KLEOS Privacy Statement
1. General information
KLEOS is a service provided by Smith & Nephew Plc. In this privacy statement all references to “KLEOS” (the brand under which the website is provided), "we" or "us" should be read as references to Smith & Nephew Plc whose registered office is at 15 Adam Street, London, WC2N 6LA, United Kingdom.
This privacy policy sets out how we use and protect any information provided to us by users accessing and using the website. We are committed to the protection of the privacy of KLEOS users. Please note that we amend this policy from time to time and therefore you should review it regularly. We will of course notify you of any changes where we are required to do so.
If you have questions or comments regarding our privacy statement then please send an e-mail to kleos-global@smith-nephew.com
2. Data collection and Use
We collect and process your personal details and information we obtain from other sources in order to provide you with optimal services, for administration and customer services, for statistical analysis of our website, for enhancement of our products and services, for marketing, to analyse your preferences and to ensure that the content, services and courses advertised and offered to you are tailored to meet your needs and interests.
We may keep your information for a reasonable period for these purposes.
If you provide us with information about someone else you confirm that they have appointed you to act for them to consent to the processing of their personal data and that you have informed them of our identity and the purposes (as set out above) for which their personal data will be processed.
3. Sharing data
This website and the data held on you is maintained by Smith & Nephew Orthopaedics AG, based in Switzerland on behalf of Smith & nephew Plc. Smith & Nephew Orthopaedics AG is governed by Swiss data protection law which the European Union has acknowledged provides an adequate and comparable level of protection to other EU countries. Smith & nephew Plc may share your information with other group companies for the same purposes as described above. Other group companies may not be based in the EU and we may need to share your information with our service providers and agents for operational reasons, some of which may be outside the EU. By providing us with your information you consent to our transferring your information to countries or jurisdictions which do not provide the same level of data protection as in Switzerland or the UK. We are still required to have regard to the security of your data and we will, if appropriate, put a contract in place to protect your information.
We may disclose personal data in order to comply with a legal or regulatory obligation.
4. Use of your data for marketing
We and our group companies may contact you by mail, telephone, fax, email or other electronic messaging service with offers of products, services or information that may be of interest to you and to request feedback on courses you have participated in. By providing us with your contact details you consent to being contacted by these methods for these purposes. We may share your information with our business partners for marketing purposes or we may send you information about other organisations' goods and services. If you do not wish to receive marketing information from us or our business partners (other than what you have specifically requested via the website) please indicate this on the "Registration" form or contact us using the details below.
5. Cookies
We may use information obtained about you from cookies (files which are sent to us by your computer or other access device) which we can access when you visit our site in future. We do this to allow us to identify users and personalise the site wherever possible. The cookies store small pieces of information about our visitors, such as names and email addresses. This means that on future visits to our site, we can identify past visitors and welcome them back.
If you want to delete any cookies that are already on your computer, please refer to the instructions for your file management software to locate the file or directory that stores cookies. If you want to stop cookies being stored on your computer in future, please refer to your browser manufacturer’s instructions by clicking “Help” in your browser menu. Further information on deleting or controlling cookies is available at www.AboutCookies.org. Please note that by deleting our cookies or disabling future cookies you may not be able to access certain areas or features of our site.
We also include web beacons (also known as clear gifs or web bugs) in our emails to track the success of our marketing campaigns. This means that if you open an email from us we can see which pages of our website you visit. If you object to web beacons we recommend you follow the instructions for deleting existing cookies and disabling future cookies above. We will still know how many of our emails are opened and we will automatically receive your IP address, a unique identifier for your computer or other access device.
We will also log your IP address when you visit our website.
6. Accuracy of data
If you become aware that your personal data is incorrect or is not up to date because your personal details have changed, you may ask us at any time to rectify the data at no cost. Please note that data entered by you while registering on the website can be accessed directly on the website by using the link to “my account”. Please check and update your entries regularly.
If your marketing preferences change please notify us at any time by emailing kleos-global@smith-nephew.com.
You are entitled to ask for a copy of the information we hold about you (for which we charge a small fee).
7. Data quality and security
We take appropriate measures to ensure that the information disclosed to us is kept secure, accurate and up to date and kept only for so long as is necessary for the purposes for which it is used. Our database containing your personal data is protected by technical and organizational measures against illegal access, and the data is protected from illegal use and processing by unauthorized persons. However, data transmission over the internet cannot be guaranteed as 100% secure and therefore you use the website at your own risk.
8. Scope of application
This privacy statement applies to the website operated by us under the brand KLEOS. We may place on our website links to other websites for your information. However, we do not assume any responsibility for the content of these websites or the way in which information is processed by third parties operating these sites, nor do we accept responsibility in respect of their privacy policies or any third party advertisers who ay advertise on such websites.
9. Other information
You should note that if our business (or any part of it) is sold or transferred at any time, the information we hold may form part of the assets transferred although will still only be used in accordance with this policy unless and until you are notified otherwise.
This privacy policy is governed by English law.
KLEOS is a service provided by Smith and Nephew Plc and its group companies.
February 2009