Privacy Policy

Orthofuse Ltd. is committed to respecting the privacy of, and rights in, the personal data we process and this policy has been put together in order to satisfy one of the Data Protection principles – the right to be informed of how and why we use your data.

References to we, our or us in this privacy policy are to Orthofuse Ltd CRN 15608491 with our registered office at Albany House, Claremont Lane, Esher, Surrey, United Kingdom, KT10 9FQ.

However, any correspondence for us should not be sent to this address but to the address set out in paragraph 9.

Your Personal Data and Information
1. When you deal with us you may provide us with personal information such as your name, address, nationality, gender, date of birth, telephone number(s), email address(s) and possibly also postal addresses, and in some cases information regarding your investment portfolios, investment appetite and approach to risk (‘personal information’). We will only use your personal information in accordance with the terms of this policy and the applicable data protection legislation, including the Data Protection Act 2018, the Data (Use and Access) Act 2025 and the UK-General Data Protection Regulation (together ‘the Data Legislation’).
2. Under UK-GDPR we, as a Data Controller, must adhere to seven data protection principals, which are (i) to process your data lawfully, fairly and in a transparent manner, (ii) only for the purposes set out below in this policy, (iii) only to the extent necessary, (iv) maintain only accurate data, (v) store and retain the data for only so long as we need to, (vi) protect and preserve data confidentiality, and (vii) be accountable to you by respecting the data subject rights set out in the Data Legislation (see 5 below).
3. We will only collect, use, and share your personal information where we are satisfied that we have an appropriate legal basis to do this.
Uses made of the information
1. We may use your personal information for the purposes of:
  1. if you are a potential investor in our business - to communicate with you and also to help us to make an assessment of both the lawfulness and appropriateness of taking any investment proceeds from you;
  2. If you are an employee, consultant or worker - in order to maintain our records, communicate with you, and assess your performance;
  3. If you are an applicant for a position with us - to be able to communicate with you and for the purpose of assessing your qualifications and acceptability for the position you have applied for;
  4. If you are a director of Orthofuse - in order to carry out the duties set out in the Companies Act and the common law;
  5. providing you with information, products and/or courses/ services that you request from us or which we feel may interest you, or undertaking surveys or market research, where you have consented to be contacted for such a purpose;
  6. notifying you about a change to product.
2. By using our Website and/or submitting personal information to us, you agree to us using your personal information in the way described in this privacy policy.
Lawful Basis
1. We can only process your personal information if we have a lawful basis for doing so. There are six available lawful basis which can be reviewed here https://ico.org.uk/for-organisations/uk-gdpr-guidance-and-resources/lawful-basis/a-guide-to-lawful-basis/.
2. The lawful basis we have for processing your data is for our legitimate interests. The legitimate interest is the furtherance of our business in circumstances where you have volunteered your personal data in order to either work with us or otherwise do business with us, or potentially invest in our business, and you acknowledge that the data will be used in accordance with the requirements of the Data Legislation. Inherent in our legitimate interest is the need to improve our product which is a health-care device that provides benefits to patients, and where there is a risk of adverse effects from invasive surgery to the vertebral column.
Retention, Updating and Removal of your Personal Information
1. Where you provide us with personal information, we may retain this information for future use, including:
  1. to further our legitimate interest,
  2. for required record keeping purposes, such as keeping a record of payments to employees and consultants for tax and accounting reasons,
  3. for exercising our rights and obligations, such as seeking payment from you or making payment to you (where/as applicable); and/or
  4. to provide on-going services, support, information or guidance where it can be reasonably assumed you have consented to receiving this support etc.
2. The duration for which we retain your personal information will differ depending on the type of information and the reason why it was submitted. However, in some cases personal information may be retained on a long-term basis: for example, basic personal information about you will normally be retained for so long as we need to for legal purposes will normally be retained for at least six years in accordance with usual commercial practice, tax, accounting and regulatory requirements.
3. You are responsible for ensuring that the personal information that you submit to us is accurate and up-to-date, and you update us on a regular basis if this changes. You can contact us using the details in paragraph 9 and we will update the relevant personal information for you.
Your Rights
1. This page from the Information Commissioner’s website sets out your rights with regard to how we use your data. https://ico.org.uk/for-organisations/uk-gdpr-guidance-and-resources/individual-rights/individual-rights/.
2. There are eight different ‘data subject’ rights as follows:
  - Right to be informed
  - Access right
  - Rectification right
  - Erasure
  - To restrict processing
  - Data portability
  - Right to object
  - Rights relating to automatic decision making (which we do not do).
Transfer outside UK, EU and SWISS FEDERATION
1. We will not transfer your personal data outside the UK, EU or Swiss Federation without your specific written consent.
Issues and Complaints
1. If you have any concerns about how your personal information is being used, please contact us as described in paragraph 9. This includes situations where you want to request the recertification or erasure of your personal information, restrictions to be placed around how we use your personal information, or to object to a particular use.
2. If you make a complaint about our handling of your personal information, it will be dealt with internally in the first instance and we will respond to you within 28 days of you submitting your complaint. If you are dissatisfied with this response you may take your complaint to the Information Commissioner’s Office. Please see https://ico.org.uk/for-the-public/raising-concerns/ for more information.
Changes to the privacy policy

We reserve the right to alter this privacy policy at any time. Such alterations will be posted on our Website. It is important that you read any such alterations as and when they are posted on the Website by us and should you object to any alteration, please contact us as described in paragraph 9.
Contacting us

If you need to contact us about this policy or any matters relating to the personal information we hold on you, you can write to us at Orthofuse, Albany House, Claremont Lane, Esher, Surrey, United Kingdom, KT10 9FQ or email us at GDPR@orthofuse.co.uk.
Further information
1. We hope that the contents of this privacy policy address any queries that you may have about the personal information we may hold about you and how we may use it. However, if you do have any further queries, comments or requests, please contact us as described in paragraph 9 above.
2. Whilst this privacy policy sets out a general summary of your legal rights in respect of personal information. More information can be found on the Information Commissioner’s website at https://ico.org.uk/for-the-public/