Circuit Medical Limited – Privacy Policy
V2.0 – last updated 17/3/2025
- Introduction
Circuit Medical Limited (CML, us, our, or we) is the controller and responsible for your personal data collected through our website (https://circuitmedical.com) (the Website) and when you interact with us as an organisation (e.g. by contacting us), including where we may provide consultancy services to your organisation.
This Privacy Policy sets out how CML uses and protects your personal data in these circumstances. It does not cover how and why we process your personal data when we collect your personal data via our digital products.
We may collect different types of personal data from you depending on whether, and how, you use the Website. We may also collect your personal data indirectly. Please read this Privacy Policy carefully to understand what personal data may be collected depending on your interactions with us.
It is relevant to:
- Users of the Website.
- The staff of our clients and potential clients.
- Our suppliers and potential suppliers (and, where applicable, their staff).
- Job/internship applicants.
If you are the data subject in respect of any personal data we process, this Privacy Policy also explains what rights you have and how to get in touch with us if you need to.
The Website is not intended for children and we do not knowingly collect data relating to children.
About us
Our full corporate name is Circuit Medical Limited (Company Number: 09941617). Our registered office is at 71-75 Shelton Street, London, England, WC2H 9JQ.
We take privacy seriously. We have appointed a data privacy manager to oversee how CML processes personal data. If you have any questions about this Privacy Policy, please contact them using the details set out below:
- Email address: [email protected]
- Postal address: 71-75 Shelton Street, London, England, WC2H 9JQ
You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK regulator for data protection issues. You may also have recourse to the relevant data protection regulator in your jurisdiction.
We would, however, appreciate the chance to address your concerns before you approach the ICO or other regulator, so please contact our data privacy manager in the first instance.
Where this Privacy Policy refers to ‘personal data’ it is referring to data about you from which you could be identified – such as your name, your date of birth, your contact details and even your IP address.
By law, all organisations who process your personal data in the UK are obliged to process your personal data in certain ways and to ensure that you are given an appropriate amount of information about how they use it. You also have various rights to seek information from those organisations about how they are using your data, and to prevent them from processing it unlawfully.
For more information about these rights, please see section 9 of this Privacy Policy.
We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:
- Identity Data includes first name, last name, any previous names, marital status, title and gender.
- Contact Data includes email address and telephone numbers.
- CV Data for example your role and qualifications, work experience, education history data, your academic qualifications, and your interests as they may appear on a CV or other media.
- 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, device ID and other technology on the devices you use to access the Website.
- Website Usage Data includes information about how you interact with and use the Website.
- Marketing and Communications Data includes your preferences in receiving marketing from us and your communication preferences.
We also collect, use and share aggregated data such as statistical or demographic data which is not personal data as it does not directly (or indirectly) reveal your identity. For example, we may aggregate individuals’ Website Usage Data to calculate the percentage of users accessing a specific Website feature in order to analyse general trends in how users are interacting with the Website to help improve the Website and our service offering.
We use different methods to collect data from and about you including through:
- Your interactions with us. You may give us your personal data by filling in online forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
- correspond with us on behalf of your organisation in connection with the digital products and other services we provide to our clients (whether or not your organisation is a client of ours);
- request marketing to be sent to you;
- offer your or your organisation’s services to us;
- apply for a job with us; or
- give us feedback or contact us.
- Automated technologies or interactions. As you interact with the Website, we will automatically collect Technical Data and/or Website Usage Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies and other similar technologies. We may also receive Technical Data about you if you visit other websites employing our cookies. Please see our cookie policy at the end of this document for further details.
We will only use your personal data when the law allows us to. For ease, set out below in tabular format are the legal bases on which we rely when we collect your personal data and the types of personal data we collect in respect of each purpose.
Legal obligation
We may use your personal data where it is necessary for compliance with a legal obligation that we are subject to.
Legitimate interests
A ‘legitimate interest’ is a legal basis under the UK GDPR to lawfully process personal data. These can be both our legitimate interests and the interests of others and society as a whole.
We largely rely on legitimate interests as our legal basis to process personal data as part of our activities. We keep this under review.
We have set out in the below table where we rely on legitimate interests and what those interests are.
| Purpose/Use | Type of data | Legal basis |
| To discuss with you and/or your colleagues how our services might benefit your organisation | (a) Identity
(b) Contact |
Necessary for our legitimate interests (to gain business and expand our client base) |
| To provide our services to your organisation (including to manage payments and debts) | (a) Identity
(b) Contact |
Necessary for our legitimate interests (to provide our services to our customers; to perform our contractual obligations and preserve or enforce our rights; to process payments and recover money owed to us) |
| To manage our relationship with your organisation which will include:
(a) notifying you about changes to our contractual terms or privacy policy; and (b) dealing with your requests, complaints and queries |
(a) Identity
(b) Contact |
Necessary for our legitimate interests (to keep our records updated and manage our relationship with the organisation you work for) |
| To receive you or your organisation’s goods or services | (a) Identity
(b) Contact (c) CV |
Necessary for our legitimate interest (to receive goods or services from suppliers) |
| To consider you or your organisation’s offer to supply goods or services to us | (a) Identity
(b) Contact (c) CV
|
Necessary for our legitimate interests (to identify potential suppliers to receive goods or services from) |
| To consider your application for a job with us | (a) Identity
(b) Contact (c) CV
|
Necessary for our legitimate interests (to consider job applicants) |
| To receive communications from you via the Website | (a) Identity
(b) Contact
|
Necessary for our legitimate interests (to receive communications via the Website about our products and services) |
| To administer and protect our business and this Website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data) | (a) Identity
(b) Contact (c) Technical (d) Website Usage |
Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise) |
| To deliver relevant Website content and online advertisements to you and measure or understand the effectiveness of the advertising we serve to you | (a) Identity
(b) Contact (c) Website Usage (d) Marketing and Communications (e) Technical |
Necessary for our legitimate interests (to study how our client organisations use our products/services, to develop them, to grow our business and to inform our marketing strategy)
|
| To use data analytics to improve the Website, products/services, customer relationships and experiences and to measure the effectiveness of our communications and marketing | (a) Technical
(b) Website Usage |
Necessary for our legitimate interests (to define types of clients for our services, to keep the Website updated and relevant, to develop our business and to inform our marketing strategy) |
| To send you relevant marketing communications | (a) Identity
(b) Contact (c) Marketing and Communications |
Necessary for our legitimate interests (to carry out direct marketing, develop our products/services and grow our business)
|
| To respond to a request from a legal authority | (a) Identity
(b) Contact (c) Website Usage (d) Marketing and Communications (e) Technical (f) CV |
Necessary for compliance with a legal obligation |
Direct marketing
You may receive marketing from us if you:
- have enquired about our services on behalf of your organisation directly or via the Website and you have not opted out of receiving the marketing; and/or
- work for an organisation and your contact details are available publicly online.
We may also analyse your Identity, Contact, Technical, and Website Usage Data to form a view on which products, services may be of interest to you or your organisation so that we can then send you relevant marketing communications.
Third-party marketing
We will get your express consent before we share your personal data with any third party for their own direct marketing purposes. However, for the avoidance of doubt, we do not sell personal data to any third party for marketing purposes (their purposes or ours).
Opting out of marketing
You can ask to stop sending you marketing communications at any time by following the opt-out links within any marketing communication sent to you or by contacting us.
If you opt out of receiving marketing communications, you will still receive service-related communications that are essential for administrative or client service purposes.
Cookies
For more information about the cookies we use and how to change your cookie preferences, please see our policy at the end of this document.
We may share your personal data where necessary with the parties set out below for the purposes set out in the table above.
- Cloud computing service providers such as Amazon Web Services.
- IT service providers such as our internal consultants and sub-contractors that help us manage our products, services and this Website.
- External consultants and collaborators who provide us with consultancy, business development and product related services.
- Professional advisers including lawyers, bankers, auditors and insurers who provide consultancy, banking, legal, insurance and accounting services.
- Data monitoring and analysis service providers such as Google.
- 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 Policy.
These third parties are mainly our service providers that provide us with a variety of administrative, statistical, and technical services. We will only provide service providers with the minimum amount of personal data they need to fulfil the services we request, and we stipulate that they protect this data and do not use it for any other purpose. Within the meaning of the UK GDPR, these are our processors.
We require all third parties to respect the security of your personal data and to treat it in accordance with the law.
Whenever we transfer your personal data out of the UK to countries which have laws that do not provide the same level of data protection as the UK law, we always ensure that a similar degree of protection is afforded to it by ensuring that the following safeguards are implemented:
- We will only transfer your personal data to countries that have been deemed by the UK to provide an adequate level of protection for personal data, namely, the Republic of Ireland.
- We may use specific standard contractual terms approved for use in the UK which give the transferred personal data the same protection as it has in the UK. To obtain further information about these contractual safeguards, please contact us.
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.
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.
How long will you use my personal data for?
We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.
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, regulatory, tax, accounting or other requirements.
By law we have to keep basic information about our clients and their staff for six years after they cease being customers for tax purposes.
In some circumstances you can ask us to delete your data: see section 9 below for further information.
Where we anonymise personal data, we may use this information indefinitely without further notice to you.
You have a number of rights under data protection laws in relation to your personal data.
You have the right to:
- Request access to your personal data (commonly known as a “subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
- Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
- Request erasure of your personal data in certain circumstances. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
- Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) as the legal basis for that particular use of your data (including carrying out profiling based on our legitimate interests). In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your right to object.
- You also have the absolute right to object any time to the processing of your personal data for direct marketing purposes (as set out in section 4 above).
- Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
- Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in one of the following scenarios:
- if you want us to establish the data’s accuracy;
- where our use of the data is unlawful but you do not want us to erase it;
- where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or
- you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
If you wish to exercise any of the rights set out above, please contact us.
No fee usually required
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 could refuse to comply with your request in these circumstances.
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.
Time limit to respond
We try to respond to all legitimate requests within one month. Occasionally it could 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.
The Website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave the Website, we encourage you to read the privacy policy of every website you visit.
How we use Cookies
- To remember information that you have inputted into this website, so you don’t have to give it to us every time you visit the site.
- To find out if the emails we send out have been read, and if our customers are finding them useful
- To help us understand how users are using our services, so that we can identify and make improvements
- To help us personalise the website so that we can remember your preferences and settings.
- To deliver adverts that we think you will find interesting
Cookies we use on this Website
Strictly Necessary Cookies
Strictly necessary cookies allow you to use the features on this website. Without them, we would not be able to provide you with the services you request. An example of how these cookies are used would be: remembering your previous actions after you navigate back to a page, such the steps on a contact form.
Functionality Cookies
Functionality cookies record information regarding the choices that you have made on the site and allow us to tailor our website to you. For example, if you set your location, we use functionality cookies to store the location that you set and show it to you next time you visit.
Performance Cookies
Performance cookies are used for internal purposes to help us provide you with the best user experience we can. Information supplied to us by these cookies help us to understand how visitors use our website and enable us to improve how we display site content to you.
‘Performance’ cookies can be turned off, however doing so may negatively affect our ability to understand what people like or don’t like about our website so that we can make it better.
Advertising Cookies
We may use tracking pixels to assist with the delivery of our online advertising campaigns. This is made possible through the use of cookies.
The information we receive is anonymised and we are unable to reach out to you personally.
Third Party Cookies
Some pages on our website may use third party services or software, such as videos and maps. These third party services may set cookies on your device.
How to opt out of cookies
Accept or block cookies in your browser settings
You can block any cookies from any website by changing the setting in your browser that allows you to refuse some or all cookies (including strictly necessary cookies). If you do choose to block all cookies, you may not be able to access some or all of our website, and you may find that your ability to enjoy the site is negatively affected. For more information about how to disable cookies in your browser, please visit www.allaboutcookies.org
Opt-out of third party cookies
Where a cookie is provided by a third party, you may be able to use the third party’s own tools to block their cookies.
Opt-out of advertising cookies
You can choose to opt out of almost all advertising cookies by updating your preferences on the ‘Your Online Choices’ website. Do note, however, that opting out of these cookies will not prevent you from seeing adverts online, it will simply mean that they won’t be tailored to you.