1. Introduction

CFT Healthcare and all of its subsidiaries globally (collectively ‘CFT Healthcare,’ ‘us,’ ‘we,’ ‘our’) understand the importance of ensuring that we collect, use, store, share, and dispose of (collectively ‘Use’) Personal Data about you in a fair, ethical, transparent, secure, and lawful way, adhering to industry best practices and regulatory standards.

This Privacy Statement describes what Personal Data we Use about you, how we Use it, and your choices and rights in relation to your Personal Data.

This Privacy Statement applies to our Use of your Personal Data in our interactions with you through our websites and social media sites (‘Sites’) that link to our Privacy Statement, or Personal Data about you that we may collect offline or receive from other parties.

Additional information on our privacy practices with respect to recruitment, certain products, services and solutions, may be provided in specific privacy statements and/or privacy sheets and/or other notices provided to you. To the extent that a specific statement, sheet or notice differs from this Privacy Statement, the specific statement, sheet or notice will take precedence.

This Privacy Statement is incorporated into, and part of, our Terms of Use that govern the use of our Sites.

If you have any questions about how we Use your Personal Data or would like to lodge a complaint, please contact us at contact@cftconsulting.us

2. Information we collect about you

Personal Data is any information that identifies you or relates to you.

We collect Personal Data about you from different sources including: Personal Data that we collect directly from you; Personal Data that we collect automatically about you as you use our Sites; and Personal Data that we collect from other sources, as described in this Privacy Statement.

The type of Personal Data that we collect about you varies based on our interactions with you.

• Personal Data that we collect directly from you.
  We collect Personal Data directly from you in the following circumstances:
  • When you use our Sites, we will collect information about your use of the Site and any information that you submit through that Site.
  • When you post to our social media pages, we may collect information about you from your post. We typically Use this information to respond to your inquiry and we do not usually associate this information with your account.
  • When you download white papers, reports, or other collateral, we may collect your name, contact information, job title, industry and location.
  • When you subscribe to our mailing lists or newsletters (we may collect your name, business contact information, email address, job title, the company you work for). When you register and attend our events, workshops, or seminars (we may collect your name, contact details such as phone numbers and email address, the company your work for, meal preferences, contact preferences, additional information as may be noted in our event forms, video and/or audio recordings of the event).
  • When you register and attend our events, workshops, or seminars, we may collect your name, contact details such as phone numbers and email address, the company your work for, meal preferences, contact preferences, additional information as may be noted in our event forms, video and/or audio recordings of the event.
  • When you request information from us, we may collect your name, contact information, job title, industry, location, and inquiry information. We may also obtain your feedback about our products, services and solutions when you
    respond to our surveys.
• Personal Data that we automatically collect.
  
  We, and our service providers, automatically collect the following information about your use of our Sites through cookies, web beacons, and other technologies including:
  • Your domain name
  • Your browser type and operating system
  • Web pages you view
  • Links you click
  • Language preferences
  • Demographic information such as your marketing preferences
  • Your IP address
  • The length of time you visit or use our Sites; and the referring URL, or the webpage that led you to our Sites
  • We may also collect your approximate location through collection of your IP address

Typically, we do not combine this information with other information that we have collected about you, including, other Personal Data.

• Personal Data we collect from other sources.
  
  We also collect Personal Data from other sources, as follows:

• Our CFT subsidiaries and affiliates: We may collect information about you from our subsidiaries and affiliated entities
• Our business partners: we collect information about you from our business partners with whom we offer cobranded products, services and solutions or engage in joint marketing activities
• Public databases or list enhancement services: we obtain information about you from public databases and list enhancement services. For example, we may use a service provider to verify mailing addresses. In some instances, our external service provider may perform mailing activities and we do not obtain the updated address information
• CFT Healthcare 3rd party service providers: where you have provided your contact data to a data service provider and agreed to your data being shared and used with their contractual partners

Special Categories of Personal Data includes information relating to your health, biometric or genetic information, religion, political beliefs, union membership, race or sexual orientation. We ask that you do not send or provide this information to us.

You can choose not to provide Personal Data to us, in certain circumstances. However, if your Personal Data is necessary to provide you with our products, services and solutions as required by our contract or to perform customer relationship management and/or administrative functions related to our contract, we may be unable to provide this Service without your Personal Data.

3. Our lawful basis for using information about you

When we Use your Personal Data in connection with the purposes set out in this Privacy Statement, we may rely on one or more of the following legal bases, depending on the purpose for which your Personal Data was collected and our relationship with you:

• Performance of contract:  To provide our products, services and solutions as specified in our contract.
• Our legitimate business interests:  To protect our legitimate business interests or those of a third party with whom we share your Personal Data. Whenever we rely on this lawful basis to Use your Personal Data, we assess our business interests to ensure that they do not override your rights. Additionally, you may have the right to object to our Use of your Personal Data in certain circumstances. See ‘Your Personal Data Rights’ section of this Privacy Statement.
• Compliance with a mandatory legal obligation: To ensure that we comply with applicable laws and regulations that govern and regulate how we do business.
• Consent:  Where you have provided consent to the Use of your Personal Data.

4. We may Use your personal data for

• Products, services, and solutions improvements. For example, to:
  • perform administrative and business functions and internal reporting
  • send administrative information to you and manage our business relationship with you
  • obtain feedback from you about our products, services and solutions including through client satisfaction surveys, in which event, we will only Use your Personal Data for the sole purpose of sending you a survey (through our third-party Customer Experience Management platform)
  • assess the performance of our Sites and to improve their operation
  • process your orders and provide you with our products, services and solutions
  • provide you with current information about our products, services and solutions
  • respond to your inquiries and fulfil requests made by you
  • update our records and keep your contact details up-to-date
• Provide you with marketing materials and to personalize your experience. For example to:
  • send marketing communications to you
  • provide you with a more personalized experience when you interact with us
  • enable you to subscribe to our newsletters and mailing lists
  • enable you to manage your marketing and cookie preferences
  • enable you to register for events, workshops and seminars hosted by us
• Achieving our business purposes and analyze information. For example, to:
  • establish, manage, and maintain our business relationship with you
  • to provide you with information regarding our products, services and solutions that may be of interest to you
  • compile usage statistics for our Sites
  • process and respond to privacy requests, questions, concerns and complaints
  • fulfil our contractual obligations
• Research and analytical purposes. For example to:
  • better understand how you use our Sites
  • improve our products, services and solutions
  • evaluate product, service and solution demand
  • administer surveys and questionnaires, such as for market research or client satisfaction requirements
• Compliance with our legal obligations. For example to:
  • investigate, prevent, or take action regarding illegal activities, suspected fraud
  • investigate violations of our Terms of Use or this Privacy Statement.

5. How we share information about you

We may share your Personal Data with the following parties for the purposes set out in this Privacy Statement (as applicable):

• Our CFT Healthcare subsidiaries and affiliates:  We may share information about you with our subsidiaries and affiliated entities for the purposes of operating our business, delivering, analyzing, improving, securing, and customizing our products, services and solutions, sending marketing and other communications related to our business, and for other legitimate purposes permitted by applicable law or otherwise with your consent.
• Authorized personnel and advisors:  We may share information about you with authorized CFT Healthcare personnel, agents and professional advisors of CFT Healthcare including legal advisors, auditors, and consultants to CFT Healthcare, where required.
• Our Service Providers:  We may share information about you with our Service Providers where we have subcontracted out parts of our products, services and solutions; where we engage third party applications, services or products; or where we engage third parties to administer CFT Healthcare internal business processes. Examples include processing of orders and credit card transactions, hosting websites, hosting seminar registration, assisting with salesrelated efforts or post-sales support, and providing customer support.
• Our business partners:  We may share information about you with our Business Partners with whom we jointly offer our products, services and solutions with respect to providing additional technical assistance in resolving the issue logged.

 We also may share Personal Data in the following circumstances:

• When you consent to the sharing of your Personal Data.
• In connection with the agreed terms of contract for the Service provided.
• In connection with, any joint venture, merger, sale of company assets, consolidation or restructuring, financing, or acquisition of all or a portion of our business by or to another company and to our advisors and the advisors of the other company in such transactions.
• To protect the rights, property or safety of CFT Healthcare, its business partners, you, or others, or as otherwise required by applicable law.
• To respond to a request for information by a competent authority in accordance with, or required by any applicable law, regulation or legal process; or where necessary to comply with judicial proceedings, court orders or government orders.
• In aggregated, anonymized, and/or de-identified form that cannot reasonably be used to identify you.
• For other legal reasons.

Any Service Providers or other parties with whom we share Personal Data are contractually required to implement appropriate physical, administrative and technical safeguards to protect Personal Data and are not permitted to use Personal Data for any purpose other than the purpose for which they are provided with or given access to Personal Data by us.

6. How we protect information about you

We are committed to protecting your Personal Data from accidental or unlawful destruction, loss, alteration, unauthorized access or disclosure by using a combination of physical, administrative and technical safeguards and contractually requiring our service providers to whom we disclose your Personal Data to do the same.

Please note that we cannot guarantee 100% security of your Personal Data, and we recommend that you take reasonable steps to protect your Personal Data. (e.g., by not sharing your passwords, choosing strong passwords and other measures).

7. How long we keep information about you

We keep information about you for as long as is necessary to fulfil the purpose for which it was collected, unless we are required to keep it for longer to comply with our legal obligations, resolve disputes, protect our assets, or enforce our rights. The criteria we use to determine how long we keep Personal Data includes:

• We are under a legal, contractual or other obligation to keep your Personal Data, or as part of an investigation for litigation purposes.
• Your Personal Data is needed to maintain accurate business and financial records.
• If there are automated means (if any) to enable you to access and delete your Personal Data at any time.
• You have consented to us keeping your Personal Data for a longer time period and we keep your Personal Data in line with your consent.
• Where Personal Data is contained in backups and/or archived copies and the removal, deletion, or destruction of the Personal Data is impossible for any reason, CFT Healthcare will retain such Personal Data in compliance with applicable Data Protection Laws.

In some instances, we may anonymize your information in accordance with our policies and may keep those anonymized records for longer periods.

8. Cross-border transfers

As a global company, we may transfer your Personal Data to countries where we, our Service Providers or Business Partners do business or to international organizations in connection with the purposes identified above and in accordance with this Privacy Statement.

When we transfer your Personal Data outside of the country from where it was originally collected to a third country or international organization we ensure that appropriate safeguards are in place, in line with applicable law, to ensure that your Personal Data is protected. You may obtain a copy of these safeguards by contacting us in accordance with the ‘How to contact us’ section below.

9. Your Personal Data rights​

You have rights under various data protection laws in various countries in relation to your Personal Data but we offer them irrespective of your location.

We are committed to upholding your rights, including:

• Right to be informed: you have a right to know what Personal Data we have about you, what we do with it, where we get it from, who we share it with, how long we keep it and why we need it
• Right of access: you have the right to access your Personal Data and obtain a copy of your Personal Data from us
• Right to rectification: you have the right to update inaccurate and/or incomplete Personal Data about you
• Right to be forgotten: you have the right to have your Personal Data erased, deleted or destroyed
• Right to data portability: you have the right to move, copy or transfer your Personal Data in a safe and secure way and reuse it for your own purposes
• Right to withdraw consent: you have the right to withdraw consent at any time regarding the Use of your Personal Data or in relation to direct marketing activities
• Right to restrict Use: you have the right to limit the way we Use your Personal Data
• Right to object: you have the right to stop or prevent us from Using your Personal Data. In particular, you can object to our Use of your Personal Data for direct marketing or the sale of your Personal Data
• Right to challenge automated decisions: you have the right to query and review decisions made about you using purely automated means (i.e. without human involvement or intervention)
• Right to complain: you have the right to make a complaint or raise a concern about how we Use your Personal Data. Complaints may be made directly to us or a relevant Data Protection Authority

Where you contact us, we may request specific information from you to verify your identify to enable us to search for and provide you with access to or a copy of your Personal Data, as permitted under applicable law. Where permitted under applicable law, we may charge you a reasonable fee to access your Personal Data; however, we will advise you of any fee in advance.

Individuals may hold additional rights in certain countries, which must be recognized and upheld.

In some situations, we may not be required to enforce these rights, where permitted under applicable law. We may also have a legitimate business interest to decline a request to action your rights.

You may contact us with requests, complaints or questions regarding these rights as set forth in the ‘How to contact us’
section, below.

10. Cookies and similar technologies

When you access our Sites, we and our service providers use cookies (small text files containing a unique identification number which are placed on your PC, laptop, tablet or mobile phone) and similar technologies including scripts, embedded web links, web beacons, Local Shared Objects (flash cookies) and Local Storage (HTML 5) Please refer to our Cookies Statement for more information on:

• what cookies are
• how we use cookies and similar technologies
• how third parties we partner with may use cookies and similar technologies
• your choices regarding acceptance of cookies and similar technologies

11. Links to third party websites and applications

Our Sites may provide links to the websites and/or applications of other parties. You may further interact with us through third party applications, owned and operated by the company you work for or other third parties such as LinkedIn, WhatsApp, Slack, Microsoft Teams, Facebook, Twitter, Google+, and other social media sites or applications.

We are not responsible for and make no representations or warranties in relation to the security, privacy practices and content of these third-party websites and applications. Please ensure that you read the applicable privacy and cookie policies before sharing Personal Data on these websites applications. Your use of such websites and applications is at your own risk.

12. Changing your consent preferences

In some instances, you may provide CFT Healthcare with consent to process your Personal Data such as where you have opted into receiving direct marketing communications from us. You can change your consent preference at any time, and manage your communication preferences by:

• Selecting the option to ‘Unsubscribe’ included in our communications with you.
• Updating your preferences in our online Preference Center.
• Sending an email to contact@cftconsulting.us

Once we have received and verified your opt-out request, we will comply with your request as soon as is reasonably practicable.

If you opt-out of receiving marketing related communications from us, we may still send you administrative messages or other required communications as part of your ongoing use of our products, services and solutions, which you are unable to opt-out of.

We do not provide your Personal Data to unaffiliated parties for their own direct marketing purposes or sell, rent, distribute or otherwise make Personal Data commercially available to any third party.

13. Children’s Privacy

We encourage parents and guardians to take an active role in their children’s online activities. We do not aim our Sites at children. If you believe that we may have collected Personal Data about someone who is under the applicable age of consent in your country without proper consent of the child’s parent or guardian, please contact us.

14. Updates to our Privacy Statement

We may update our Privacy Statement at any time. If we do, we will update the ‘Version’ and ’Last update’ information at the bottom of our Privacy Statement.

We encourage you to regularly review our Privacy Statement to stay informed about how we Use your Personal Data and privacy practices.

15. How to contact us

If you have any questions about how we Use your Personal Data, have a privacy concern, or wish to make a request or complaint relating to your Personal Data, please contact us at contact

These Privacy Policy were last updated on 14 June 2023.