Privacy Policy

This is the privacy notice of LimeLight Health Ltd t/a Ekarnia (v1.1)

We respect your privacy and are determined to protect your personal data. The purpose of this privacy notice is to inform you as to how we look after your personal data when you visit our website (regardless of where you visit it from). We will also tell you about your privacy rights and how data protection law protects you.

1. WHO WE ARE AND IMPORTANT INFORMATION

2. THE PERSONAL DATA WE COLLECT ABOUT YOU

3. HOW WE COLLECT YOUR PERSONAL DATA

4. HOW WE USE YOUR PERSONAL DATA

5. WHO WE SHARE YOUR PERSONAL DATA WITH

6. INTERNATIONAL TRANSFERS

7. DATA SECURITY

8. DATA RETENTION

9. YOUR LEGAL RIGHTS

10. CHANGES TO THIS NOTICE AND YOUR DUTY TO INFORM US OF CHANGES

11. QUERIES, REQUESTS OR CONCERNS

1. WHO WE ARE AND IMPORTANT INFORMATION 

What is the purpose of this privacy notice?

This privacy notice aims to give you information on how we collect and process your personal data through your use of this website, including any data you may provide through this website when you sign up for updates, purchase a product or service, including use of the EKARNIA Platform.

This website and our products and services are not intended for children, and we do not knowingly collect data relating to children.

You must read this privacy notice together with any other privacy notice we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy notice supplements the other notices and is not intended to override them.

Data controller(s)

LimeLight Health Ltd. is the controller and responsible for your personal data (collectively referred to as "LimeLight Health Ltd.", "we", "us" or "our" in this privacy notice). Our contact details are 55 Station Road, Beaconsfield, England, HP9 1QL, support@ekarnia.com. For all data matters contact Carwyn Jones on Limelightdpo@clinicaldpo.com.

LimeLight Health is the controller and responsible for this website and the EKARNIA Platform.

Third-party links outside of our control

This 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 our website, we encourage you to read the privacy notice of every website you visit.

2. THE PERSONAL DATA WE COLLECT ABOUT YOU

Personal data, or personal information, means any information about an individual from which that person can be identified. You can find out more about personal data from the Information Commissioners Office.

We may collect, use, store and transfer different kinds of personal data about you when you use our website or create an account with EKARNIA, which we have grouped together follows:

Identity Data includes first name/last name/job title/place of work

Contact Data includes Work address/email address/ telephone numbers, billing address

Educational and biographical data include information about your work history, job title, specialisms, qualifications

Financial data include bank account and payment card details

Transaction data include details about payments to and from you

Technical data include IP address, login data, time zone setting and location, browser type and version, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access our website and products

Profile data include your preferences, feedback, interests, and any survey responses

Marketing data include your preferences in receiving marketing and or newsletters from us and any communication preferences collected

Use data include information about how you use our website and products via cookies or similar technologies

We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.

If you fail to provide personal data

Where we need to collect your personal data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with goods or services). In this case, we may have to cancel a product or service you have with us, but we will notify you if this is the case at the time.

3. HOW WE COLLECT YOUR PERSONAL DATA 

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

• Directly. You may give us your Identity and Contact Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:

  • Apply for our products or services;

  • Sign up to hear from us on our website;

  • Subscribe to our service or products;

  • Request marketing to be sent to you.

• Indirectly. We may collect your data via cookies or other technological means when you visit this website or use EKARNIA.

4. HOW WE USE YOUR PERSONAL DATA

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

• Performance of Contract this means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.

• Legitimate Interest this means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting Carwyn Jones – limelightdpo@clinicaldpo.com.

• Comply with a legal or regulatory obligation this means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.

GENERALLY, we do not rely on consent as a legal basis for processing your personal data other than in relation to sending third party direct marketing communications to you via email or text message. 

You have the right to withdraw consent to marketing at any time by contacting Carwyn Jones limelightdpo@clinicaldpo.com.

Automated Decision-Making and Profiling

We do not use your personal data for automated decision-making processes or profiling that would produce legal effects concerning you or similarly significantly affect you.

While we may use some automated processes to improve our services and user experience (such as analysing usage patterns to enhance platform functionality), these processes do not make decisions that would have significant impacts on you without human intervention.

We may use artificial intelligence and machine learning technologies to improve the functionality and performance of our SaaS platform. This may include: 

• Analysing usage patterns to enhance user experience and platform features

• Optimising system performance and responsiveness

• Providing personalised content recommendations based on your interactions

• Identifying potential technical issues to improve platform stability

These AI-powered processes primarily focus on product improvement and do not make automated decisions that would produce legal effects concerning you or similarly significantly affect you without human oversight.

The data used for these AI processes is pseudonymised where possible, and we implement appropriate safeguards to protect your privacy. You maintain the right to:

• Request information about how your data is used in our AI systems

• Object to the processing of your personal data for AI improvement purposes

• Request human intervention for any significant decisions that may affect you

We regularly review our AI systems to ensure they remain fair, transparent, and compliant with data protection regulations.

OUR COMMITMENT TO DATA PROTECTION PRINCIPLES:

Data Minimisation

We are committed to collecting and processing only the personal data that is necessary for the specific purposes we have identified. We regularly review our data collection practices to ensure we:

• Only collect the minimum amount of personal data needed to provide our services

• Limit access to personal data to those who need it for legitimate business purposes

• Regularly audit and delete data that is no longer necessary for the purposes for which it was collected

• Use anonymized or pseudonymized data whenever possible for analytics and system improvements

Privacy by Design and Default

We implement privacy by design and default principles throughout our organisation:

• We integrate data protection considerations into our product development lifecycle from the earliest stages

• New features and processes undergo privacy impact assessments before implementation

• We regularly train our development and product teams on privacy best practices

• We implement technical measures such as data encryption, access controls, and secure deletion protocols

• We maintain documentation of our privacy-enhancing measures as part of our accountability obligations

These principles help us ensure that privacy protection is not an afterthought but a fundamental component of how we design, develop, and deliver our services.

Purposes for which we will use your personal data.

We have set out below, in a table format, a description of all the ways we plan to use your personal data, with the legal bases we rely on to do so.

Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data.

For processing based on legitimate interests, we conduct balancing tests to ensure our interests do not override your fundamental rights and freedoms. You can request information about these assessments by contacting our Data Protection Lead.

Where we rely on your consent, you have the right to withdraw this consent at any time by updating your preferences in your account settings or by contacting us directly.

Marketing

We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising.

Promotional offers from us

We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you.

You will receive marketing communications from us if you have requested information from us or purchased goods or services from us and, in each case, you have not opted out of receiving that marketing.

EKARNIA

If you register as a user on EKARNIA your profile may be visible to Pharma procurement and business Intelligence customers of our services to assist you with your marketing and business development efforts. You can choose which information you wish to share and can update these at any time in your account settings. Your profile is not visible to other service providers on the EKARNIA platform.

Third-party marketing

We will get your express opt-in consent before we share your personal data with any company outside the LimeLight Health group of companies for marketing purposes.

Service Providers to EKARNIA 

We may use others to help us provide our products and services (e.g., IT maintenance, analysis, audit, payments, fraud detection, customer support, marketing, and development). They may have access to your information (e.g., the contents of a customer support request) as reasonably necessary to perform these tasks on our behalf and are obligated not to disclose or use it for other purposes. 

Our key service providers are: 

• Microsoft 365 (Office IT infrastructure & communications)

• Amazon Web Services

• Stripe Payments

• Outseta

Opting out

You can ask us or third parties to stop sending you marketing messages at any time by logging into the website and checking or unchecking relevant boxes to adjust your marketing preferences or by following the opt-out links on any marketing message sent to you or by emailing support@ekarnia.com at any time.

Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a product/service purchase or other transactions.

Cookies

You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly. For more information about the cookies we use, please see our cookie policy.

Change of purpose

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 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.

Change of Control or sale

We can also share your personal data as part of a sale, merger or change in control, or in preparation for any of these events. Any other entity which buys us, or part of our business will have the right to continue to use your data, but only in the manner set out in this Privacy Policy unless you agree otherwise.

5. INTERNATIONAL TRANSFERS

Your personal data may be processed both inside and outside the UK and European Economic Area (EEA) when you use our EKARNIA Platform. When we transfer your data outside the UK, EEA, or Switzerland, we implement appropriate safeguards to ensure your information remains protected:

• We use UK International Data Transfer Agreements (IDTAs) and EU Standard Contractual Clauses (SCCs) with all third-party processors located outside these regions. 

• We implement additional technical measures such as encryption and pseudonymization where appropriate. 

• We regularly review our international transfer mechanisms to ensure compliance with evolving regulations.

Ekarnia is intended for use by Life Sciences businesses around the world. This means that your data may be processed (without limitation) in countries like the United States, Canada, Australia, China, and India. Parties accessing Ekarnia  from outside the UK or EU are required to sign our Data Processing Agreement. Please email support@ekarnia.com to request a copy of our Data Processing Agreement and the specific safeguards we use with all third parties accessing the EKARNIA Platform here.

We only work with partners who can demonstrate compliance with UK and EU data protection standards, and we maintain the right to audit their compliance.

6. DATA SECURITY

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, including:

• Encryption: All data in transit is protected using encryption protocols, and sensitive data at rest is encrypted using industry-standard encryption

• Access Controls: We enforce strict role-based access controls, multi-factor authentication, and least privilege principles for all staff accessing personal data

• Monitoring: We maintain 24/7 security monitoring systems to detect and respond to unusual activities or potential breaches

• Regular Testing: We conduct periodic vulnerability assessments and penetration testing by qualified security professionals

• Staff Training: All employees undergo regular data protection and security awareness training

• Incident Response: We maintain a documented incident response plan to quickly address any potential data breaches

 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 regularly monitor our systems for possible vulnerabilities and attacks. However, despite these measures, no method of transmission over the Internet or electronic storage is 100% secure and we cannot warrant the security of any information that you send us. There is no guarantee that data may not be accessed, disclosed, altered, or destroyed by breach of any of our physical, technical, or managerial safeguards. You should use strong, unique passwords for your EKARNIA account and access the platform only from secure devices protected by two-factor authentication. You should not share your password to your account on EKARNIA with any other person.

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.

7. DATA RETENTION

We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

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 requirements.

By law we have to keep basic information about our customers including Contact, Identity, Financial and Transaction Data for six Years after they cease being customers for tax purposes.

In some circumstances you can ask us to delete your data: see Your legal rights below for further information.

In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.

8. YOUR LEGAL RIGHTS

Unless subject to an exemption under the data protection laws, you have the following rights with respect to your personal data: 

• The right to request a copy of the personal data which we hold about you;

• The right to request that we correct any personal data if it is found to be inaccurate or out of date;

• The right to request your personal data is erased where it is no longer necessary to retain such data;

• The right to withdraw your consent to the processing at any time, where consent was the lawful basis for processing your data; 

• The right to request that we provide you with your personal data and where possible, to transmit that data directly to another data controller, (known as the right to data portability), where applicable 9i.e. where our processing is based on consent or is necessary for the performance of our contract with you or where we process your data by automated means); 

• The right, where there is a dispute in relation to the accuracy or processing of your personal data, to request a restriction is placed on further processing;

• The right to object to our processing of personal data, where applicable i.e. where processing is based on our legitimate interests (or in performance of a task in the public interest/exercise of official authority); direct marketing or processing for the purposes of scientific/historical research and statistics).

If you are resident of countries outside the UK, EU, or Switzerland you may have additional rights which will endeavour to respect upon written notice from you of such additional rights. 

If you wish to exercise any of the rights set out above, please email Carwyn Jones – limelightdpo@clinicaldpo.com.

9. YOUR LEGAL RIGHTS

Account Closure

If you choose to close your account, your personal data will generally stop being visible to others on our services within 72 hours. We generally delete closed account information within 30 days of account closure, except as noted below.

We retain your personal data even after you have closed your account if reasonably necessary to comply with our legal obligations (including law enforcement requests), meet regulatory requirements, resolve disputes, maintain security, prevent fraud and abuse (e.g., if we have restricted your account for breach of our user agreement), or fulfil your request to "unsubscribe" from further messages from us. We will retain de-personalized information after your account has been closed.

No fee required – with some exceptions.

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 admin fee if your request is clearly unfounded, repetitive, or excessive. Alternatively, we may 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 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.

10. CHANGES TO THIS NOTICE AND YOUR DUTY TO INFORM US OF CHANGES

This version was last updated on 7th May 2025. Please keep us informed if your personal data changes during your relationship with us. It is important that the personal data we hold about you is accurate and current.

When we make material changes to this privacy notice, we will:

• Update the "last updated" date at the top of this privacy notice 

• Send an email notification to the email address associated with your account if the changes significantly affect your rights or how we use your data 

• For significant changes that require your consent, we may ask you to acknowledge and accept the updated terms before continuing to use our services

We encourage you to review our privacy notice periodically to stay informed about how we protect your personal information. Your continued use of our services after any changes to this privacy notice constitutes your acceptance of the revised terms.

If you disagree with any changes to this privacy notice, you may close your account and discontinue use of our services. Please contact us at support@ekarnia.com if you have any questions about changes to our privacy practices.

11. QUERIES, REQUESTS OR CONCERNS

To exercise all relevant rights, queries, or complaints (including a Data Subject Access Request) in relation to this policy or any other data protection matter between you and us, please in the first instance contact our Data Protection Lead on limelightdpo@clinicaldpo.com.

If this does not resolve your complaint to your satisfaction, you have the right to lodge a complaint with the Information Commissioners Office on 03031231113 or via email https://ico.org.uk/global/contact-us/email/ or at the Information Commissioner's Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF, England, UK.

To make a Data Subject Access Request, please:

1. Clearly state which right(s) you wish to exercise

2. Provide sufficient information to verify your identity (we may request additional verification)

3. Specify the personal data your request relates to

We aim to respond to all legitimate requests within one calendar month. If your request is complex or we have received multiple requests from you, we may extend this period by up to two additional months, but we will inform you of any such extension within the first month.

There is no fee for making a DSAR. However, we may charge a reasonable administrative fee if your request is clearly unfounded, excessive, or repetitive.