Privacy Policy

This Privacy Policy explains what personal data is collected when you use StartLocum (“StartLocum”) together with the services provided through our website and how such personal data will be used or shared.

By using the service, you promise us that:

1) You have read, understood and agreed to this privacy policy; and

2) You are/have reached the age of majority in the applicable jurisdiction.

If you do not agree or you are unable to make this promise, you must not use the Service. In such case, you must contact the support team via online chat or email to request deletion of your data, if any has been collected thus far during our engagement with you.

If you have any comments on this privacy policy, please email them to contact@startlocum.com

1. Data Controller

​B12 Medical LTD (DBA. StartLocum), a company registered in England Wales, company number 12951684 , with a registered office located at 192 King Cross Road, Halifax, England, HX1 3JP will be the controller of your personal data. Our nominated representative is Qasim Zahid and they can be contacted at qasim.zahid@startlocum.com

2. What we may collect

​We may collect and process the following data about you:

• Information you put into forms or surveys on our site at any time
• Your first name, maiden name, last name, username, or any similar identifier, along with your title when you register on our platform
• A record of any correspondence between us
• Business and personal addresses, email address, and telephone numbers
• How you interact with our website and utilise our services
• Your internet protocol (IP) address, login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technological details related to the devices you use to access our website
• We also gather, utilise, and disclose Aggregated Data for various purposes. Aggregated Data refers to statistical or demographic information that does not directly or indirectly disclose your identity, as it is not considered personal data under the law

Under GDPR we will ensure that your personal data is processed lawfully, fairly, and transparently, without adversely affecting your rights. We will only process your personal data if at least one of the following basis applies:

1. you have given consent to the processing of your personal data for one or more specific purposes;
2. processing is necessary for the performance of a contract to which you are a party or in order to take steps at the request of you prior to entering into a contract;
3. processing is necessary for compliance with a legal obligation to which we are subject;
4. processing is necessary to protect the vital interests of you or of another natural person;
5. processing is necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller; and/or
6. processing is necessary for the purposes of the legitimate interests pursued by us or by a third party such as our credit card payment processing, except where such interests are overridden by the fundamental rights and freedoms of the data subject which require protection of personal data, in particular where the data subject is a child.

3. Cookies

​All Cookies used by and on our website are used in accordance with current English and EU Cookie Law. Kindly visit our Cookies Policy for more details.

4. How we use what we collect

​We use information about you to:

• Present site content effectively to you.
• Provide information, products and services that you request, or (with your consent) which we think may interest you.
• Carry out our contracts with you.
• Allow you to use our interactive services if you want to.
• Tell you our charges.
• To customise your experience.
• Tell you about other goods and services that might interest you. We will also let other people do this, and we (or they) may contact you.
• To manage our engagement with you and provide you with customer support.
• To communicate with you regarding your use of our Service.
• To research and analyse your use of the Service.
• To enforce our TOS and to prevent and combat fraud.
• To comply with legal obligations.

If you are already our customer, we will only contact you electronically about things similar to what was previously sold to you.

If you are a new customer, you will only be contacted if you agree to it.

Please note: We don't identify individuals to our advertisers, but we do give them aggregate information to help them reach their target audience, and we may use information we have collected to display advertisements to that audience.

In addition, if you don’t want us to use your personal data for any of the other reasons set out in this section in 5, you can let us know at any time by contacting us at contact@startlocum.com , and we will delete your data from our systems. However, you acknowledge this will limit our ability to provide the best possible [products and] services to you.

In some cases, the collection of personal data may be a statutory or contractual requirement, and we will be limited in the [products and] services we can provide you if you don’t provide your personal data in these cases.

We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.

If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

5. Where we store your data

​We may transfer your collected data to storage outside the European Economic Area (EEA). It may be processed outside the EEA to fulfil your order and deal with payment. Whenever we transfer your personal data out of the EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

I. Where we use certain service providers, we may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe. For further details, see European Commission: Model contracts for the transfer of personal data to third countries .

II. Where we use providers based in the US, we may transfer data to them if they are part of the Privacy Shield which requires them to provide similar protection to personal data shared between the Europe and the US. For further details, see European Commission: EU-US Privacy Shield .

Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA

By giving us your personal data, you agree to this arrangement. We will do what we reasonably can to keep your data secure.

Payment will be encrypted. If we give you a password, you must keep it confidential. Please don't share it. Although we try to provide protection, we cannot guarantee complete security for your data, and you take the risk that any sending of that data turns out to be not secure despite our efforts.

We only keep your personal data for as long as we need to in order to use it as described above in section 5, and/or for as long as we have your permission to keep it. In any event, we will conduct a regular review to ascertain whether we need to keep your personal data. Your personal data will be deleted if we no longer need it.

6. Disclosing your information

​We are allowed to disclose your information in the following cases:

• If we want to sell our business, or our company, we can disclose it to the potential buyer.
• We can disclose it to other businesses in our group.
• We can disclose it if we have a legal obligation to do so, or in order to protect other people's property, safety or rights.
• We can exchange information with others to protect against fraud or credit risks.
• We can disclose it to out service providers.

We may contract with third parties and approved affiliate partners to supply services to you on our behalf. These may include payment processing, search engine facilities, advertising and marketing or auxiliary services. In some cases, the third parties may require access to some or all of your data.

Where any of your data is required for such a purpose, we will take all reasonable steps to ensure that your data will be handled safely, securely, and in accordance with your rights, our obligations, and the obligations of the third party under GDPR and the law.

7. Your rights

​Under the GDPR, you have the following rights:

• Right to be informed. You have the right to be provided with clear, transparent and easily understandable information about how we use your personal data and your rights. This is why we are providing you with the information in this Privacy Policy.
• Right of access. You have the right to obtain access to your personal data (if we are processing it) and certain other information (similar to that provided in this Privacy Policy). This is so you are aware and can check that we are using your personal data in accordance with data protection law.
• Right to rectification. You are entitled to have your personal data corrected if it is inaccurate or incomplete.
• Right to erasure. This is also known as ‘the right to be forgotten’ and, in simple terms, enable you to request the deletion or removal of your personal data where there is no compelling reason for us to keep using it. This is not a general right to erasure; there are exceptions.
• Right to restrict processing. You have the right to ‘block’ or suppress further use of your personal data in certain circumstances. When processing is restricted, we can still store your personal data, but may not use it further.
• Right of data portability. You have the right to obtain and reuse your personal data in a structured, commonly used and machine-readable format in certain circumstances. In addition, where certain conditions apply, you have the right to have such information transferred directly to a third party.
• Right to object to processing. You have the right to object to us processing your personal data for our legitimate business interests or for direct marketing purposes (including in each case any related profiling).
• Right to withdraw consent to processing. If you have given your consent to us to process your personal data for a particular purpose (for example, direct marketing), you have the right to withdraw your consent at any time (although if you do so, it does not mean that any processing of your personal data up to that point is unlawful).
• Right to make a complaint to the data protection authorities. You have the right to make a complaint to the Information Commissioner’s Office (ICO) if you are unhappy with how we have handled your personal data or believe our processing of your personal data does not comply with data protection law

To enforce any of the foregoing rights or if you have any other questions about our site or this Privacy Policy, please contact us at contact@startlocum.com

​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 may refuse to comply with your request in these circumstances.

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.

We try to respond to all legitimate requests within one month. Occasionally it may 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.

8. Links to other sites

​Please note that our terms and conditions and our policies will not apply to other websites that you get to via a link from our site. We have no control over how your data is collected, stored or used by other websites and we advise you to check the privacy policies of any such websites before providing any data to them.

9. Changes

​If we change our Privacy Policy, we will post the changes on this page. If we decide to, we may also email you.

10. Automated Decision-Making and Profiling

​10.1 In the event that we use personal data for the purposes of automated decision-making and those decisions have a legal (or similarly significant effect) on you, you have the right to challenge to such decisions under GDPR, requesting human intervention, expressing their own point of view, and obtaining an explanation of the decision from us.

10.2 The right described in section 11.1 does not apply in the following circumstances:

• the decision is necessary for the entry into, or performance of, a contract between the you and us;
• the decision is authorised by law; or
• you have given you explicit consent.

10.3 Where we use your personal data for profiling purposes, the following shall apply:

1. Clear information explaining the profiling will be provided, including its significance and the likely consequences;
2. Appropriate mathematical or statistical procedures will be used;
3. Technical and organisational measures necessary to minimise the risk of errors and to enable such errors to be easily corrected shall be implemented; and
4. All personal data processed for profiling purposes shall be secured in order to prevent discriminatory effects arising out of profiling.

11. Dispute Resolution

​11.1 The Parties will use their best efforts to negotiate in good faith and settle any dispute that may arise out of or relate to this Privacy Policy or any breach of it.

11.2 If any such dispute cannot be settled amicably through ordinary negotiations between the parties, or either or both is or are unwilling to engage in this process, either party may propose to the other in writing that structured negotiations be entered into with the assistance of a fully accredited mediator before resorting to litigation.

11.3 All negotiations connected with the relevant dispute(s) will be conducted in confidence and without prejudice to the rights of the parties in any further proceedings.

11.4 If the parties agree on a resolution of the dispute at mediation, the agreement shall be reduced to writing and, once signed by the duly authorised representatives of both parties, shall be final and binding on them.

11.5 If the parties fail to resolve the dispute(s) within 60 days (or such longer term as may be agreed between the parties) of the mediator being appointed, or if either party withdraws from the mediation procedure, then either party may exercise any right to seek a remedy through arbitration.

​11.6 Any dispute shall not affect the parties’ ongoing obligations under this Privacy Policy.

12. Age Limitation

We do not knowingly process personal data from persons under 16 years of age. If you learn that anyone younger than 16 has provided us with personal data, please contact us at contact@startlocum.com .

13. Data Retention

We will store your personal data for as long as it is reasonably necessary for achieving the purposes set forth in this Privacy Policy (including providing the Service to you), which includes (but is not limited to) the period during which you use our services. We will also retain and use your personal data as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.