Privacy Policy

General Privacy Notice - website use and administration of member contracts/accounts

Last updated: 23rd May 2018

Who are we?

"We", "our" or "us" means Lhasa Limited. We are a charitable organisation. Our company no. is 1765239 and charity no. is 290866. Our registered office is at Granary Wharf House, 2 Canal Wharf, Holbeck, Leeds, West Yorkshire, LS11 5PS.

What does this privacy notice apply to?

  • This privacy notice sets out how we use your personal information when we collect it through our website.
  • If you are a contact at one of our member organisations it also sets out how we use your personal information from the point of view of administration of your contract/account. Please note that we have a separate privacy notice about the use of personal information from a marketing perspective. This is available by clicking here.
  • This privacy notice also tells you what your rights are over your personal information and how to exercise those rights.

This privacy notice answers the following questions – please click on the links below to take you directly to the answers to each question:

  1. How we use the personal information that you give us when you use our website?
  2. How we use the personal information that we collect about you from your use of our website?
  3. What is our legal basis for using the information you give us when you use our website and the information we collect about you from your use of our website?
  4. How we use the personal information that you give us if you are a contact at one of our member organisations from the point of view of administration of your contract/account?
  5. What is our legal basis for using the information you give us if you are a contact at one of our member organisations from the point of view of administration of your contract/account?
  6. How long we will keep your personal information?
  7. Who will we share your personal information with?
  8. Will we transfer your personal information outside the UK/EEA?
  9. What rights you have over your personal information?
  10. Does this privacy notice cover websites I link to from this website?
  11. How we’ll tell you about changes to this privacy notice?
  12. How you can contact us?

1. How we use the personal information that you give us when you use our website?

Information you give us: If you fill in a form or use the live chat function on our website, we will collect the information you include on the form or in the live chat message. We will use this information to: 

  • send you the information you have requested, for example, about our software or training;
  • respond to your query;
  • register you for attendance at one of our events; and/or
  • update your communication preferences if you have asked us to do so.

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2. How we use the personal information that we collect about you from your use of our website?

We use cookies on our website. Full details of how we use cookies can be found in our cookie policy. We also use Google Analytics and related cookies on our website. Full details of this use are also set out in our cookie policy. Other than as set out in our cookie policy, our website does not collect any information that identifies you personally.

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3. What is our legal basis for using the information you give us when you use our website and the information we collect about you from your use of our website?

Under data protection law we must have a legal basis to use your personal information. We have set these out below.

Information you give us: Where you fill in a form or use the live chat function on our website, the legal basis for this use is that it is in our legitimate interests as a business to be able to respond to enquiries that we get through our website so that we can respond to the request you have made. We will only use the information we get from you to respond to your enquiry and so we consider that this is a proportionate use of your personal information. If you fill in one of the forms on our website or provide your details through the live chat function and you are not a company representative for one of our member organisations, after we have responded to your enquiry we may send you a follow-up message to ask if you would like to sign up to receive marketing communications from us. Please read our marketing policy which explains how we use your personal information for marketing if you agree to it. If you do not respond to the follow-up message or tell us that you don’t want to hear from us with marketing, we will send not any marketing communications to you.

Information we collect about you from your use of our website: Where we collect personal information through Google Analytics or the other cookies on our website, the legal basis for this use is that it is in our legitimate interests as a business to monitor how our website is used, the traffic we get through our website, and to help us to improve the user-experience of our website. We have considered our legitimate interests carefully and we do not consider that our legitimate interest in having a well-functioning website has a disproportionate effect on your rights under data protection law because we collect minimal information from you which is largely anonymised. We do not use the information we collect to make any decisions about you.

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4. How we use the personal information that you give us if you are a contact at one of our member organisations from the point of view of administration of your contract/account?

Information you give us: If your organisation becomes a member of Lhasa, we will collect information from you, such as your name, job title and business contact details. We may use this information to:

  • log you in to your online account on our website;
  • contact you to manage the contract we have with your organisation;
  • contact you to manage your organisation’s Lhasa membership;
  • contact you every year to discuss the renewal of your organisation’s Lhasa membership agreement;
  • contact you about Lhasa’s annual general meetings at which company representatives at Lhasa members are entitled to vote at;
  • provide your organisation with updates to our software;
  • provide your organisation with training on our software;
  • register you for attendance at one of our events; and/or
  • send invoices to you, contact you in relation to payment and administer the financial account relating to your organisation.

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5. What is our legal basis for using the information you give us if you are a contact at one of our member organisations from the point of view of administration of your contract/account?

Under data protection law we must have a legal basis to use your personal information. We have set these out below.

Information you give us: We are collecting and using the personal information that you give us as the contact for your organisation that is a Lhasa member on the legal basis that it is in our legitimate interests as a business to be able to contact you to administer the contract, membership account and financial account that your organisation has with us and to contact you in relation to the software and services we provide to your organisation. We have considered our legitimate interests carefully and consider that this is a proportionate use of your personal information as we only use your business contact details for matters which relate directly to our relationship with the organisation you work for.

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6. How long we will keep your personal information?

We will not keep your personal information for longer than we need it for the purposes we have explained in this privacy notice. We have added a table at the end of this privacy notice which sets out how long we keep the different personal information for.

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7. Who will we share your personal information with?

We will only share the personal information that you give us with the following third parties and for the following reasons:

Where your organisation is a member of Lhasa or we have otherwise collected your personal information, for example through our website or at an event.

We will share your personal information with our group company Lhasa Limited Inc. Where your organisation is a Lhasa member based in the USA, this is because our USA based group company is best placed to contact you in respect of matters relating to your organisation’s contract, membership account and financial account and to contact you in relation to the software and services we provide to your organisation. Where your organisation is a Lhasa member not based in the USA, or we have otherwise collected your personal information, for example through our website or at an event, this is because Lhasa Limited Inc.provides us with support in managing all our members’ accounts and prospect data. We consider the use of your personal information is in our legitimate interests and is proportionate because we will only pass on the information you have given to us.

Where your organisation has purchased and/or evaluated eTOXsys.

We will share your personal information with oureTOX partners Molecular Networks because Molecular Networks has authroised Lhasa Limited to distribute eTOXsys and Lhasa must report to Molecular Networks on all sales and evaluations of eTOXsys. We consider the use of your personal information is in our legitimate interests and is proportionate because we will only pass on the information you have given to us.

Where you or your organisation is based in China, Japan or the Republic of Korea and you ask us for information.

We will share your personal information with our distributors in China, Japan or the Republic of Korea as we do not have a presence there. We do this on the basis that it is in our legitimate interests as a business to be able to ask our local distributors to provide you with the information you have asked for. We consider the use of your personal information is in our legitimate interests and is proportionate because we will only pass on the information you have given to us.

If you have registered to attend one of our webinars or one of our events.

We use third party software GoToWebinar to facilitate our hosting of our webinars and we use third party software RegOnline to facilitate our processing of our event bookings. Your personal information passes through this third party software so that we can give you access to the webinar or process your booking. It is in our legitimate interests to be able to use reputable third party providers to facilitate the booking of our events and the hosting of our webinars. We consider the use of your personal information is in our legitimate interests and is proportionate as we only pass personal information through this software where required for us to be able to provide the service.

If you have registered to attend one of our events and we are co-hosting the event with a third party organisation.

We will share your personal information with the co-host(s) of the event as they will be a joint data controller of your data. We will only share your registration information with them. We consider the use of your personal information is in our legitimate interests to make sure that both us and the co-host organisation(s) know who will be attending the event;

If you have agreed to fill in a survey about us.

We use third party software QuestionPro to administer our surveys. We will pass your personal information through this software so that we can give you access to the survey. We consider it is in our legitimate interests to be able to use reputable third party providers to facilitate us obtaining feedback about our software and our relationships with our members. We consider the use of your personal information is proportionate as we only pass personal information through this software as required for us to carry out the survey.

With organisations who provide support for our internal systems or develop our website.

We use reputable third parties to provide us with support for our internal systems and also to develop and improve our website. We will share your personal information with them to the extent that they need to access our systems and website to be able to provide their services. We consider it is in our legitimate interests to be able to use reputable third party providers to facilitate us having well-functioning IT systems and website and to fix any issues with our IT systems and website.

With an organisation that we merge with or transfer our business assets to.

In the unlikely event that we sell all or part of our business, or merge with another organisation, we may transfer personal information that we have collected as described in this notice, along with our other business assets, to the organisation that we are selling to or merging with.

With entities, organisations or individuals outside Lhasa for legal reasons.

We will share your personal information with entities, organisations or individuals outside Lhasa where this is strictly necessary to: comply with any law, rule, regulation, legal procedure or governmental request that is applicable to us; obtain legal advice; enforce the terms of our agreements; prevent or detect fraud; otherwise as permitted or required by law.

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8. Will we transfer your personal information outside the UK/EEA?

We store your personal information in the United Kingdom or in countries within the European Economic Area. We will only transfer your personal information outside the EEA where we share your data with Lhasa Limited Inc. in the USA, to pass your personal information to our distributors in China, Japan and Korea, or to pass your personal information through the RegOnline, GoToWebinar or Live Chat third party software to facilitate our processing of event bookings, our hosting of webinars and responding to your questions.

We only transfer your personal information outside the EEA where we have a legal basis for doing so and where we ensure that your personal information is protected to the same standard as it would be protected in the UK.

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9. What rights you have over your personal information?

 You have a number of rights over your personal information, which are:

  • the right to make a complaint to the Information Commissioner’s Office (ICO) if you are unhappy about the way your personal information is being used – please refer to the ICO’s website for further information about this (https://ico.org.uk/);
  • the right to ask us what personal information we have about you and to have a copy of your personal information from us;
  • the right to ask us to correct any errors in your personal information;
  • the right to ask us to review and explain our legitimate interests to you;
  • the right to ask us to delete your personal information where: (i) we don’t need your personal information anymore; (ii) you have asked us to review and explain our legitimate interests to you and we don’t actually have a valid legitimate interest to do what we are doing; (iii) our use of your personal information is illegal; (iv) we have to delete your personal information to comply with our legal obligations; and
  • the right to ask us to restrict the use that we are making of your personal information where: (i) you don’t think the personal information we have about you is correct, so that we can check if it is correct; (ii) what we are doing with your personal information is illegal but you would rather we stop using your personal information rather than delete it; (iii) we don’t need your personal information anymore, but you need us to keep it so that you can exercise any legal rights; and (iv) you have asked us to review and explain our legitimate interests to you, so that we can check whether we actually have a valid legitimate interest to do what we are doing.

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10. Does this privacy notice cover websites I link to from this website?

Links within our website to other websites, such as Facebook and LinkedIn, are not covered by this privacy notice. You should review the privacy information on those other websites to find out how they may use your personal information.

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11. How we’ll tell you about changes to this privacy notice?

We keep our privacy notice under regular review. Any changes we make to our privacy notice in the future will be posted on this page and if the changes will have an effect on you or the way we use your personal information we will bring them to your attention by email where appropriate (e.g. if we have your email address as a contact at one of our member organisations). Please check back frequently to see any updates or changes to our privacy notice.

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12. How you can contact us?

If you have any questions about this privacy notice or about the ways we use your personal information, please contact us at info@etoxsys.com.

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SCHEDULE – DATA RETENTION POLICY

We have set out in this table how long we keep the different types of personal information that we have:

Type of personal information Why we have it How long we keep it and why
Your name, contact details and any other details you submit to us via our website. To respond to the query you have submitted via our website or to send you the information you have requested. We keep this for 2 years after the end of our communications with you. This is in case you get back in touch with us at a later date for further information so we can refer back to our previous discussions with you and for legal reasons in case of a contractual claim.
Your name, contact details and other details you provide when you register for one of our events or webinars. To register your application to attend one of our events or webinars. We keep this for 2 years after the end of our communications with you. This is in case you get back in touch with us at a later date for further information so we can refer back to our previous discussions with you and for legal reasons in case of a contractual claim.
Your IP address and any other information that identifies you that we collect when you use our website. To monitor how our website is used, the traffic we get through our website, and to help us to improve the user-experience of our website. We set out in our cookie policy how long we keep the information that we get through cookies. Please refer to our cookie policy.
Your name, job details and contact details. You are a contact of one of our member organisations from the point of view of administration of the member’s contract/account. We keep this for 6 years after your organisation’s membership has come to an end as long as you remain employed by the member. This is in order to facilitate any contractual issues that may arise post-termination of your organisation’s membership.
Your name, contact details and marketing preferences. To send you marketing where you have agreed that we can do so. We keep this for 2 years from the date you agree we can send you marketing. We will contact you every 2 years to see if you are still happy to receive marketing from us and will keep your information for as long as you agree to receive marketing from us.