Privacy Policy

We are James Leckey Design Limited (part of the Sunrise Medical Group) and are registered in Northern Ireland under company number NI023037. Our registered office and main trading address is 19c Ballinderry Road, Lisburn, BT28 2SA. Our VAT number is GB 366 4071 49. You can contact us by post at the above address, by email at hello@leckey.com or by telephone on +44 (0) 28 9260 0750

For the purposes of data protection laws in the UK, the data controller is James Leckey Design. We are registered as a data controller with the Information Commissioner’s office under number Z9379317

If you wish to contact us about our use of your personal data, you can email us at hello@leckey.com

or contact our Data Protection Officer at data.privacy@sunrisemedical.eu

We collect and process information about you in the following ways:

Information you give us:

This is information about you that you give to us by:

• Registering you as a new customer
• Managing our relationship with you
• Processing and delivering your quote or order
• Managing payments, fees and charges and the collection and recovery of money owed to us
• Requesting product or service information by phone, at a public event such as a trade show or exhibition, or on our website
• Contacting us by filling in forms on our website
• Replying to one of our marketing campaigns (e.g. filling out a response card)
• Delivering relevant content and advertisements to you and measure and understand the effectiveness of our advertising
• Requesting to receive email newsletters (e.g. subscribing via our website or filling out a form at a trade show event)
• Registering for a Leckey distributer account
• Corresponding with us by phone, email or otherwise
• Participating in one of our surveys, competitions or prize draws

Depending on the services you use on the James Leckey Design website, the information you give to us may include your forename, surname, email, address (for example your street, town, city, county or postcode), phone, date of birth, details of medical condition, disability, dependent’s contact and condition information, company name, and company account code.

You may decide to supply other personal data when you contact James Leckety Design (for example when you send us an email or phone our customer services team). If we require personal data during correspondence with you, we will explain to you why we would like this information and what we do with it at each stage.

If you are providing personal data to us on behalf of someone else, you must ensure that they have been provided and read this Privacy Policy before doing so.

You can visit the James Leckey Design website without providing any personal data.

Information we collect about you:

In addition to the information identified in the above section, when you visit our website, we will automatically collect the following information:

• Device Information

This includes information from or about your computer, phone or other device that you access our website from. Examples of the device information that we collect includes your operating system, IP address, browser type, device type and date and time of your visit.

• Information about your visit

We collect how you use and interact with our website during your visit. This includes the pages you visit, the products or services you enquired about, clickstream to, through and from our website (including the date and time), what you searched for, page response times, how long you visited, advertising identifiers and page interaction information (for example what was clicked). Depending on the consent that you give us, this information may or may not be associated with you. If you have consented to receive email newsletters from us, we will also record information regarding your interaction with it (such as whether you open, click on a link or forward the email message). If you do not want us to collect this information, you can unsubscribe from receiving email newsletters.

• Combined information

We combine personal data that we collect via the James Leckey Design website with information we receive from other sources (for example if you have consented to receive email newsletters when visiting James Leckey Design at a trade show, training event, opening an account with us or other similar activities). We will always explain how we intend to use your information before you give consent.

If you do not provide the information requested or automatically collected by us, we may not be able to provide you with the appropriate products or services (including website services) to the same standard or at all.

Where we receive personal data from third parties or other Sunrise Medical Group companies, we will inform you of the source of that data where required by law.

Special category personal data:

Some of the personal data we collect may constitute special category personal data under UK data protection law, including information relating to health, disability or medical conditions.

We only process special category personal data where it is strictly necessary and where a valid condition under Article 9 of the UK GDPR applies, together with an appropriate lawful basis under Article 6.

Depending on the context, this may include:

• Your explicit consent, for example where you voluntarily provide health or disability information via forms or correspondence;
• Processing necessary for the provision of healthcare or related services; or
• Processing necessary for employment, social protection or social security purposes, where permitted by law.

Where we rely on explicit consent, we will clearly explain what data is being collected, why it is needed, and how it will be used at the point of collection. You may withdraw your explicit consent at any time by contacting us using the details in the “Who Are We” section. Withdrawal of consent will not affect the lawfulness of processing carried out before consent was withdrawn.

We apply additional technical and organisational safeguards when processing special category personal data to ensure a high level of security and confidentiality.

We provide products and services intended to support both adults and children with disabilities. In some circumstances, we process personal data relating to children, usually where this is provided by a parent, carer, or person with parental responsibility.

Where we process children’s personal data, we do so with particular care and in accordance with the UK GDPR and the Age Appropriate Design Code.

We rely on consent from a person with parental responsibility where required and apply enhanced safeguards to ensure that children’s data is processed fairly, lawfully, and in their best interests.

If we become aware that we have collected personal data relating to a child under 16 without appropriate authorisation, we will take steps to delete that information as soon as possible. If you believe that a child under 16 has provided us with personal data, please contact us using the details set out in the “Who Are We” section.

Basis for collecting, processing and disclosing your personal data

This section explains how and why we process your personal data, as well as the legal basis on which we carry out this processing.

This section explains how and why we process your personal data, as well as the legal basis on which we carry out this processing.

• When you opt-in to receive permission-based email newsletters

Where you have subscribed to receive email newsletters from us about products, services, promotions, news, events and useful resources, we will process your personal data to provide you with this. Our legal basis for processing your personal data in this way is consent. You can withdraw your consent at any time by following the unsubscribe link on any of the email newsletters you receive from us.

• To provide you with the product or service information you request

Where you ask us to provide product or service information to you by email, it is necessary

to process your personal data in this way for the performance of a contract with James Leckey Design. This involves passing your personal data through our in-house technology to generate the email with the information and send it to you. We need to process your personal data in this way to provide you this service.

• To answer your questions and enquiries

Where you submit an online enquiry or send us an email, we need to process your personal data to respond to you. If appropriate, we will need to pass your personal data to other internal departments or third parties to help with, or reply to your enquiry. These internal departments and third parties are not authorised to use or disclose your personal data except as provided in this Policy. Please remember if you intend to send sensitive information (such as your disability) it is advisable to contact us by telephone rather than by email or via our website. It is necessary to process your personal data in this way for the performance of a contract with James Leckey Design. Please refer to ‘WILL WE DISCLOSE YOUR PERSONAL DATA TO ANYONE ELSE?’ for current third-party processors.

• To register and manage your online distributor account

If you register for a James Leckey Design distributor online account, we need to process your personal data to create and maintain your account, and to verify that you are an authorised James Leckey Design Distributor. Our use of your personal data in this way may include providing you with emails about password reminders, notification of website maintenance and account de-activation. Where you place an order for a refurbished product or reserve a demonstration product through your online account, we will process your personal data to provide these products to you. Our use of your personal data in this way includes passing your personal data through our in-house technology to process your order (for example, notifying Customer Services of your order and emailing you an order acknowledgement). It is necessary to process your personal data in this way for the performance of a contract with James Leckey Design.

• To enter you into a competition or prize draw

Where you submit your personal data for the purposes of entering a competition or prize draw, we will need to process your personal data to provide this service to you. Our reason for doing so is for the performance of a contract with James Leckey Design.

• To personalise your website and email experience

Where permitted by law, we process your personal data to personalise your experience on our website and in our communications. Our lawful basis for this processing is our legitimate interests in providing relevant content and improving user experience, except where consent is required by law (for example, where personalisation relies on non-essential cookies or similar technologies).

You have the right to object at any time to the use of your personal data for direct marketing and related profiling by contacting us using the details in the “Who Are We” section or by using the unsubscribe options provided in our communications.

• To make our website better

We use cookies and similar technologies, including analytics cookies, to understand how visitors use our website and to improve its performance. Where required by law, we will only place non-essential cookies on your device where you have given your consent through our cookie preferences mechanism. You can withdraw or amend your consent at any time by updating your cookie settings. Further information is available in our Cookie Policy.

• To make our website secure

Our legitimate interest for processing your personal data this way is for the purpose of making our website more secure. This may involve using your IP address to block you from using our website if your actions are disruptive or illegal. We also use it for general website administration and for internal operations including troubleshooting, data analysis, research, testing and statistical purposes.

• To ensure you don’t receive email communications from us when you opt-out

Where you have opted-out of receiving email communications from us, we will process your personal data to assign you to a suppression list. This involves holding on to limited personal data (such as your email). Our legitimate interest for processing your personal data this way is to ensure email communications are no longer sent after you have withdrawn consent.

• To create data sets

We will also process your personal data into an aggregate format where it can be used for reporting purposes (for instance to show the amount of product demonstration requests, measure the success of advertising campaigns or the number of visitors who subscribe to email newsletters). Our legitimate interest for processing your personal data this way is to evaluate the efficiency of marketing campaigns.

• If our business is sold, we will transfer your personal data to a third party

In the event that we buy or sell any business or assets, in which case we will disclose your personal data to the prospective seller or buyer of such business or assets (at all times in accordance with all applicable data protection laws); or if James Leckey Design or substantially all of its assets are acquired by a third party, in which case personal data held by James Leckey Design will be one of the assets transferred to the purchaser. Our legitimate interest for processing your personal data this way is to ensure our business can be continued by a purchaser. If you object to our use of your personal data in this way, the relevant seller or buyer of our business may not be able to provide services to you.

You will receive marketing communications from us if you have:

• Requested information from us or purchased goods or services from us; or
• If you provided us with your details and ticked the box at the point of entry of your details for us to send you marketing communications.

We will get your express opt-in consent before we share your personal data with any third party for marketing purposes. You can ask us or third parties to stop sending you marketing messages at any time by emailing us at hello@leckey.com  at any time.

We rely on the “soft opt-in” exemption under PECR where applicable and will provide an opt-out option at the point of data collection and in every marketing communication.

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

We will only use your personal data within James Leckey Design for the purposes for which it was obtained. We will not, under any circumstances, share or sell your personal data with any third party for their own marketing purposes, and you will not receive marketing from any other companies or other organisations as a result of giving your details to us. However, there are some situations where we use trusted providers to help us with administration of the services you have asked us to supply to you for example:

• Third-Party Product Providers

We need to share your personal data with third-party product providers to help us to deliver your product. These Third-Parties will only act under our instruction and we have a contract in place with them that requires them to keep your information secure and to only use it for the reason it was collected.

• Professional advisers

We need to share your personal data with professional advisors including lawyers, banks, auditors and insurers who provide consultancy, banking, legal and tax, insurance and accounting services.

• James Leckey Design distributors - We will always provide you the name of the distributor before disclosing your personal data and require your consent either verbally by phone or by email in order to do so.
• Other Sunrise Medical Divisions
• If your enquiry originates from a different country, we may disclose personal data about you to the relevant Sunrise Medical division responsible for that country to help with your enquiry or fulfil request. Unless they provide you with their own Privacy Policy, they may use your personal details for the purposes explained in this Policy.

We require all third parties to whom we transfer your data to respect the security of your personal data and to treat it in accordance with the law. We only allow such third parties to process your personal data for specified purposes and in accordance with our instructions.

Under some circumstances we may be required to disclose or share your information without your consent, for example if we are required by the police, the courts or for other legal reasons

In order to collect certain data described above, we use cookie technology on our website.

Cookies are small pieces of information that websites send to a visitor’s computer and are saved to your device to allow that website to store your interactions and recognise you when you visit. This allows us to provide you with a tailored experience when using the James Leckey Design website. Cookies are either session-based (they only last until you close your internet browser) or persistent (they remain on your computer for a specific amount of time or until you delete them). For example, James Leckey Design uses persistent cookies to remember when you return to our website or to track your activities when using our website. We may associate personal data with a cookie in those instances.

During your visit to the James Leckey Design website, you may notice some cookies that are not related to us. These may include Facebook, Google and YouTube. This Privacy Policy does not apply to these features.  Your interactions with these features are governed by the privacy policy and other policies of the companies providing them. You can opt out these third-party cookies on the James Leckey Design website by changing your cookie preferences.

For more information, please see our Cookie Policy

All personal data you provide to James Leckey Design is stored on our secure servers in the United Kingdom, Germany or in the United States. A variety of security techniques are used, including encryption and authentication, to help with the protection and maintain the availability, security and integrity of your personal data.

Please remember that data transmission over the internet is not guaranteed to be secure. James Leckey Design is committed to protecting your information in accordance with data protection requirements. These include:

• Restricting access to your personal data to only those who need to use it for the relevant purpose
• Keeping your personal data stored in encrypted form
• Prevent unauthorised access to IT systems by using firewalls
• Permanent monitoring of IT systems to detect and stop misuse of personal data

If you have a James Leckey website account, you have a username and password which enables you to access certain parts of our website. You are responsible for keeping this username and password confidential. We ask you not to share your username and password with anyone.

We will notify affected individuals and the ICO of personal data breaches where required by law.

Some of our service providers are located outside the United Kingdom, including in the United States, Europe and Australia. Where we transfer personal data outside the UK, we ensure that appropriate safeguards are in place to protect your personal data in accordance with UK data protection law.

These safeguards may include:

• The UK International Data Transfer Agreement (IDTA);
• The UK Addendum to the EU Standard Contractual Clauses; or
• Reliance on an adequacy decision issued by the UK Government, where applicable.

We assess international transfers on a case-by-case basis and implement additional safeguards where necessary.

We conduct Transfer Risk Assessments and implement supplementary technical and organisational measures where required.

You may obtain further information about these safeguards by contacting us using the details set out in the “Who Are We” section.

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. You can request our data retention table from hello@leckey.com

In some circumstances you can ask us to delete your data: see 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.

• Right to Access

You have the right to receive confirmation as to whether your personal data is being processed by us, as well as various other information relating to our use of your personal data. You also have the right to access your personal data which we are processing. If you wish to access the personal data we hold about you, please contact us using the details provided above.

• Right to Object

You have the right to object to our processing your personal data where we are processing your personal data based on our legitimate interests (as set out above) or you can show that your interests, rights and freedoms regarding your personal data outweigh our interest to process it. If you ask us to stop processing your personal data on this basis, we will stop unless we can demonstrate compelling grounds as to why the processing should continue in accordance with data protection laws.

• Right to withdraw consent

If you have given us your consent to use personal data (for example to receive email newsletters), you can withdraw your consent at any time by sending an email to the address provided in the “Who Are We” section. If you do choose to withdraw your consent, this will not mean that our processing of your personal data before you withdrew your consent was unlawful.

Where consent is related to email communications, you can exercise your right to withdraw consent by clicking on the “unsubscribe” link in the email communications we send you. Please remember that if you request to be emailed product information, made a course reservation, made an enquiry or registered for a Dealer account after unsubscribing, you will still receive emails about your request and other administrative messages even if you have opted out of receiving email communications.

• Right to Rectification

You have the right to require us to rectify any inaccurate personal data we hold about you, and have incomplete personal data that we hold about you completed by providing it to us. If you have registered for a James Leckey Design distributor account, you can update your Account information and preferences at any time by accessing your Account settings page on the website. 

• Right to Erasure

You have the right to require we erase your personal data which we are processing where at least one of the following grounds applies:

• The processing is no longer necessary in relation to the purposes for which your personal data was collected for
• Our processing of your personal data is based on your consent, you have subsequently withdrawn your consent and there is no other legal ground we can use to process your personal data
• You object to the processing as set out in the “right to object” section of this Policy and we have no overriding legitimate interest for our processing
• The personal data has been unlawfully processed and the erasure is required for compliance with a law to which we are subject.
• Right to Data portability

You have the right to receive your personal data that you have provided to us in a structured, standard machine readable format and the right to transmit such personal data to another controller if the legal basis for processing your personal data is the fulfilment of a contract or consent.

• Right to Restriction

You can ask us to restrict our processing of your personal data where:

• The accuracy of the personal data is being contested by you
• The processing by us of your personal data is unlawful (but you do not want the relevant personal data erased)
• We no longer need to process your personal data for the agreed purposes (but you want to preserve your personal data for the establishment, exercise or defence of legal claims)
• We are processing your personal data on the basis of our legitimate interest and you object to our processing on this basis and you want processing of the personal data to be restricted until it can be determined whether our legitimate interest overrides your legitimate interest.

Where any exercise by you of your right to restriction determines that our processing of your personal data is to be restricted, we will then only process the relevant personal data in accordance with your consent and, in addition, for storage purposes and for the purpose of legal claims.

• Automated Decision Making

Automated decision-making takes place when an electronic system uses personal data to make a decision without human intervention.

You have the right to ask James Leckey Design to:

• Give you information about our processing of your personal data for automated decision making purposes
• Request human intervention or challenge a decision where processing is done solely by automated processes
• Carry out regular checks to make sure that our automated decision making processes are working as they should.

James Leckey Design does not currently use automated decision making.

How to exercise your rights:

If you wish to exercise your rights, you can contact us using the details in the “Who Are We” section. Please note that while any changes you make will be reflected in active user databases instantly, we may retain all information you submit for backups, archiving, prevention of fraud and abuse, analytics, suppression, satisfaction of legal obligations, or where we otherwise reasonably believe that we have a legitimate reason to do so.

Please note, some of these rights only apply in certain circumstances and we may not be able to fulfil every request.

We may change this Policy from time to time.  If we do, we will post the revised version here and change the “Effective Date” listed at the top of this Statement before such changes take effect.  If we make changes to this Policy that impacts the purposes of processing your personal data, we will also inform you by email.

You may request further information about the way we manage your Personal Data or lodge a complaint by contacting us using the details above.

We will deal with any complains by investigating it, and providing a response to you within one month, provided that we have all necessary information and have completed and investigation required. In some cases, we may need to ask you to put your complaint in writing so that we are sure that we understand it, and may also need to ask you for further information or to verify your identity. In cases where further information, assessment or investigation is required, we will seek to agree an alternative timeframe with you.

If you are dissatisfied with the outcome, please contact us. Alternatively, you may take your compliant to the Information Commissioner’s Office via their website at https://ico.org.uk/your-data-matters/raising-concerns/ or write to them at:

Information Commissioner's Office

Wycliffe House

Water Lane

Wilmslow

Cheshire

SK9 5AF

You have the right to lodge a complaint with the Information Commissioner’s Office (ICO) at any time if you believe that our processing of your personal data infringes data protection law. You do not need to contact us before doing so, although we would welcome the opportunity to address your concerns first.