Privacy Policy

Torbay Pharmaceuticals Limited takes data privacy seriously. We recognise and value the trust that individuals place in us when providing us with personal data and we are committed to safeguarding the privacy and security of personal data we may collect from visitors to our websites.

This Privacy notice aims to help you understand our personal data collection, usage, and disclosure practices by explaining:

What personal data we collect about you
How we obtain the personal data about you
How we use your personal data
Who we share your personal data with
Which countries we transfer your personal data to
How long we keep your personal data
How we protect your personal data
What rights you have in relation to your personal data
How we use cookies and similar technologies
How you can contact us

By providing your personal data to us (whether via one of our websites, by email, in person or over the phone), you agree to the processing set out in this Privacy notice. Further notices highlighting certain uses we wish to make of your personal data together with the ability to opt in or out of selected uses. may also be provided to you when we collect personal data from you.

Please note: This Privacy notice does not apply to, and Torbay Pharmaceuticals Limited is not responsible for, any third-party websites which may be accessible through links from this website. If you follow a link to any of these third-party websites, they will have their own privacy policies and you will need to check these policies before you submit any personal data to such third-party websites.

This Privacy notice aims to help you understand our personal data collection, usage, and disclosure practices by explaining:

1. What personal data we collect about you

We may collect and process different types of personal data in the course of operating our business and providing our services. These include:

Basic personal details such as your name and job title
Contact data such as your telephone number and postal or email address
Website usage and other technical data such as details of your visits to our websites or information collected through cookies and other tracking technologies
Personal data provided to us by or on behalf of our clients or generated by us in the course of providing our services
Recruitment related data such as your curriculum vitae, your education and employment history, details of professional memberships and other information relevant to potential recruitment to Torbay Pharmaceuticals Limited
Data that you may provide to us in course of registering for and attending events or meetings
Any other personal data relating to you that you may provide

2. How we obtain the personal data about you

We may collect or receive your personal data in a number of different ways:

Where you provide it to us directly, for example by corresponding with us by email, or via other direct interactions with us such as completing a form on our website
Where we monitor use of, or interactions with, our websites, any marketing we may send to you
Third party sources, for example, where we receive information about you from recruitment agencies for recruitment purposes
Publicly available sources – we may, for example, use such sources to help us keep the contact details we already hold for you accurate and up to date or for professional networking purposes (e.g., on LinkedIn)

3. How we use your personal data

We will only use your personal data where we are permitted to do so by applicable law. Under EU and UK data protection law, the use of personal data must be justified under one of a number of legal grounds. The principal legal grounds that justify our use of your personal data are:

Contract performance: where your information is necessary to enter into or perform our contract with you.
Legal obligation: where we need to use your information to comply with our legal obligations.
Legitimate interests: where we use your information to achieve a legitimate interest and our reasons for using it outweigh any prejudice to your data protection rights.
Legal claims: where your information is necessary for us to defend, prosecute or make a claim against you, us or a third party.
Consent: where you have consented to our use of your information (you will have been presented with a consent form or facility in relation to any such use and may withdraw your consent through an unsubscribe or similar facility).

We may use your personal data in the following ways. In each case, we note the grounds that we rely on to use your personal data:

To facilitate use of our websites and to ensure content is relevant – to respond to requests for information or enquiries from visitors to our websites and to ensure that content from our websites is presented in the most effective manner for you and for your device;	Legal grounds: legitimate interests (to allow us to provide you with the content and services on the websites), consent, contract performance.
For marketing and business development purposes – to provide you with details of new services, legal updates and invites to seminars and events where you have chosen to receive these. We will provide an option to unsubscribe or opt-out of further communication on any electronic marketing communication sent to you or you may opt out by contacting us as set out in section 11 below;	Legal grounds: legitimate interests, consent.
For research and development purposes – analysis in order to better understand your and our services and marketing requirements and to better understand our business and develop our services and offerings;	Legal grounds: legitimate interests (to allow us to improve our services).
For recruitment purposes – to enable us to process applications for employment submitted via the Careers section of our website and to assess your suitability for any position for which you may apply	Legal grounds: legitimate interests (to ensure that we can make the most appropriate recruitment decisions), contract performance (in order for us to take steps at your request to enter into a contract with you).
To fulfil our legal, regulatory, or risk management obligations – to comply with our legal obligations; to enforce our legal rights, to comply with our legal or regulatory reporting obligations and/or to protect the rights of third parties	Legal grounds: legal obligations, legal claims, legitimate interests (to cooperate with law enforcement and regulatory authorities).

Torbay Pharmaceuticals Limited may also share your personal data with a variety of the following categories of third parties:

Third parties who conduct marketing for us.
Our professional advisors (e.g., legal, financial, business, risk management or other advisors), bankers and auditors
Our insurers and insurance brokers
Third party service providers, to whom we outsource certain functions such as information and document management, office support, technology and IT services, word processing, photocopying and translation services (we have agreements in place with these service providers to protect the confidentiality and security of information (including personal data) shared with them)

We may also process your personal data to comply with our regulatory requirements or in the course of dialogue with our regulators as applicable, which may include disclosing your personal data to government, regulatory or law enforcement agencies in connection with enquiries, proceedings or investigations by such parties anywhere in the world or where compelled to do so. Where permitted, or unless to do so would prejudice the prevention or detection of a crime, we will direct any such request to you or notify you before responding.

5. Which countries we transfer your personal data to

As a global company, we cannot limit our processing of an individual’s personal data to the country in which that individual is based. In the course of providing our services, we will likely need to transfer personal data to locations outside the jurisdiction in which you provide it or where you are viewing our website. If you are based in the United Kingdom (UK) or European Economic Area (EEA), this will mean that your personal data may be transferred to, accessible from, and/or stored at, a destination outside the UK/EEA in which data protection laws may not be as comprehensive as in the UK/EEA.

Regardless of the location of our processing, we will impose the same data protection safeguards that we deploy inside the UK/EEA and implement appropriate measures to ensure that your personal data is protected in accordance with applicable data protection laws. Similarly, where a third-party service provider processes the personal data of EEA or UK residents on our behalf, we will ensure that appropriate measures are in place to ensure an adequate level of protection for your personal data, usually by including standard contractual clauses in our agreements with such third-party service providers (alongside other supplementary technical or contractual measures where necessary).

Please contact us as directed below if you would like to see a copy of the specific safeguards applied to the export of your personal data

6. How long we keep your personal data

We will retain your personal data for as long as is necessary to fulfil the purpose for which this data was collected and any other permitted linked purpose. If your personal data is used for two purposes, we will retain it until the purpose with the latest period expires; but we will stop using it for the purpose with a shorter period once that period expires. Our retention periods are also based on our business needs and good practice.

7. How we protect your personal data

We recognise that information security is an integral element of data privacy. While no data transmission (including over the Internet or any website) can be guaranteed to be secure from intrusion, we implement a range of commercially reasonable physical, technical, and procedural measures to help protect personal data from unauthorised access, use, disclosure, alteration, or destruction in accordance with data protection law requirements.

Information that you provide to us is stored on our or our service providers’ secure servers and accessed and used subject to our security policies and standards, or those agreed with our service providers.

Everyone at Torbay Pharmaceuticals Limited and any third-party service providers we may engage that process personal data on our behalf (for the purposes listed above) are also contractually obligated to respect the confidentiality of personal data.

8. What rights you have in relation to your personal data

If you have any questions about our use of your personal data, you should first contact us via the details provided in section 11 below. Under certain circumstances and in accordance with UK/EU or other applicable data protection laws, you may have the right to require us to:

provide you with further details on the use we make of your information
provide you with a copy of information that we hold about you
update any inaccuracies in the personal data we hold
delete any personal data that we no longer have a lawful ground to use
where processing is based on consent, to withdraw your consent so that we stop that particular processing
object to any processing based on the legitimate interests ground unless our reasons for undertaking that processing outweigh any prejudice to your data protection rights
restrict how we use your information whilst a complaint is being investigated

You may also ask us not to process your personal data for marketing purposes. We will inform you if we intend to disclose your information to any third-party service provider for this purpose. As indicated in section 4 above, you can exercise your right to prevent such processing at any time by using an unsubscribe facility or contacting us at customerservices@torbaypharma.com

We are also required to take reasonable steps to ensure that your personal data remains accurate. In order to assist us with this, please let us know of any changes to the personal data that you have provided to us by contacting us at customerservices@torbaypharma.com or by using any relevant facilities that we provide.

While it is our policy to respect the rights of individuals, please be aware that your exercise of these rights is subject to certain exemptions to safeguard the public interest (e.g. the prevention or detection of crime), our interests (e.g. the maintenance of legal privilege) and some of these rights may be limited (for example the right to withdraw consent) where we are required or permitted by law to continue processing your personal data to defend our legal rights or meet our legal and regulatory obligations.

If you contact us to exercise any of these rights, we will check your entitlement and respond in most cases within a month.

If you are not satisfied with our use of your personal data or our response to any exercise of these rights, you have the right to complain to the Information Commissioner / relevant Supervisory Authority (data protection regulator).

9. How we use cookies and similar technologies

Cookies are small text files which are stored on your browser or your computer’s hard drive when you visit a website. Our website uses cookies to distinguish you from other users and to improve your user experience. This also helps us to improve our website and to assess whether our online adverts reflect the interests of our website users by analysing user behaviour.

All cookies have expiration dates that determine how long they stay in your browser. There are 2 types of cookies that may be used during your visit to our website:

Session Cookies: These are temporary cookies that expire as soon as you close your internet browser; and
Persistent Cookies: These cookies have an expiration date and so stay in your browser until they expire or until you manually delete them.

Further information about the types of cookies used on our website and the reasons why is provided below:

Essential cookies	These cookies are necessary for the use of the features and services on our website. If you block these cookies, we cannot guarantee access to the services provided through our website or be sure how the website will perform during your visit.
Functional cookies	These cookies allow our website to remember choices you make, such as your log in details or language preferences, and any customisations you make to pages on our website during your visit.
Performance & Analytics cookies	These cookies help us understand how people use our website. They collect information such as which pages on our website visitors go to most often, which features they use, and which websites people have visited before they visit ours. We use this information to improve our website and provide a better user experience.
Advertising/ Targeting cookies	These are cookies that we use to remember which pages you’ve viewed (including which adverts you’ve been shown) on our website, and to show you adverts that we think might be of interest to you based on your browsing history on our website. We also use these cookies to limit the number of times you’re shown a particular advert, and to follow up with you if you partially complete an order for products or registration on our website.

Which cookies does this website use?

The table below sets out the cookies this website uses and why:

Cookie Name	First/ Third party	Type of Cookie	Purpose	Duration
_ga_##########	Third party	Performance & Analytics	This Cookie is dropped by Google Analytics, which we use to monitor our website’s performance and visitor numbers across all our pages. It does not and cannot personally identify you.	2 years
_ga	Third party	Performance & Analytics	This Cookie is dropped by Google Analytics, which we use to monitor our website’s performance and visitor numbers across all our pages. It does not and cannot personally identify you.	2 years

Changing your cookie settings

When you arrive on our site, you will be asked to confirm whether you accept or reject our use of cookies. You will also be given the option to adjust your “Cookies Settings” wherever you want to allow certain types of cookies but not others. Unless you have adjusted your browser settings prior to visiting our website, our system will set cookies as soon as you agree to their use.

Most web browsers will also provide an option to adjust your cookie settings (including disabling certain types of cookies or blocking cookies entirely) by updating your browser settings. Persistent cookies can also be deleted using your web browser settings.

Please note, if you use your browser settings to block all cookies (including essential cookies), or decline to agree to our use of cookies, you may not be able to access all or parts of our website.

10. How you can contact us

If you have any questions about this Privacy notice or how we process your personal data, please contact us by sending an email to: customerservices@torbaypharma.com or by writing to: Data Processing, Torbay Pharmaceuticals Limited, Wilkins Drive, Paignton, Devon, TQ4 7FG.