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Privacy notice

90Ten Group Limited (“90Ten” / “we” / “us” / “our”) respects an individual’s right to privacy. This Privacy notice explains our approach to any Personal Information that we collect through an individual’s use of this website www.90ten.co.uk.

In particular, this notice describes:

  • Who we are.
  • How we collect Personal Information.
  • What Personal Information we collect.
  • How we use and disclose Personal Information, and the legal basis for use.
  • How long we keep Personal Information.
  • How we protect Personal Information.
  • International transfers of Personal Information.
  • An individual’s rights regarding their Personal Information.

“Personal Information” means any information or a set of information that identifies or is used by or on behalf of 90Ten to identify an individual.

Who we are

90TEN Group Limited (registered in England and Wales under company number 09301682) provides communications consultancies, that deliver global and international public relations, medical education and patient engagement programs for pharmaceutical and healthcare clients. 90Ten is a subsidiary of Envision Pharma Group Limited (registered in England and Wales under company no. 10117262) (“Envision Pharma Group”) and has a registered address of Envision House, 5 North Street, Horsham, West Sussex, England, RH12 1XQ, UK.

How we collect Personal Information
The Personal Information that we process includes:

  • When you download content from our website.
  • When you request information through our website including using the “Contact Us” or similar functionality for requests in relation to sales, support, or demonstrations.
  • When you engage with us for services
  • Technical information collected automatically through the use of cookies.

What Personal Information we collect
The Personal Information that we may collect includes:

  • Personal contact details such as name, title, addresses, telephone numbers, email addresses, employer, and job title.
  • Information provided to us regarding marketing preferences.
  • Technical information (such as Internet Protocol (IP) address) from visits to this website.  For more information, please see our Cookie Notice.
  • Any other information relating to individuals which they may provide to us without request.

How we use and disclose Personal Information, and the legal basis for use
We only use Personal Information when the law allows us to do so. The types of Personal Information that we use depends on the relevant circumstances.  The key types of Personal Information that we may use together with the relevant basis for such use and details of any third parties with whom such information is shared, are set out below.

Purpose for which we use Personal Information Legal basis for use Third party organizations with whom Personal Information may be shared
To send requested information about us and/or our services. Legitimate interests None
To provide content requested or downloaded from our website and to obtain feedback regarding such content. Legitimate interests None
To market our services including communicating about updates, news, newsletters and event invitations which are relevant to the individual’s activities and in line with stated preferences. Legitimate interests;
Consent		 None
To manage our relationship with our clients and potential clients. Legitimate interests;
Performance of a contract		 Third party vendors that we engage (where required).
To manage our relationship with our vendors and potential vendors. Legitimate interests;
Performance of a contract		 None
To provide and improve our website. Legitimate interests Web service providers and cookie providers.
To compile anonymous statistics including for managing our business performance and assessing client satisfaction to improve our services. Legitimate interest None
To enable us to provide webinars, meetings and events. Legitimate interest Third party service providers that we engage to support these activities.

“Third-party organizations” does not include any companies within Envision Pharma Group. However, we are an international business, and any Personal Information provided to us may be shared with and used by an entity within Envision Pharma Group (including those outside of the United Kingdom and European Economic Area (“EEA”).

Where necessary, or for the reasons set out in this notice, Personal Information may also be shared with regulatory authorities, courts, tribunals, government agencies and law enforcement agencies. While it is unlikely, we may be required to disclose Personal Information to comply with legal or regulatory requirements. We will use reasonable endeavors to notify the individual before we do this, unless we are legally restricted from doing so.

How long we keep Personal Information
Personal Information will be retained in accordance with our global data retention policy which categorizes all of the information held by us and specifies the appropriate retention period for each category of Personal Information. Those periods are based on the requirements of applicable data protection laws and the purpose for which the information is collected and used, taking into account legal and regulatory requirements to retain the information for a minimum period, limitation periods for taking legal action, good practice and our general business purposes.

How we protect Personal Information
A key principle of data protection legislation is that Personal Information must be dealt with securely by means of ‘appropriate technical and organizational measures’. This involves considering matters such as risk analysis, organizational policies, and physical and technical measures, all of which contribute to ensuring the confidentiality, integrity and availability of systems and processes. Envision Pharma Group is certified under ISO/IEC 27001:2013, which is an auditable international best practice standard that formally outlines requirements for an Information Security Management System.

International Transfers
We may need to transfer Personal Information to locations outside of the United Kingdom and EEA.

The level of information protection in countries outside the United Kingdom and EEA may be less than that offered within the United Kingdom and EEA. Where this is the case, we will implement appropriate measures (such as the EU standard clauses) to ensure that Personal Information remains adequately protected and secure in accordance with applicable data protection laws.

An individual’s rights regarding their Personal Information
Under certain circumstances, an individual has rights under certain data protection legislation with respect to their Personal Information which may include some or all of the following:

  • The right of access. Subject to certain exceptions, this is the right to request a description of the Personal Information we hold about an individual and how we use it.
  • The right to rectification. This is the right to require relevant Personal Information be corrected, if it is inaccurate or incomplete.
  • The right to erasure (right to be forgotten). This is the right to request the removal or deletion of Personal Information that we use about an individual, unless we are required to retain such data in order to comply with a legal obligation or to establish, exercise or defend legal claims, or if there is no compelling reason for us to continue using it.
  • The right to restrict use. This is the right to request that we restrict our use of Personal Information where: (i) such Personal Information is inaccurate, (ii) our use is unlawful, or (iii) we no longer need to use such Personal Information for a particular purpose and we are unable to delete the Personal Information due to a legal or other obligation.
  • The right to data portability. This is the right to request that we transmit the relevant Personal Information to a third party, provided that the individual provided such personal data to us and that we are using such personal data on the basis of that individual’s consent or in order to perform our obligations under contract with the individual, and the use is carried out by automated means.
  • The right to object. This is the right to object to us using Personal Information if the use is based on our legitimate interest. We will comply with requests unless we have a compelling legitimate basis for such use which overrides the individual’s interests and rights, or our use relates to the establishment or exercise of the defense of a legal claim.
  • The right to withdraw consent. If we are using Personal Information pursuant to the lawful basis of consent, the individual has the right to withdraw such consent at any time.
  • Automated individual decision-making and profiling. This is the right not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning you or similarly significantly affects you.

Such individual may also have the right to lodge a complaint in relation to our use of Personal Information with a local supervisory authority.

If an individual objects to our use of their Personal Information or withdraws their consent to our use after having initially provided it, we will respect that choice in accordance with our legal obligations, but it is likely this will make it impractical for us to deal with the relevant individual.

Further questions
Please direct any Data Subject Access Requests or further questions to the Envision Pharma Group Legal Department at privacy@envisionpharma.com or to our Data Protection Officer at either of the following:

By Email:

DPO.EnvisionPharma@twobirds.com

By Post:

Bird & Bird DPO Services SRL

Avenue Louise 235 b 1

1050 Brussels

Belgium

Attention: DPO for Envision Pharma Group

Changes to this notice

90Ten may revise or update this notice from time to time.

Last updated: October 2024