FUNDAMENTAL SURGERY PRIVACY NOTICE
We are FVRVS Limited (trading as Fundamental Surgery), a company incorporated and registered in England and Wales with company number 07370553 whose registered office is at 55 Baker Street, London, England, W1U 7EU, (“we”, “us”, “our”).
Fundamental Surgery software enables users to access simulated operating environments (“Simulations”) to practice medical procedures.
You are permitted to use the Fundamental Surgery software (the “Licensed Software”) and associated documentation provided or made available by us relating to the Licensed Software from time to time (including on the pages of our website) (“Documentation”) under a Customer Agreement (the “Master Agreement”) between us and the entity that has permitted you to use the Licensed Software (your “Sponsor”).
We provide the Licensed Software and Documentation for you to use on behalf of your Sponsor and primarily process the personal data provided by, or collected about, you on behalf of your Sponsor.
However, we will also process your personal data for own purposes in certain circumstances. This privacy notice sets out how we process your personal data.
- When you use the Licensed Software and participate in Simulations, we will process:
- the personal data that you provide to us, including your name, department, specialist area of surgery, location (country and state/region), level/role, e-mail addresses, phone numbers, and account username and password; and
- the personal data that we collect about you, including Simulations accessed, started and completed, Simulation scores (by procedure, occasion or stage), the number of times a Simulation is started and whether it is completed, and average time spent in a specific Simulation or group of Simulations (whether completed or aborted).
- We will use this personal data to validate that your Sponsor has a current valid licence to use the Licensed Software and that the Licensed Software is not already in use, to provide your Sponsor with details in respect of your use of the Licensed Software and participation in Simulations, and to comply with our obligations under the Master Agreement.
- We may also process:
- anonymised and/or aggregated data for research and product development purposes;
- your personal data for research, insight and product development purposes; and
- if you have consented to this, your personal data to send you marketing messages by email, phone, SMS or post. Some of these messages may be tailored to you, based on the information we hold about you. If you no longer want to receive marketing communications from us, you can click on the ‘unsubscribe’ link in any email or contact us by email or post at the addresses set out below.
- We rely on the following legal bases to process your personal data:
- because we have obtained your consent (e.g. if you consent to receive marketing from us); and
- because it is in our legitimate interests to maintain, improve and promote our products and services. We are always seeking to offer the most relevant Simulations.
- We may share your personal data with third parties in the following circumstances:
- with your Sponsor;
- with our suppliers and service providers working for us (e.g. data services providers); with third party research and product development partners (e.g. instrument manufacturers, pharmaceutical manufacturers, and healthcare providers and organisations);
- with our professional and legal advisors;
- in exceptional circumstances with law enforcement or other governmental authorities (e.g. to report a fraud or in response to a lawful request);
- in the event that we sell any business assets, to a potential buyer or investor (in which case, we will make reasonable attempts to ensure the buyer or investor will be bound by the terms of this privacy notice); and
- otherwise where we have your consent or are otherwise legally permitted to do so.
- We use service providers based around the world so your personal data may be processed in countries outside of your country or residence in countries where you may have fewer legal rights in respect of your data than you do under local law. Where we transfer personal data outside the European Economic Area, we will, as required by applicable law, ensure that your privacy rights are adequately protected by appropriate safeguards, such as the EU’s standard contractual clauses and the EU-US Privacy Shield. Please contact us if you would like more information about these safeguards.
- If you have any queries on any aspect of this privacy notice, please contact us by email at firstname.lastname@example.org or by post at 60 Grays Inn Road, London, WC1X 8LU.