Last updated: 01/06/2025
Thank you for downloading and using our 3D Scanning App ("App"). Your privacy and the security of your personal data are important to us. This Privacy Policy explains how we, Lohmann & Rauscher GmbH & Co. KG and L&R Medical UK Ltd (jointly referred to as “L&R”, “we,” “us,” or “our”), process your personal data when you use our App.
1. Who We Are – Joint Controllers
Lohmann & Rauscher GmbH & Co. KG and L&R Medical UK Ltd act as joint controllers under Article 26 EU/UK GDPR regarding the processing of personal data via the App. A Joint Controllership Agreement (“JC Agreement”) governs our respective responsibilities in ensuring the protection of your personal data.
• Lohmann & Rauscher GmbH & Co. KG
Irlicher Straße 55, 56567 Neuwied, Germany
Sandra Buchholz
Digital Transformation Manager
Westerwaldstrasse 4
Rengsdorf Rheinland-Pfalz 56579
Germany
Sandra.buchholz@de.lrmed.com
• L&R Medical UK Ltd
1 Wellington Court, Lancaster Park, Needwood, Burton upon Trent,
Staffordshire, DE13 9PS, UK
Contact: customersolutions@uk.LRMed.com
A summary of the essence of our Joint Controllership Agreement can be provided upon request.
2. App Service Provider – Data Processor
The App is developed, technically operated supported and hosted by Technologies UMAN 3D INC (“Processor”), located in Canada. The latter acts as a data processor on our behalf, under a Data Processing Agreement (“DPA”) concluded in accordance with Article 28 EU/UK GDPR.
3. What Data We Collect
We collect and process the following categories of personal data from users of the App (i.e., HCPs, healthcare professionals or authorized staff):
a. User Identification Data
• User First Name
• User Last Name
• User Email address
• Encrypted password
• Role
• Company Name
• L&R Customer ID
• Type of Membership
• Product catalogue
b. Device and Technical Data
• IP address
• Device type and operating system
• App version
c. Usage Data
• Logs of app access, Timestamps of log-ins and activities
• Configuration settings (language, preferences)
4. Purpose and Legal Basis of Processing
We process your personal data for the following purposes and legal bases:
Purpose:
To enable access to and use of the App (user authentication, functionality, maintenance)
Type of Data:
a. User Identification Data
b. Device and Technical Data
c. Usage Data
Legal Basis:
Art. 6 (1) (b) EU/UK GDPR – Performance of a contract (your App user account) or to take steps at your request prior to entering into a contract;
Art. 6 (1) (a) EU/UK GDPR – Consent for specific purposes
Purpose:
To ensure the security and integrity of the App (including logging, access control)
Type of Data:
a. User Identification Data
b. Device and Technical Data
c. Usage Data
Legal Basis:
Art. 6 (1) (f) EU/UK GDPR – Legitimate interest (in securing our systems)
5. No Use of Tracking Technologies
This App does not use cookies or other tracking technologies for marketing or behavioral analysis purposes.[A1]
6. Data Transfers Outside the EU/EEA/UK
L&R is an internationally operating group of companies. Due to partially existing matrix structure, your personal data may be shared with other companies within the group for internal administrative purposes (for example, for corporate strategy, compliance, auditing and monitoring, research and development and quality assurance), based on other legitimate interests within the meaning of Art. 6 (1) (f) EU/UK GDPR or in the context of commissioned data processing (Art. 28 EU/UK GDPR). Your personal data may be transferred internationally.
Your data may also be processed by service providers engaged by us (processors within the meaning of Art. 28 GDPR) outside the EU/EEA/UK, such as Technologies UMAN 3D INC, as mentioned above. The latter is located in Canada. Canada benefits from an adequacy decision under Article 45 EU/UK GDPR.
However, data transfers to countries that do not provide an adequate level of data protection within the meaning of Art. 45 EU/UK GDPR will only occur if appropriate safeguards within the meaning of Art. 46 (2) EU/UK GDPR (e.g., in the form of standard data protection clauses) are in place.
7. Data Retention
We retain your personal data for no longer than necessary for the purpose it was obtained and described above. L&R ensures personal data is securely disposed of when no longer needed to reduce the risk that it will become inaccurate, out of date or irrelevant.
The following criteria are used to determine data retention periods for your personal data:
a. Retention of user account data:
• Active user accounts: For the duration of the user account
• Inactive or deleted accounts: Up to 6 months after deactivation, unless retention is required for compliance with applicable laws or legal defense
b. Retention in case of queries: L&R will retain your personal data as long as necessary to deal with your queries.
c. Retention for legitimate interests: L&R will retain your personal data as long as necessary for our legitimate interests.
d. Retention of consent: L&R will retain your personal data until you unsubscribe or we receive notification of a change of profession or an email delivery failure.
e. Retention in the event of a complaint: L&R will retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.
f. Retention in compliance with the law: By law L&R will retain 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 we will 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 Rights
You have the following rights with respect to your personal data:
a. Request access to your personal data (commonly known as a "data subject access request"). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
b. Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
c. Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
d. Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
e. Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios:
• If you want us to establish the data's accuracy.
• Where our use of the data is unlawful but you do not want us to erase it.
• Where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims.
• You have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
f. Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
g. Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.
No fee usually required: 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 could 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 could 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.
9. Data Security
We and our processor have implemented appropriate technical and organizational measures to protect your personal data against unauthorized access, alteration, or disclosure. This includes encryption, access control, and secure development practices.
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. This includes encryption, access control, and secure development practices.
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 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.
We will never contact you via SMS or email requesting that you confirm or amend your personal (such as bank/payment details or passwords).
10. Changes to This Policy and your Duty to Inform us of Changes
We keep this Privacy Policy under regular review and may update it to reflect changes in legal requirements or the App’s functionalities. Therefore, we encourage you to review it regularly. Significant changes will be notified through the App.
It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.
11. Contact and Data Protection Officer
For privacy-related inquiries or to exercise your rights, please contact:
Lohmann & Rauscher GmbH & Co. KG:
FIRST PRIVACY GmbH
Konsul-Smidt-Str. 88
28217 Bremen
Germany
Tel.: +49 421 69 66 32-80
L&R Medical UK Ltd
Louise McNamara
Quality & Regulatory Coordinator
2 Wellington Court, Lancaster Park, Newborough Rd, Needwood
Burton on Trent Staffordshire DE13 9PS
United Kingdom
Tel.: +44 7527 117 811