Privacy Policy




This document refers to “personal data”

This is defined as information concerning any living person (a natural person who hereafter will be called the Data Subject) that is not already in the public domain.

The Data Protection Act (DPA), Privacy and Electronic Communications Regulations (PECR) and The General Data Protection Regulations (GDPR) which is EU wide and far more extensive, seek to protect and enhance the rights of data subjects. These rights cover the safeguarding of personal data, protection against the unlawful processing of personal data and the unrestricted movement of personal data within the EU. It should be noted that GDPR does not apply to information already in the public domain such as Companies House data.

Surgitrac Instruments Group Limited (Surgitrac Instruments UK) is pleased to provide the following GDPR information:

Surgitrac Instruments UK Limited is a Data Controller under the Data Protection Act 1998. This means that we are responsible for how and why your personal information is used.

Information about us is a site operated by Surgitrac Instruments UK Limited (“We”). We are registered in England and Wales as a limited company under company number 3005986 address 10 Wharfside Business Park, Irlam Wharf Road, Irlam, Manchester, M44 5PN.

We are registered with the Information Commissioners’ Office (ICO) number Z8262928.

Part of the Surgitrac Instruments Group.

We are committed to respecting your privacy and to complying with the Data Protection Act and any other relevant privacy laws. We have provided this Privacy Policy to help you understand how we collect, use and protect your personal information.

Who we are

Surgitrac Instruments is multinational company operating inside and outside of the EU.

We are a manufacturer and distributor of surgical instruments and operate in the B2B sector.

Personal Data

Surgitrac Instruments uses the information collected from you to provide quotations, make telephone contact and to email marketing or product information which we believe may be of interest to you and your business.

In you making initial contact you consent to Surgitrac Instruments maintaining a marketing dialogue with you until you either “opt out” (which you can do at any stage) or we decide to desist in promoting our services. Surgitrac Instruments also acts on behalf of its clients in the capacity of data processor.

Some personal data may be collected about you from the forms and surveys you complete, from records of our correspondence and phone calls and details of your visits to our website, including but not limited to personally-identifying information like Internet Protocol (IP) addresses.

Surgitrac Instruments may also collect statistics about the behaviour of visitors to its website.

Surgitrac Instruments’ website uses cookies, which is a string of information that a website stores on a visitor’s computer, and that the visitor’s browser provides to the website each time the visitor returns. uses cookies to help Surgitrac Instruments identify and track visitors and their website access preferences. Surgitrac Instruments website visitors who do not wish to have cookies placed on their computers should set their browsers to refuse cookies before using Surgitrac Instruments website.

Any information Surgitrac Instruments holds about you and your business encompasses all the details we hold about you and any sales transactions including any third-party information we have obtain about you from public sources and our own suppliers such as credit referencing agencies.

Surgitrac Instruments will only collect the information needed so that it can provide you with a service, we will not sell or broker your data, although there may be times when your information could be contained in data that Surgitrac Instruments has purchased from a third-party list broker.

Legal basis for processing any personal data

To meet Surgitrac Instruments contractual obligations to clients and to also respond to marketing enquiries.

Legitimate interests pursued by Surgitrac Instruments

To promote the products and services offered by Surgitrac Instruments and/or to market the services and/or products offered by Surgitrac Instruments to existing clients and those who have signed up to receive out marketing communications.


Through agreeing to this privacy notice you are consenting to Surgitrac Instruments processing your personal data for the purposes outlined. You can withdraw consent at any time by emailing the [email protected] or by phoning 0044 (0) 161 7767626 or writing to us.

Retention Policy

When you provide us with your personal information we will only retain it for as long as we need to, to make sure that we have dealt with all aspects of your enquiry. In practice, this means that we will keep your name and address for a minimum of 12 months if you make an enquiry or request a brochure or sample or quote.

Surgitrac Instruments will process personal data during the duration of any contract and will continue to store only the personal data needed for six years after the contract has expired to meet any legal obligations. We delete any personal data after six years.

Data storage

Data is held in the United Kingdom using different (multiple) servers. Surgitrac Instruments does not store personal data outside the EEA.

Your rights as a data subject

At any point whilst Surgitrac Instruments is in possession of or processing your personal data, all data subjects, have the following rights:

  • Right of access – you have the right to request a copy of the information that we hold about you.
  • Right of rectification – you have a right to correct data that we hold about you that is inaccurate or incomplete.
  • Right to be forgotten – in certain circumstances you can ask for the data we hold about you to be erased from our records.
  • Right to restriction of processing – where certain conditions apply to have a right to restrict the processing.
  • Right of portability – you have the right to have the data we hold about you transferred to another organisation.
  • Right to object – you have the right to object to certain types of processing such as direct marketing.
  • Right to object to automated processing, including profiling – you also have the right to be subject to the legal effects of automated processing or profiling.

In the event that Surgitrac Instruments refuses your request under rights of access, we will provide you with a reason as to why, which you have the right to legally challenge.

Surgitrac Instruments at your request can confirm what information it holds about you and how it is processed

You can request the following information:

  • Identity and the contact details of the person or organisation (Surgitrac Instruments) that has determined how and why to process your data.
  • Contact details of the data protection manager, where applicable.
  • The purpose of the processing as well as the legal basis for processing.
  • If the processing is based on the legitimate interests of Surgitrac  Instruments or a third party such as one of its clients, information about those interests.
  • The categories of personal data collected, stored and processed.
  • Recipient(s) or categories of recipients that the data is/will be disclosed to.
  • How long the data will be stored.
  • Details of your rights to correct, erase, restrict or object to such processing.
  • Information about your right to withdraw consent at any time.
  • How to lodge a complaint with the supervisory authority (ICO).
  • Whether the provision of personal data is a statutory or contractual requirement, or a requirement necessary to enter into a contract, as well as whether you are obliged to provide the personal data and the possible consequences of failing to provide such data.
  • The source of personal data if it wasn’t collected directly from you.
  • Any details and information of automated decision making, such as profiling, and any meaningful information about the logic involved, as well as the significance and expected consequences of such processing.

Third party lists

Surgitrac Instruments may purchase contact details from third party brokers in order to carry out marketing activities.

Surgitrac Instruments uses data purchases on ;licence from Wilmington Healthcare and uses this data in accordance with its terms of use relating to self managing email rights below.

Self-Managed Email 

The client is licensing data from WH which includes the provision of email addresses, for the purpose of carrying out their own healthcare email marketing campaigns
Electronic Communications: The parties acknowledge that you shall be a data controller with respect to the processing of email addresses provided by WH under
this Agreement. You shall comply with GDPR and the Privacy and Electronic Communications (EC Directive) Regulations 2003 in each case as amended,
consolidated, repealed and/or re-enacted from time to time. Without limitation to your general obligations as a data controller, you shall provide the following
information in each email sent to an email address provided by us to you: a. the full name of the Licensee; b. contact details for the Licensee including, but not limited
to, a valid address; and; c. a clear mechanism by which the target of the unsolicited marketing emails may opt-out of receiving further emails from you, at no cost. You
shall honour any opt-out requests received in relation to this agreement, pursuant to (c) above or otherwise and thereafter shall no longer send unsolicited marketing
emails to such email addresses.

Use of Email Addresses: Your email communications will be professionally relevant to the intended recipient in their current role.
You will not attempt to engage the recipient in any private capacity for any reason. Your email communications will be limited to a maximum of one per calendar
week, to each individual contact provided to you by us. The email addresses held by WH are corporate email addresses, which mean that the named recipient has
not given explicit consent to receive emails from the sender. As these are not “opt in” email addresses, we will only allow these email addresses to be used in
accordance with good email practice guidelines and in accordance with the advice of the Information Commissioner. Use of Email Platforms: Please note that
Mailchimp is not a recognised email platform, and as such Wilmington Healthcare cannot recognise hard bounces from this platform. Wilmington Healthcare will not
recognise hard bounces from any email platform where the terms and conditions of such an email platform do not allow for purchased data or third-party email data to
be used.


In the event that you wish to make a complaint about how your personal data is being processed by Surgitrac Instruments or its partners, you have the right to complain to Surgitrac Instruments. If you do not get a response within 30 days you can complain to the ICO.

The details for each of these contacts are:

Surgitrac Instruments UK Limited

Attention of the Business Director
10 Wharfside Business Park,
M44 5PN

[email protected]


Wycliffe House, Water Lane, Wilmslow, SK9 5AF

Telephone 0303 123 1113 or email: