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PRIVACY NOTICE


BBI RISK SOLUTIONS COMPLIES WITH EU GENERAL DATA PROTECTION DIRECTIVE (GDPR) FOR
THE COLLECTION, USE, AND RETENTION OF ALL PERSONAL DATA.




BBI GROUP HOLDCO LIMITED AND BBI COMPANIES (BBI) PRIVACY NOTICE.

 

Under the EU’s General Data Protection Regulation (GDPR) ‘Personal Data’ is
defined as:

“any information relating to an identified or identifiable natural person ('data
subject'); an identifiable natural person is one who can be identified, directly
or indirectly, in particular by reference to an identifier such as a name, an
identification number, location data, an online identifier or to one or more
factors specific to the physical, physiological, genetic, mental, economic,
cultural or social identity of that natural person”.

BBI respects your privacy and is committed to protecting your Personal Data.
This Privacy Notice will inform you as to how we look after your Personal Data,
tell you about your privacy rights and how the law protects you.

 

1.0     Purpose of this Privacy Notice

1.1       This Privacy Notice aims to give you information on how BBI collects
and processes your Personal Data.

1.2       It is important that you read this Privacy Notice so that you are
fully aware of how and why we are using your data.

2.0       Contact details

2.1       Our full details are:

Full name of legal entity

BBI Group Holdco Limited

BBI Companies

BBI Healthcare Limited, BBI Solutions OEM Limited; BBI Detection Limited &
Novarum DX Ltd. BBI Solutions – Freiberg (Diarect GmbH)

Data Protection Officer

Dr Phil Griffiths

Email address

p.griffiths@thedpo.co.uk

Postal address

The Capital Tower, Greyfriars Road Cardiff CF10 3AZ

 

3.0       Changes to the Privacy Notice and your duty to inform us of changes

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.

4.0       The data we collect about you

4.1       We collect, use, store and transfer different categories of Personal
Data about you which we have grouped together as follows:

 * Identity Data includes first name, maiden name, last name, username or
   similar identifier, marital status, title, date of birth and gender.
 * Contact Data includes billing address, delivery address, email address and
   telephone numbers.
 * Financial Data includes bank account, payment card details, and payroll data.
 * 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 and other technology on the
   devices you use to access our website or intranet.
 * Profile Data includes your username and password on our website, our
   intranet, purchases or orders made by you, your preferences, and feedback and
   survey responses.
 * Usage Data includes information about how you use our website, intranet,
   products and services.
 * Marketing and Communications Data includes your preferences in receiving
   marketing from us and our third parties and your communication preferences.

4.2       We also collect, use and share Aggregated Data such as statistical or
demographic data for any purpose. Aggregated Data may be derived from your
Personal Data but is not considered Personal Data in law as this data does not
directly or indirectly reveal your identity. For example, we may aggregate your
Usage Data to calculate the percentage of users accessing a specific website
feature. However, if we combine or connect Aggregated Data with your Personal
Data so that it can directly or indirectly identify you, we treat the combined
data as Personal Data which will be used in accordance with this Privacy Notice.

4.3       Special Categories of Personal Data these are details about your race
or ethnicity, religious or philosophical beliefs, sex life, sexual orientation,
political opinions, trade union membership, information about your health and
genetic and biometric data). We do not normally collect any special categories
of data nor do we collect any information about criminal convictions and
offences other than for our employees or applicants for employment. However if
we do need to processes such data we will ask for your explicit consent to do
so.

5.0       If you fail to provide Personal Data

Where we need to collect Personal Data by law, or under the terms of a contract
we have with you and you fail to provide that data when requested, we may not be
able to perform the contract we have or are trying to enter into with you (for
example, to provide you with goods or services or employee benefits). In this
case, we may have to cancel a product or service you have with us but we will
notify you if this is the case at the time.

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

6.1       Direct interactions. You may give us your Identity, Contact and
Financial Data by filling in forms or by corresponding with us by post, phone,
and e-mail or otherwise. This includes Personal Data you provide when you:

 * apply for our products or services;
 * create an account on our website;
 * subscribe to our service or publications;
 * request marketing to be sent to you;
 * enter a promotion or survey;
 * give us some feedback;
 * provide unsolicited information to us;
 * apply for employment with us or when you become an employee.

6.2       Automated interactions. As you interact with our website or intranet,
we may automatically collect Technical Data about your equipment, browsing
actions and patterns. We collect this Personal Data by using cookies, and other
similar technologies.

6.3       Third parties (or publicly available sources). We may receive
categories of Personal Data about you from various third parties and public
sources as set out below:

 * Technical Data from analytics providers such as Google; advertising networks
   and search information providers.
 * Contact, Financial and Transaction Data from providers of technical, payment
   and delivery services.
 * Identity and Contact Data from data brokers, aggregators or recruitment
   agencies.
 * Identity and Contact Data from publicly availably sources such as Companies
   House and the Electoral Register.

7.0       How we use your Personal Data

7.1       We will only use your Personal Data when the law allows us to. Most
commonly, we will use your Personal Data in the following circumstances:

 * Where we need to perform the contract we are about to enter into or have
   entered into with you.
 * Where it is necessary for our legitimate interests (or those of a third
   party) and your interests and fundamental rights do not override those
   interests.
 * Where we need to comply with a legal or regulatory obligation.

7.2       We may also use your Personal Data in the following situations, which
are likely to be rare:

 * Where we need to protect your interests (or someone else's interests).
 * Where it is needed in the public interest or for official purposes.

7.3       Generally we do not rely on consent as a legal basis for processing
your Personal Data other than, where we have not had any prior relationship with
you and you have not opted out of such marketing, in relation to sending direct
marketing communications to you via email or text message. You have the right to
withdraw consent to marketing at any time by unsubscribing to that email or
text.  

8.0       Purposes for which we will use your Personal Data

8.1       We have set out below, in a table format, a description of all the
ways we plan to use your Personal Data, and which of the lawful bases we rely on
to do so. We have also identified what our legitimate interests are where
appropriate.

8.2       Note that we may process your Personal Data for more than one lawful
ground depending on the specific purpose for which we are using your data.
Please contact us if you need additional details about the specific legal ground
we are relying on to process your Personal Data where more than one ground has
been set out in the table below.

 

Purpose/Activity

Category of Personal Data

Lawful basis for processing including basis of legitimate interest

To register you as a new client or employee.

(a) Identity

(b) Contact

Performance of a contract with you

To process and deliver your service or order including:

(a) Manage payments, fees and charges

(b) Collect and recover money owed to us

(a) Identity

(b) Contact

(c) Financial

(d) Transaction

(e) Marketing and Communications

(a) Performance of a contract with you

(b) Necessary for our legitimate interests

 * to recover debts due to us.

To manage our relationship with you which will include:

(a) Notifying you about changes to our terms or privacy policy

(b) Asking you to leave a review or take a survey

(c) As an employee

(a) Identity

(b) Contact

(c) Profile

(d) Usage

(e) Marketing and Communications

(f) Financial

(a) Performance of a contract with you

(b) Necessary to comply with a legal obligation

(c) Necessary for our legitimate interests

 * to keep our records updated,
 * to study how customers and clients use our products/services;  and,
 * to administer our employee relationships

To enable you to partake in a prize draw, competition or complete a survey

(a) Identity

(b) Contact

(c) Profile

(d) Usage

(e) Marketing and Communications

(a) Performance of a contract with you

(b) Necessary for our legitimate interests

 * to study how customers use our products/services; and
 * to develop them and grow our business.

To administer and protect our business and our intranet and website (including
troubleshooting, data analysis, testing, system maintenance, support, reporting
and hosting of data) 

(a) Identity

(b) Contact

(c) Profile

(d) Technical

(e) Usage

(a) Necessary for our legitimate interests

 * for running our business and employee relationship,
 * provision of administration and IT services, network security,
 * to prevent fraud and
 * in the context of a business reorganisation or group restructuring exercise.

(b) Necessary to comply with a legal obligation

To deliver relevant website content and advertisements to you and measure or
understand the effectiveness of the advertising we serve to you

(a) Identity

(b) Contact

(c) Profile

(d) Usage

(e) Marketing and Communications

(f) Technical

Necessary for our legitimate interests

 * to study how customers use our products/services,
 * to develop them,
 * to grow our business and
 * to inform our marketing strategy.

To use data analytics to improve our website, products/services, marketing,
customer relationships and experiences

(a) Technical

(b) Usage

Necessary for our legitimate interests

 * to define types of customers for our products and services;
 * to keep our website updated and relevant;
 * to develop our business; and,
 * to inform our marketing strategy.

To make suggestions and recommendations to you about goods or services that may
be of interest to you

(a) Identity

(b) Contact

(c) Technical

(d) Usage

(e) Profile

Necessary for our legitimate interests

 * to develop our products/services; and,
 * to grow our business)

 

9.0       Marketing

9.1       We strive to provide you with choices regarding certain Personal Data
uses, particularly around marketing and advertising. We have established the
following Personal Data control mechanisms:

 * Promotional material from us. We may use your Identity, Contact, Technical,
   Usage and Profile Data to form a view on what we think you may want or need,
   or what may be of interest to you. This is how we decide which products,
   services and offers may be relevant for you (we call this marketing).
 * You will receive marketing communications from us if you have requested
   information from us or purchased products or services from us and, in each
   case, you have opted-in to receiving that marketing.
 * Third-party marketing.  We will get your express opt-in consent before we
   share your Personal Data with any company outside BBI for marketing purposes.
 * Opting out. You can ask us or third parties to stop sending you marketing
   messages at any time by following the opt-out links on any marketing message
   sent to you.
 * Where you opt-out of receiving these marketing messages, this will not apply
   to Personal Data provided to us as a result of a product/service purchase,
   warranty, product/service experience or other transactions.
 * Cookies. Most web browsers allow some control of most cookies through the
   browser settings. To find out more about cookies, including how to see what
   cookies have been set and how to manage and delete them,
   visit www.aboutcookies.org or www.allaboutcookies.org.
 * To opt out of being tracked by Google Analytics across all websites
   visit http://tools.google.com/dlpage/gaoptout.

 

10.0     Change of purpose

10.1     We will only use your Personal Data for the purposes for which we
collected it, unless we reasonably consider that we need to use it for another
reason and that reason is compatible with the original purpose.

10.2     If we need to use your Personal Data for an unrelated purpose, we will
notify you and we will explain the legal basis which allows us to do so.

10.3     Please note that we may process your Personal Data without your
knowledge or consent, in compliance with the above rules, where this is required
or permitted by law.

11.0     Disclosures of your Personal Data

11.1     We may have to share your Personal Data with the parties set out below
for the purposes set out in the table above.

 * Internal Third Parties: other companies or departments in BBI acting as
   processors or joint controllers and provide IT and system administration
   services and undertake leadership reporting
 * External Third Parties: service providers acting as processors based who
   provide IT and system administration services
 * Other Third Parties to whom we may choose to sell, transfer, or merge parts
   of our business or our assets. Alternatively, we may seek to acquire other
   businesses or merge with them. If a change happens to our business, then the
   new owners may use your Personal Data in the same way as set out in this
   Privacy Notice.
 * Professional advisers: acting as processors or joint controllers including
   lawyers, bankers, auditors and insurers who provide consultancy, banking,
   legal, insurance and accounting and payroll services.
 * HM Revenue & Customs, regulators and other authorities acting as processors
   or joint controllers who require reporting of processing activities in
   certain circumstances.

11.2     We require all third parties to respect the security of your Personal
Data and to treat it in accordance with the law. 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.

12.0     International transfers

12.1     Some of our external third parties are based outside the UK/European
Economic Area (EEA) so their processing of your Personal Data will involve a
transfer of data outside the UK/EEA.

12.2     Whenever we transfer your Personal Data out of the UK/EEA, we ensure a
similar degree of protection is afforded to it by ensuring at least one of the
following safeguards is implemented:

 * We will only transfer your Personal Data to countries that have been deemed
   to provide an adequate level of protection for Personal Data by the European
   Commission.
 * Where no adequacy decision has been granted by the European Commission, we
   will only transfer personal data to third countries where appropriate
   safeguards have been provided by the transferee, including we may use
   standard contract clauses approved by the European Commission which give
   Personal Data the same protection it has in Europe.

13.0     Data security

13.1     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, we limit access to your Personal Data to
those employees, agents, contractors and other third parties who have a business
need to know. They will only process your Personal Data on our instructions and
they are subject to a duty of confidentiality.

13.2     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.

14.0     Data retention

14.1     We will only retain your Personal Data for as long as necessary to
fulfil the purposes we collected it for, including for the purposes of
satisfying any legal, accounting, or reporting requirements.

14.2     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 requirements.

14.3     In some circumstances we may 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.

15.0     Your legal rights

15.1     Under certain circumstances, you have rights under data protection laws
in relation to your Personal Data to request the following:

 * access to your Personal Data.
 * correction of your Personal Data.
 * erasure of your Personal Data.
 * object to processing of your Personal Data.
 * restrict of processing your Personal Data.
 * transfer of your Personal Data.
 * withdraw consent to any consent that you have previously given.

15.2     If you wish to exercise any of the rights set out above, please
contacts our DPO. You can also contact the Information Commissioner's Office
via https://ico.org.uk/  for information, advice or to make a complaint.

15.3     You 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
may refuse to comply with your request in these circumstances.

16.0     What we may need from you

We 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.

17.0     Time limit to respond

We try to respond to all legitimate requests within one month. Occasionally it
may 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. 


BBI SOLUTIONS BRANDS

DIARECT has a world leading recombinant autoimmune antigen capability
immediately that enhances BBI’s portfolio and position as a ‘complete’
immunoassay reagent supplier.

Maine Biotechnology Services brings 28 years of knowledge, experience, process
development, and project management to our customers to ensure the best possible
antibodies for any application.

Novarum™ technology transforms a smartphone into a diagnostic test reader and
work flow management system , empowering users to read and share the results of
rapid tests at the point of care connecting patients and doctors, field workers,
lab researchers and primary care clinicians to specialist practices as part of a
mobile eco-system.

BioTeZ Berlin-Buch GmbH is a biotechnology company founded in 1992. BioTeZ is a
partner of research institutions, the pharmaceutical industry and laboratory
diagnostics.

STEFFENS BIOTECHNISCHE ANALYSEN GmbH has been developing and producing
Enzyme-Linked Immuno Sorbent Assay (ELISA) test kits and components since 1991,
both as an OEM manufacturer and for direct sales.


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