Privacy Policy

We at Vitalograph are committed to ensuring that your privacy is protected, and to ensure that we comply with our obligations under all relevant Privacy Regulations including but not limited to Data Protection Act 2018, General Data Protection Regulations, California Consumer privacy Act 2018, Health Insurance Portability and Accountability Act 1996 and Act on Protection of Personal Information. The purpose of this Privacy Policy is to outline how we handle and safeguard all Personal Data provided to us via our websites.

By visiting Vitalograph websites and providing us with your Personal data as defined below, via the websites you are accepting to the terms and conditions detailed within this Privacy Policy. Should you not agree with this Privacy Policy, please follow the directions mentioned in different sections of this policy or leave the Vitalograph website.

The following definitions will apply throughout this Privacy Policy:

  • DPA 2018 means Data Protection Act 2018
  • GDPR means General Data Protection Regulations (both EU and UK);
  • CCPA means California Consumer Privacy Act 2018
  • Personal Data means any information relating to an identified or identifiable natural person (‘data subject’); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person;
  • Personal information under CCPA means information that identifies, relates to, or could reasonably be linked with you or your household. For example, it could include your name, social security number, email address, records of products purchased, internet browsing history, geolocation data, fingerprints, and inferences from other personal information that could create a profile about your preferences and characteristics.
  • Vitalograph; We, Us and Our means Vitalograph Ltd including its affiliated companies:
    • Vitalograph (Ireland) Ltd;
    • Vitalograph Inc;
    • Vitalograph GmbH;
  • Vitalograph websites include all global Vitalograph websites.

What Personal data do we process?

  • General Data including but not limited to,, name, job title, department and company;
  • Contact information including address, phone number and email address;
  • Demographic information such as postcode/zip code, preferences and interests;
  • Meta data and/or communication data such as IP Address;
    Browsing history on our Websites;
  • Other information relevant to customer surveys and/or offers;

Why do we process Personal Data?

We process Personal Data to allow us to understand your needs and provide you with a better service and in order to enable us to do the following:

  • To develop and improve our website services;
  • To facilitate marketing analysis;
  • To register customer purchased devices
  • To post the most relevant informational content
  • Device vigilance, including but not limited to the unlikely event of a recall


What is the Lawful basis for processing Personal Data?

In accordance with GDPR we will only process Personal Data where we have a legal basis to do so.  Under Article 6 of the GDPR the lawful bases we rely on for processing your Personal Data are as follows:

  1. Your consent. You are able to remove your consent at any time. You can do this by contacting;
  2. Contractual obligation;
  3. Legal obligation;
  4. Legitimate interest.

What are your Data Protection rights?

Under data protection law, you have rights which include the following:
Your right of access – You have the right to ask us for copies of your personal information.
Your right to rectification – You have the right to ask us to rectify personal information you think is inaccurate. You also have the right to ask us to complete information you think is incomplete.
Your right to erasure – You have the right to ask us to erase your personal information in certain circumstances.
Your right to restriction of processing – You have the right to ask us to restrict the processing of your personal information in certain circumstances.
Your right to object to processing – You have the the right to object to the processing of your personal information in certain circumstances.
Your right to data portability – You have the right to ask that we transfer the personal information you gave us to another organisation, or to you, in certain circumstances. In accordance with CCPA you have rights, which include the following:
Your right to know – you have the right to know about the personal information a business collects about you and how it is used and shared;
Your right to delete – you have the right to have the personal information collected from you deleted (with some exceptions);
Your right to opt-out – you have the right to opt-out of the sale of your personal information; and
Your right to non-discrimination – you have the right to non-discrimination for exercising your CCPA rights.

You are not required to pay any charge for exercising your rights. If you make a request, we have one month to respond to you.

If you wish to make a request, please contact us at or via post at Vitalograph Ltd, Vitalograph Business Park, Maids Moreton, Buckingham, MK18 1SW, United Kingdom.

If you are a US resident, please send postal correspondence to Vitalograph Inc, 13310 W 99th St, Lenexa, KS 66215, United States or via email to

How long do we retain your data?

In accordance with GDPR we delete your Personal Data as soon as we no longer have a legal basis for retaining it, and they are no longer needed to achieve the purpose for which they were originally collected; except where we have a legal obligation to retain said data.

Do we transmit Personal Data securely?

Data transmission over the internet cannot be 100% secure. However please be assured that we are committed to ensuring it is as secure as reasonably possible, with appropriate technical and security measures.

Your Personal Data and external website links

While visiting Vitalograph Websites you may come across links to external websites which are not operated by Vitalograph, when you click those links Vitalograph are no longer in control of the data protection practices and therefore are no longer responsible for how your Personal Data is managed. We suggest that you read the external website’s privacy policies.

Consent to the use of cookies.

For our website to function properly we use cookies. To obtain your valid consent for the use and storage of cookies in the browser you use to access our website and to properly document this we use a consent management platform: CookieFirst. This technology is provided by Digital Data Solutions BV, Plantage Middenlaan 42a, 1018 DH, Amsterdam, The Netherlands. Website: referred to as CookieFirst.

When you access our website, a connection is established with CookieFirst’s server to give us the possibility to obtain valid consent from you to the use of certain cookies. CookieFirst then stores a cookie in your browser in order to be able to activate only those cookies to which you have consented and to properly document this. The data processed is stored until the predefined storage period expires or you request to delete the data. Certain mandatory legal storage periods may apply notwithstanding the aforementioned.

CookieFirst is used to obtain the legally required consent for the use of cookies. The legal basis for this is article 6(1)(c) of the General Data Protection Regulation (GDPR).

Data processing agreement

We have concluded a data processing agreement with CookieFirst. This is a contract required by data protection law, which ensures that data of our website visitors is only processed in accordance with our instructions and in compliance with the GDPR.

Server log files

Our website and CookieFirst automatically collect and store information in so-called server log files, which your browser automatically transmits to us. The following data is collected:

  • Your consent status or the withdrawal of consent
  • Your anonymised IP address
  • Information about your Browser
  • Information about your Device
  • The date and time you have visited our website
  • The webpage url where you saved or updated your consent preferences
  • The approximate location of the user that saved their consent preference
  • A universally unique identifier (UUID) of the website visitor that clicked the cookie banner

How do we use Cookies?

A cookie is a small amount of data that is passed to your browser and stored on your computer ready to be retrieved at a later time by the website that originally sent it. The cookies we use allow our website to respond to you in a more personal way by remembering your preferences and customisations. We also use cookies to anonymously analyse how you use the website which helps us improve the user experience. No personal information about you is stored in cookies which our website uses.

If you would prefer not to allow the use of cookies then you may configure your browser to decline them. This may prevent you from taking full advantage of our website.

Vitalograph work with Lead Forensics to provide a tool for IP tracking. The IP tracking tool is used to recognise businesses. The Lead Forensics tool uses a tracking code to enable them to identify said businesses. The tracking tool only provides data that is already available in the public domain; it cannot and does not provide Vitalograph with any personal data, it only provides data relating to businesses that have visited the Vitalograph Website by using the IP address. We may use this data to contact the business for marketing purposes and/or to determine how they found their experience using our website. Should you require any further information it can be found at

Our website uses Google Analytics, this service is provided by Google LLC (“Google”). Google uses cookies to enable us to understand how you use our online services. For further information on how Google uses your personal data, and about how to manage your settings then please visit

Do we use Social Medial and how is your Personal Data protected on these platforms?

We are active on social media platforms, when you visit these platforms then the privacy practices of the platforms will apply. We will only process data when we respond to your communications; including but not limited to the following examples, if you send us a message via the platform or if we respond to a comment on our page.

Do we sell your Personal Data?

We will never sell, distribute or lease your personal data and/or information to third parties unless required by law to do so.

How do you contact us?

Should you need to contact us regarding our Privacy Policy then please do so using the following details:

FAO Data Protection Officer
Vitalograph Business Park,
Maids Moreton,
MK18 1SW

Privacy Policy Updates

We may from time to time be required to update this Privacy Policy. If we do implement any changes to this Privacy Policy then the updated version will be shown here, so please review frequently.

Last updated September 2023