provide our services to you or for our internal business purposes, we may share your personal data with certain third parties who reasonably require such data in order to perform a service to us. For example:

  • in the case of suppliers to ExR, providers of (among other things) [administration and IT-related products and services]; and

  • if we are sold to a third party, your personal data may be transferred to that reorganised entity or third party and used for the purposes above.

    • In addition, it may be necessary for us to disclose your personal data if we are under a duty to do so in order to comply with any legal or regulatory obligation to which we are subject, enforce any agreement we have with you or a related third party, or protect the rights, property or safety of ExR, its employees or other personnel. This includes exchanging information with other companies and organisations for the purposes of fraud and crime prevention.

    You acknowledge that the third parties described above may receive and process your personal data. ExR asks all third parties to treat your personal data securely and in accordance with Data Protection Legislation, and will take reasonable steps to enforce this. We will never sell your personal data to third parties.


    5. STORAGE, RETENTION AND TRANSFER OF YOUR PERSONAL DATA OUTSIDE OF THE UK

    We take steps to protect your personal data from unauthorised access and against unlawful processing, accidental loss, destruction and damage. We will only keep your personal data for as long as we reasonably require and, in any event, only for as long as Data Protection Legislation allows. We do not transfer your personal data outside of the United Kingdom.


    6. LINKS TO THIRD PARTY WEBSITES

    Our Website may, from time to time, contain links to third party websites, such as LinkedIn, Twitter, medical technology companies, research institutions and healthcare organisation sites. If you follow a link to any of these websites, please note that you will be leaving our Website and accessing the other website, the collection of personal data via which will be carried out in accordance with its own privacy policy.

    We do not accept any responsibility or liability for these websites or their related policies and you should therefore review these policies before you submit any personal data via these websites.


    7. YOUR RIGHTS

    Pursuant to Data Protection Legislation, subject to certain exemptions, you have various rights in relation to the personal data that we hold about you, as follows:

  • you have the right to see the personal data that we hold about you and to withdraw any consent you may have given us to hold and use that personal data;

  • you have the right to ask us to make any changes which may be necessary to ensure that any information we hold about you is accurate and up to date;

  • you have the right to request that we erase your personal data (or any part thereof); a request which we will comply with unless we have a lawful reason to retain the information; and

  • in some cases, you have the right to request that we transfer your personal data to a specified third party.

    • If you wish to exercise any of the rights described us, please contact us via the details set out in Section 10 of this policy.


    8. CHANGES TO OUR PRIVACY POLICY

    ExR may amend this privacy policy at any time without notice. By continuing to use the Website, the App, communicate with us, or otherwise provide us with your personal data, you agree to the updated privacy policy. If you do not agree to any changes that we make to this policy, you should not use or access (or continue to use or access) the Website, the App and/or our services. Any changes to our privacy policy will be posted on the Website and, where appropriate, notified to you by e-mail.


    9. COOKIES

    A cookie is a small file that is sent to your browser from a web server and is stored on your computer. Cookies help us to analyse web traffic and identify which pages of our Website are being used. Our Website also uses cookies to respond to you as an individual so that it can tailor its operations to your needs, likes and dislikes by gathering and remembering information about your preferences as well as enabling you to login. We only use this information for statistical analysis purposes and then it is removed from our systems.

    A cookie in no way gives us access to your computer or any information about you, other than information about how you use the Website and the personal data you choose to share with us (including personal data you automatically share with us by way of your browser settings).

    In particular, we use the following cookies:

  • Essential cookies. These cookies are used to identify unique visitors to the Website. If you log in to the Website, these are the cookies that allow us to remember who you are and what your preferences are so that we can provide you with access to pages personal to you, for example your account pages. These cookies can help to keep your visit to the Website secure.

  • Non-essential cookies. These cookies allow us to identify your device as you use the Website, so that you are not treated as a new visitor each time you go to another part of the Website.

    • You can choose to accept or decline cookies. Most web browsers automatically accept certain cookies, but you can usually modify your browser setting to decline cookies if you prefer. This may prevent you from taking full advantage of our Website. We may also use banners and pop-ups from time to time to give you options around cookie use.

    You may also turn non-essential cookies on or off at any time. Non-essential cookies help us to improve our Website by collecting and reporting information on how you use it. The cookies collect information in a way that does not directly identify you. You can come back to this page to change your cookie settings at any time by using the link at the bottom of the Website.

    You can find more information about the specific cookies we use and the purposes for which we use them in the table below. You can also find more information about cookies generally here: www.allaboutcookies.org.


    Cookie name Host Description/Purpose Duration
    Essential cookies
    _app_session app.exr.education Used to track whether a user is logged in, and who they are logged in as. The length of the browser session.
    Non-essential cookies
    _ga google.com Used to distinguish users. 2 years.
    _ga_[container-id] google.com Used to persist session state. 2 years.

    10. CONTACT US

    Should you have any questions or comments regarding this privacy policy, or if you otherwise wish to exercise any of your rights as described above in Section 7 of this policy, please contact us by emailing privacy@exr.education.

    Alternatively, you have the right to make a complaint to the Information Commissioner's Office (the supervisory body in the UK that is responsible for the enforcement of data protection legislation), the details of which may be found here.