Embla Medical Privacy Notice

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, maiden name, last name, username or similar identifier, title, date of birth and gender. 
• Contact Data includes billing address, delivery address, email address and telephone numbers. 
• Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences. 
• 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 websites, applications and services.
• Usage Data includes information about how you use our website, products, applications and services.
• Professional Background Data includes information which is usually provided on a resume, such as academic qualifications, degrees, certifications, work history, professional achievements and experiences.

Where we need to collect personal data, and you do not provide that data when requested, we may not be able to use your data for the purposes set out in the section “Why do we use your personal data?” below. We will inform you if this is the case at the time.

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

• Direct Interactions. You may provide personal data by completing forms or by communicating with us by post, phone, email, in person, or through our website. This includes information you give us when you request services, provide feedback, or contact us with queries.
• Automated Technologies or Interactions. When you interact with our website or digital services, we may automatically collect Technical Data using cookies, server logs, and similar technologies. You can manage your cookie preferences at any time by clicking the cookie banner on our website.

Our websites and applications 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 our website, we encourage you to read the privacy notice of every website you visit and application you use.

We do not sell, trade, or rent your personal data to third parties under any circumstances.

To communicate with you

• Types of data: Identity, Contact, Profile, Usage, Marketing and Communications
• Basis for processing: Necessary for our legitimate interests (to take care of our relationship with you)

To show you content and advertisements that are relevant to you, and to see how well our advertisements are working

• Type of data: Identity, Contact, Profile, Usage, Marketing and Communications, Technical
• Basis for processing: Your Consent

To use data analytics to improve our websites, marketing, customer relationships and experiences

• Type of data: Identity, Contact, Technical, Usage, Profile, Marketing and Communications
• Basis for processing: Your Consent

To process job applications and maintain records of applicants

• Type of data: Identity, Contact, Professional Background
• Basis for processing: Your Consent

We only share your personal data with the entities within Embla Medical and with third parties, such as service providers who provide IT and system administration services, and professional advisers who provide consultancy, banking, legal, insurance and accounting services.

When we share your data with third parties, we ensure that they are contractually required to protect your data, use it only for agreed purposes and comply with data protection laws.

We keep your personal data only for as long as necessary to fulfil the purposes for which it was collected, such as managing our relationship with you, and meeting legal or regulatory requirements. In some cases, we may need to retain your data for longer, for example if there is an ongoing complaint, legal claim, or audit.

When deciding how long to keep your data, we consider factors such as the type and sensitivity of the data, the potential risks of keeping it too long or not long enough, and legal and professional rules that apply.

When you visit our premises, your image may be recorded by our Closed Circuit Television (CCTV) cameras.

The legal basis for that processing is our legitimate interest - we use CCTV systems to monitor and manage access to our buildings, ensuring their security and the safety of personnel and visitors, as well as to protect property and information housed on-site. We also use it to prevent, discourage, and investigate instances of unauthorized access, including breaches into restricted areas or information systems.

The purpose of the CCTV system is to provide a general visual overview of our premises. We do not use any facial recognition technologies or record sound.

In the event of an incident which prompts a formal investigation, the recorded footage from the CCTV system may be reviewed and, if deemed necessary, transferred to the relevant law enforcement or regulatory authorities to assist in the inquiry and support any legal proceedings. We do not use the footage for any other purpose than the ones explained in this section.

You may exercise any of the rights described in this section by contacting us at [email protected]. To make sure your data stays secure, we may ask you to prove your identity before we continue.

You have the right to: 

• Request access to your personal data. 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 cases. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. Please note that we may not always be able to comply with your request for 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 when we are relying on a legitimate interest and want to object to the processing because you feel it impacts your fundamental rights and freedoms.
• Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data if needed.
• Request the transfer of your personal data to you or to a third party. We will provide you, or a third party you have chosen, with your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to data kept in an electronic form which you initially provided with consent for us to use or where we used the data to fulfill a contract with you.

You can withdraw consent at any time where we are relying on consent to process your personal data, including data processing for marketing purposes. Please note that this will not affect the lawfulness of any processing that took place before you withdrew your consent. 

You have the right to make a complaint at any time to your country´s supervisory authority for data protection issues. We would, however, greatly appreciate the chance to deal with your concerns before you approach the supervisory authority, so please reach out to us in the first instance.

Being that Embla Medical's headquarters are in Iceland, the group’s main supervisory authority for data protection issues is the Icelandic Data Protection Authority (Persónuvernd) - Data Protection Authority. The Icelandic Data Protection Authority with its seat at Laugavegur 166, 105 Reykjavík, Ísland, can be contacted by e-mail: [email protected]. If you reside in the European Economic Area, you may also lodge a complaint directly with your local supervisory authority.