- Information we collect about you
- How we use your information
- Our promotional updates and communications
- Who we give your information to
- Where we store your information
- Child safety
- Payment processing
- Automated decision making
- How we protect your information
- How long we keep your information
- Your rights
- Changes to this policy
- Contact us
- Please read the following carefully to understand our views and practices regarding your personal data and how we will treat
For the purposes of European Economic Area data protection law, (the “Data Protection Law”), the data controller is: electroCore UK Ltd trading as electroCore. We are a limited company, registered in England. Our registered company number is 09432721, and our registered office is at Suite Ff10, Brooklands House, 58 Marlborough Road, Lancing, West Sussex, England, BN15 8AF. Our ICO registration number is: ZB237517.
Our Data Protection Officer is Iain Strickland and can be contacted at DPO@electrocore.com.
Information we collect about you
We are committed to the UK GDPR principle of data minimisation, and only collect the personal data that we need to be able to provide our services to you. We will collect and process the following personal data from you:
Information you give us
This includes to:
- Register to create an account with us via the
- Record information about your health, treatment, symptoms, medications and how you are
- Answer questionnaires about your health, treatment, symptoms, and holistic
- Share your health information with Permitted Third Parties (you have complete control over with whom you share your health information).
- Prescribe you with electroCore
- Obtain information via the Site or by corresponding with us by phone, e-mail or otherwise, including information you provide when you register to use the Site, complete a questionnaire to assess your eligibility for a product, search for a product, place an order on the Site, participate in feedback or enter a survey, submit a query, and when you report a problem with the
The information you give us may include your name, address, e-mail address, phone number, date of birth, financial and credit card information, personal description, login, and password details.
To interact fully with the Site and obtain access to the products you may need to provide information about your existing health conditions and symptoms, including medical diagnoses, previous surgical procedures, and known allergies.
Any information about your health is classed as sensitive personal data and we ensure that additional safeguarding measures are in place to protect this information. Our lawful basis for processing this sensitive personal data is your consent. You can withdraw your consent at any time – for more information please see “Your rights”. Please note that if you do not consent to our processing of your sensitive personal data, you may not be able to benefit from our products and services.
Information we collect about you
We will automatically collect information from you each time you visit the Site. This includes:
- Information about your visit (including any information provided by third party analytics tools)
- Location Data
- If you accept an invitation that you have received from a Patient, Caregiver or a Medical Provider to visit the Site, we will be able to tell which third party has provided you with this invitation (this may be in the form of a code you receive, an SMS or email invitation, or other form of communication).
- Technical information may include the Internet protocol (IP) address used to connect your computer to the Internet, your login information, browser type and version, time zone setting, browser plug-in types and versions, operating-system and
- Information about your visit may include the full Uniform Resource Locators (URL), clickstream to, through and from the Site (including date and time), products you viewed or searched for, page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), methods used to browse away from the page, and any phone number used to call our customer service number or social media handle used to connect with our customer service
- Location data – we may collect information through the Sites as to your real time location to provide location services where requested or agreed to by you in order to deliver content, advertising or other services that are dependent on knowing where you are. This information may also be collected in combination with an identifier associated with your device to enable us to recognise your mobile browser or device when you return to the
- Delivery of location services will involve reference to one or more of the following: (a) the coordinates (latitude/longitude) of your location; (b) look-up of your country of location by reference to your IP address against public sources; and/or (c) your Identifier for Advertisers (IFA) code for your Apple device, or the Android ID for your Android device, or a similar device
Information we receive from other sources
This is information we receive about you:
- If you accept an invitation from a Healthcare Provider to use the Website, we may receive information about your medical history and Healthcare Provider from the Healthcare Provider’s records on you.
- If you use any of the other websites we operate or the other services we
- From third parties we work closely with such as the platform providers whose devices or operating systems are compatible with the
In each case we will have informed you when we collected that data if we intend to share your data internally and combine it with data collected on this site. We will also have told you for what purpose we will share and combine your data.
We are working closely with third parties (including, for example, business partners, sub- contractors in technical, payment and delivery services, advertising networks, analytics providers, and search information providers).
This Site uses a tracking technology called a “cookie.” A cookie is a small text data file that a web site can place on your computer’s hard drive, where your internet browser files are kept. Cookies enable us to recognise when a computer being used to browse our web site has previously visited gammaCore or its other owned web sites. Cookies can also be used to enable a site to ‘remember’ the information a visitor has previously inputted, should that visitor so choose. Cookies may be placed on your computer both by us and by third parties with whom we have a relationship, such as web analytic services, pixel tags, browser analysis tools, server logs and web beacons. Most internet browsers allow you to change your browser settings to notify you when you receive a cookie, which lets you choose whether or not to accept it, or to automatically accept or refuse all cookies.
A cookie’s life span may vary depending on what the individual providers have set for them. Some cookies disappear as soon as you close your browser window, where others may exist for several years. The third parties electroCore partners with typically use a 12-or 24-month life span on web analytics and advertisement-related cookies. The life span is reset after each visit to the Site.
You can block cookies from being placed on your computer. If you block cookies, it can result in parts of the Site not functioning or appearing properly. Additionally, you can delete previously stored cookies. The method deleting those previously stored depends on the browser and the device being used to visit the website.
Our promotional updates and communications
Where permitted in our legitimate interest or with your prior consent where required by law, we will use your personal information for marketing analysis and to provide you with promotional update communications by email, SMS/iMessage or in-Site about our products and services. We will also analyse the information that you or a Permitted Third Party give us about your symptoms to suggest our commercial partners’ products. You can object to further marketing at any time by selecting the “unsubscribe” link at the end of all our marketing and promotional update communications to you, or by sending us an email to firstname.lastname@example.org.
The information gathered will be used solely for marketing in connection with our business and our commercial partners’ products and will not be shared with any other third parties.
We may give your information to
Information you provide to us is used to improve the products and services we provide you or for the development of our business and is not provided to any unrelated company for that company’s independent use. We may disclose your personal information to the following categories of recipients and you hereby consent to such disclosures (which may be revoked at any time in your discretion):
- to our group companies, third party services providers and partners who provide data processing services to us (for example, to support the delivery of, provide functionality on, or help to enhance the security of our website), or who otherwise process personal information for purposes that are described in this Privacy Notice or notified to you when we collect your personal In addition to electroCore UK, our group companies include electroCore Inc.
- to any competent law enforcement body, regulatory, government agency, court or other third party where we believe disclosure is necessary (i) as a matter of applicable law or regulation, (ii) to exercise, establish or defend our legal rights, or (iii) to protect your vital interests or those of any other
- we may transfer any information we have about you in the event we sell or transfer all or a portion of our business or assets or in the process leading up to an intended sale or transfer.
- to any other person with your consent to the
Where we store your information
The data that we collect from you is stored within the European Economic Area (“EEA”).
information is not routinely transferred outside of the EEA or Switzerland except where necessary to respond to product complaints or inquiries. In such instances, we will take appropriate safeguards to require that your personal information will remain protected in accordance with this privacy notice. These include implementing the European Commission’s Standard Contractual Clauses.
Protecting the safety of children when they use the Internet is important to us. The Site and products available are intended for use only by persons who are at least 18 years of age. By using our Site you confirm to us that you meet this requirement.
How we protect your information
All information you provide to us is stored on our secure servers and is encrypted between your device and any external host storage to keep it safe. Where we have given you (or where you have chosen) a password which enables you to access certain parts of the Sites, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.
Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to the Sites and any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access.
The Sites may, from time to time, contain links to external sites. We are not responsible for the privacy policies or the content of such sites.
Automated decision making
We do not carry out any automated decision making using your personal data that would have a legal or similarly significant effect on you.
How long we keep your information
We retain personal information we collect from you where we have an ongoing legitimate business need to do so (for example, to provide you with a service you have requested or to comply with applicable legal, tax or accounting requirements).
When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymise it or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.
You have the right under certain circumstances:
- to be provided with a copy of your personal data held by us;
- to request the rectification or erasure of your personal data held by us;
- to request that we restrict the processing of your personal data (while we verify or investigate your concerns with this information, for example);
- to object to the further processing of your personal data, including the right to object to marketing (as mentioned in ‘Our promotional updates and communications’ section; and
- to request that your provided personal data be moved to a third
Your right to withdraw consent
Where the processing of your personal information by us is based on consent, you have the right to withdraw that consent without detriment at any time by contacting us at DPO@electrocore.com. You can also change your marketing preferences at any time as described in ‘Our promotional updates and communications’ section (above).
You can exercise the rights listed above at any time by contacting us at DPO@electrocore.com. We strive to respond to your requests within one month and will let you know if we are unable to meet this timeframe. If your request or concern is not satisfactorily resolved by us, you may approach your local data protection authority, (see http://ec.europa.eu/justice/data- protection/bodies/authorities/index_en.html).
The Information Commissioner is the supervisory authority in the UK and can provide further information about your rights and our obligations in relation to your personal data, as well as deal with any complaints that you have about our processing of your personal data.
Changes to this policy