YOUR.MD AS, incorporated and registered in Norway with the company number 999260993 whose registered office is at c/o Advokatfirmaet Simonsen Vogt Wiig AS, Filipstad Brygge 1, 0252 Oslo, Norway is offering its Services which may be branded as Healthily and/or Your.MD, via its subsidiary Your.MD Limited, incorporated and registered in the UK with the company number 08727263 WHOSE registered office is at Your.MD Ltd, 5th Floor, 43 Whitfield Street, London, W1T 4HD, UK (hereinafter collectively referred to as: ‘Your.MD’, ‘Healthily’, ‘we’ or ‘us’).
Your personal data is controlled by Your.MD Ltd who is the data controller in regard to its Services. Should you have any privacy-related questions, please contact us at email@example.com.
We use your data to personalise your experience when you use our Services. We also use your data to improve the safety and security of the Services we provide, and for the purpose of analytics, marketing and communications.
Contract performance. This covers data that is processed by us in order to provide you with Services that you have requested.
Consent. Where you have consented to our use of your personal data, including health data.
Legitimate interests. This covers data processed by us for the purposes that can be reasonably expected within the context of your use of our Services to pursue our legitimate interests, in order to improve our Services and your experience, for general social benefits to enable free access to health information, for marketing our Services, exploring business opportunities, for scientific research and to enable us to offer a safe and secure service.
HEALTHILY APP IN COLLABORATION WITH THIRD PARTY
The Healthily App collaborates with and is supported by third parties (the “Co-branding Party”) in certain areas.
Dettol, owned by Reckitt Benckiser. None of your data is shared with the co-branding party without first obtaining your explicit consent.
PROVIDING OUR SERVICES AND PERSONALISING YOUR EXPERIENCE
We use your data to understand your health so that we can provide relevant information personalised to your needs. You can personalise your experience by adding health data into your profile, completing assessments, or using other services we offer. We will use this data to personalise Services such as the Self-Assessment Tool, and to recommend health plans, track your symptoms, assess your health, and display articles of interest to you.
APPS for users who create a profile. Legal basis: contract performance and consent for processing health data. Data collected: as stated in ‘The data we collect’ section of this Policy.
Self-Assessment Tool (in old versions of our Apps and Web App known as Symptom Checker or chatbot). We use your data so the chatbot can calculate the most likely condition based on your reported symptoms. We might use the Self-Assessment Tool's results to show you care options (relevant OneStop Health™ providers in your location), or to offer follow-up notifications for relevant conditions, symptom tracking, Health Plans, and receive articles about specific topics. If you use the Self-Assessment Tool on behalf of someone else the collected data is used only for that specific assessment.
Coronavirus Risk Assessment. Health data provided while completing the self-assessment. Your outcome will not be used for the Self-Assessment Tool's calculation.
Health Library (Health A-Z). You can search the Health library and save your preferred articles. Some articles include a When to Worry feature, which helps you assess the need to visit a health professional. We might show you OneStop Health™ providers based on your Health Library search. For example, if you read an article about asthma, we will direct you to a OneStop Health™ provider that offers services for this condition. All the articles you will view will be stored in My Journal.
Health Journal with My Journal functionality. My Journal can store data about your wellbeing so you can track your symptoms over time (Trackers), access your pas assessments (Reports) and articles you have viewed (Articles). Assessments for third parties are not stored as reports, but we do save a record in our Technical Information logs. My Journal data will not be used in the Self-Assessment Tool’s calculation.
Your Profile. We do not create third-party profiles. You can decide to create a profile for yourself or use our Services without one. We use your in-app Profile data to allow you to use our Services and personalise your experience. You cannot create a profile for an additional user.
Manage Trackers. You can track your symptoms over time and sync with your health and fitness apps data to get useful insights relevant for your health. This data will not be used in the Self-Assessment Tool's calculation.
Health Background. You can share your health background with us by selecting one or more conditions from the list (for example, high blood pressure, coronary artery disease, chronic kidney disease, diabetes, asthma, etc). This data will be used for the Self-Assessment Tool.
Backup Your Profile. By signing in with your email/Google/Facebook account you give us permission to access and use your name and email address as outlined in this Policy. We use this data to enable you to access Your Profile from other devices. We recommend you sign out each time you leave the App so that your health data will be accessible only upon signing in.
Self-assessments. Health data provided while completing self-assessments and your subjective scores will not be used for the Self-Assessment Tool's calculation.
Notes. You can add your own data via the notes section. We don’t use this data for other features of our App, such as Self-Assessment Tool.
Push Notifications. We will send you push notifications based on the health data you provide when you use our Services. For example, we will use an assessment outcome to send you follow-up notifications for relevant conditions and to recommend that you track your symptoms for a period of time to see how they change. We will ask you if you are feeling any better and provide information relevant to your response. We will send you notifications to display articles based on your Health Library search and/or our OneStop Health™ providers available in your local area. We will also use your personal details - age, gender, and acquisition channel - to send push notifications related to these characteristics. For example, we will send you an article we think may be of interest to users in a certain age group. By enabling notifications, you will personalise your experience.
Health Plans. The data collected from answers given to questions asked in assessments can be used to provide you with the Personalised Health Plan. We will send you daily reminders for symptom tracking and bi-weekly notifications about health tips on how to improve your wellbeing.
Back Pain Hub. The data collected from answers given to questions asked during the safety assessment will be used only for safety assessment purpose, namely to assess and triage your symptoms before giving you access to Back Pain Hub. The information regarding Posture, Activity Levels, Back Exercises, Relaxation Exercises and Pain Medication will be used to enable you to track your habits and will not be used for Self-Assessment Tool’s calculation. We will send you daily reminders to track your habits only if you decide to opt-in to receiving notifications. Third party providers, available within Discuss and Healthily Loves sections, are OneStop Health™ providers, all verified by our team of doctors. We never share any of your health information with these providers.
We use the data we collect from you to present you with OneStop Health™ services in your local area which might be useful (for example, providers available in your country of residence or providers for a specific condition). For this service to be free, we need to track which users click on or see links to the providers. We use this data for analytics and billing purposes. When you click the link of a OneStop Health™ provider, you will be directed to their website and that provider will receive your IP address.
Data collected by OneStop Health™ providers may include personal information, but this is governed by their own privacy practices. The providers and other third-party websites or services may place cookies or other files on your computing or smart device, collect information or solicit personal information from you. We encourage you to be aware of the privacy practices of any third-party providers you interact with. We are not responsible or liable for your interaction with third-parties, the information requests initiated by them, or the subsequent use, treatment or dissemination of information you voluntarily choose to provide to them.
OneStop Health™ providers are also available within “Healthily Loves” and “Discuss” section of Back Pain Hub.
Discover. Within Discover you can access Health Library and OneStop Health™ marketplace and we process your data as described above.
Apple a Day. We show you health and wellbeing article a day. If the topic is of your interest and you click on it we will store this article in My Journal.
You can access our symptom checker on website through our web app.
Legal basis: legitimate interests, namely general social benefits to enable free access to health information. Data collected: as stated in ‘The data we collect’ of this policy, without any directly identifiable personal data.
Coronavirus (COVID-19) Symptom Mapper
Legal basis: legitimate interests, namely general social benefits to enable free access to health information and consent for processing health data. Data collected: as stated in ‘The data we collect’ of this policy, without any directly identifiable personal data. We use the information you provide in order to enable you to use the service and for research as described in Coronavirus (COVID-19) research section.
My Coronavirus Survey
Legal basis: consent for participation and processing of health data for research purpose, consent for sharing health data. Data collected: as stated in ‘The data we collect’ of this policy, without any directly identifiable personal data. We use the information you provide for research as described in Coronavirus (COVID-19) research section.
You can access our site here: https://www.your.md
Legal basis: legitimate interests, to improve our Site and your experience. Data collected: as stated in ‘The data we collect’ section of this policy, without directly identifiable personal data - namely, country, region, time zone, service preference, identifiers (IP address, analytics IDs) and applicable technical and analytical information.
Your COVID – 19 story
Legal basis: consent for processing health data for research purposes and/or for publishing withing platforms and/or social media. Data collected: anonymised health data.
If you decide to participate in our usability tests (“User Tests”) available on/via various third party providers, we will use your personal data and any other data provided through our Services (“Tester data”) only for the purposes of User Tests. Third party providers will not process Tester data for purposes or by other means than as instructed by Healthily/Your.MD or as otherwise necessary to provide the services. Tester data may include personal data, including personal contact information such as name, address, telephone number, email address or other personal demographic information and health data. Legal basis: contract performance and/or consent. Data collected: as stated in ‘The data we collect’ section of this policy.
FOR INTERNAL ANALYTICS
We collect data on how you use our Services so we can make improvements to the service we offer you. We use identifiers but do not link these to your name or email address, and we carry out troubleshooting, testing, research, and surveys. We also analyse your activities to understand how you use and interact with our Services. Legal basis: contract performance and/or legitimate interests, to helps us improve our Services (Site) and for general social benefits to enable free access to health informationfor users who do not create a profile. Data collected: Analytical information, Technical Information, as stated in ‘The data we collect’ section of this policy.
For example, we look at whether you click on a OneStop Health™ partner, conduct an assessment, view articles, use the health tracker, engage with notifications, and we will analyse the screens you use and if you added data into your profile. We check how you use our Services with the help of analytics providers (Google Analytics for Firebase, Google Analytics and Amplitude) and by processing Analytical Information (please see section “The data we collect” of this Policy). With the help of analytics ID assigned to you, we can use the data that you enter when talking to our chatbot (age and location, but not your name or email address) for our internal analytics and research. We do not process any information which could directly identify you in our analytical databases unless you use a service that requires us to do so. For example, we check how many users have finished an assessment or have visited our Site.
Surveys. We use surveys to ask for information/feedback/ which helps us improve our Services. You might be asked to participate in a survey via our Services. We will use your email address and/or telephone number for a survey, research, or testing if you choose to participate. If you confirm that you would like to receive notifications when we develop a specific feature, we will inform you when this feature is available. Or if you carry out a risk assessment survey, we will send you the results of the assessment via email. Your data will be transferred to Typeform, a third-party service provider we use for online surveys. We will not collect any information that could directly identify you when you carry out a survey. Legal basis: legitimate interests and/or consent, to helps us improve our Services. Data collected: your responses, your email and/or telephone number and IP address.
FOR SAFETY AND SECURITY
We usually process your data based on IDs attached to Your profile, so we do not see your name or email address. To safeguard your privacy, we store health data and data which could personally identify you in separate databases. We do store technical logs of your activities in the app. In line with best practice, only authorised staff members can access personal data, and only when required for user safety or critical systems issues. Legal basis: legitimate interests, to enable us to offer a safe and secure service. Data collected: As stated in Technical Information of this Policy; in ‘The data we collect’ section.
FOR MARKETING OR COMMUNICATION PURPOSES
We use your data to send you newsletters, respond to your requests, offer surveys, and for research and testing purposes. Legal basis: legitimate interests, for marketing our Services, exploring business opportunities and consent to show you relevant care options form third party providers. Data collected: email, full name (if provided), IP address or other identifier assigned by a third-party service provider.
NEWSLETTERS. We will use your email address to send you newsletters to update you about our Services, health tips, and more. If you're a business customer, we will send you emails to explore potential opportunities for collaboration. Your data will be transferred to MailChimp and Airship, a third-party service provider that we use for sending out newsletters.
EMAIL REQUESTS. We will use your email to respond to any queries you send to firstname.lastname@example.org and/or email@example.com. Your data will be transferred to Zendesk, a third-party service provider that we use for a support ticketing system. Please do not share any health data when sending emails to firstname.lastname@example.org and/or email@example.com as we do not respond to any case-specific health issues.
Facebook Lead Ads. We will use the information that you send us through a Lead Advert, which may consist of your email address and any additional information, to send you the selected content. The email address will be transferred to Mailchimp and Airship, a third-party service provider that we use for sending out newsletters.
CORONAVIRUS (COVID-19) RESEARCH
Legal basis: consent or legitimate interests, namely to support COVID-19 research that is also in line with our business interests to improve healthcare and selfcare by enabling access to free health information. We process the data in pseudonymised manner, meaning that we cannot directly identify you when processing this data and share the information for research purposes based on Article 9 (j) GDPR or consent in anonymised manner with third parties only for research purposes. Data collected: as stated in ‘The data we collect’ section of this policy, without directly identifiable personal data.
PARTICIPATION IN THIRD PARTY RESEARCH PROJECTS
If you decide to participate in a third party research project by providing your email address we will process this information on legitimate interests and/or consent basis and share this information with a third party researcher. Data collected: email address.
DIRECTLY IDENTIFIABLE PERSONAL DATA (only for users who decide to create a profile): Full name, email address, Facebook/Google account name and email address.
INDIRECTLY IDENTIFIABLE PERSONAL DATA: First name or nickname, age, gender, location (country, region - not specific enough to identify the street), time zone, service preferences, Messenger's information, acquisition channel), identifiers (profile ID attached to your profile data, IP address, analytics IDs, conversation/consultation ID, device ID, messenger ID).
HEALTH DATA. Any type of health data you share when using our Services and when participating in research projects and research surveys, such as health data collected through the chatbot, Health Background data, and Health data provided through specific services such as assessments, health goals, the health tracker, health plans, quizzes and tools (BMI calculator).
TECHNICAL INFORMATION. User agent (web browser type and version), device model, screen information, mobile service provider, installed app version, OS version, location (country and city), time zone, IP address at the time of usage, Healthily's/Your.MD's unique identifiers (profile ID, conversation ID/consultation ID), Messenger identifier, records of events with Technical Information and your interaction with our App/Services. For example, logs on your usage of the Services, which include chat information, quizzes, self-assessments and tools, the BMI calculator, and the articles you have viewed in the Health Library and our OneStop Health™ Marketplace.
ANALYTICAL INFORMATION. Hashed IP address, hashed profile ID or guest profile ID, hashed conversation/consultation ID, analytics provider's unique user ID (Firebase ID) or client ID (Google Analytics ID) or Messenger ID, third-party cookies.
Information on how you use our Services:
General Activity (e.g. the screens you view, time spent, if you added data to your profile, whether you are in test groups, items on your home feed and interaction)
Sessions (e.g. when you started the session, duration)
App info (e.g. if you deleted/upgraded the App, version)
Authentication (e.g. whether you authenticated and which type of authentication)
Acquisition channel (e.g. which ad you clicked on to get to our Services)
Notification activity (e.g. whether you opted in or out of notifications)
Activity within our Services and features (e.g. your data and activities, assessment outcomes and feedback, whether you sent an input that failed to be understood by our chatbot, clicks on articles, whether you opened an assessment report, viewed assessment history, articles you view, share, whether you view/click on the partner, whether you are logging your feelings, tracking symptoms, receiving follow ups, syncing data with third-parties, whether you sign up for Health Plans and your interactions, logs on your usage of our Services).
We cannot provide all services necessary for the successful operation of our Services by ourselves. We therefore share collected information with third-party providers for the purpose of offering and improving the Services. The information we share will not identify you personally, and the providers will only use the data to offer services to us. However, we will use your email to send you newsletters and surveys. For privacy-related requests, see section “Your rights” of this Policy or send an email to firstname.lastname@example.org
THIRD-PARTY TECHNOLOGY AND PROVIDERS
Third party providers are data processors. This means they process your information on our behalf, in accordance with our instructions. We only allow your information to be used by them to offer services to us. How third party providers' use of information is controlled by the terms of their contract with us and any settings enabled by us through the user interface of their product.
Airship. We use Airship to send out Healthily/Your.MD newsletters, for tester program correspondence, surveys and to send push notifications. Airship uses your data to host an email marketing and communication services for us and may share your data with third-parties for the same purpose. Your data is stored in EU Datacenter. You may exercise any rights you may have to access, correct, amend or delete such data. You can unsubscribe from our email messaging by clicking the 'unsubscribe from the list' link in the footer of every email you receive from us. Please refer to Airship Privacy Statement for more information.
Typeform. If you decide to participate in one of our Surveys, we use Typeform, an online software service for form building and surveys. Typeform will collect the following information: your responses (these are managed by us and we take responsibility for this data, which may include personal data), usage data (data about your interaction with Typeform services), device and application data (IP address, browser type, operating system, geolocation), referral data (the source that referred you to us – link on site, email etc.), and email address (to send you Typeform notification emails). All data is hosted by Amazon Web Services (AWS). Typeform's main servers are located in Virginia, USA, and its backup servers are in Frankfurt, Germany. Typeform uses Transport Layer Security to secure data in transit.
Third-party Health Trackers. You can sync data collected by third-party trackers with our Health Tracker: HealthKit (only iOS v.2. version), Samsung Health, Google Fit. We will use this data solely for providing and improving our Services, which includes health, motion and/or fitness services, to improve health management, or for health research.
Firebase Authentication feature enables you to sign in or create a profile with your email/Google/Facebook account. Firebase Authentication stores the following data: password (only relevant for users who created a profile with the 'email' authentication method), email address, phone number (only relevant for users authenticated with Facebook, for which the email address is not available). User Agent String and IP addresses are used for added security and to prevent misuse during sign up and authentication. For more information, please refer to the Firebase Data Processing and Security Terms.
Zoom. We use Zoom to conduct and record an online interview (upon prior user’s consent), for our tester program communication. Zoom uses your data to host communication services for us and may share your data with third-parties for the same purpose. By using Zoom you acknowledge that your personal data may be transferred to or stored in the United States or in other countries around the world. If you are a resident of the European Economic Area (EEA), and your personal data is transferred outside of the EEA, Zoom will process it in a territory which the European Commission has determined provides an adequate level of protection for personal data, or implement appropriate safeguards to protect your personal data. Please refer to Zoom Privacy Statement for more information.
We use third-party providers to advertise our Services on other platforms and acquire new users.
Google AdWords. We use AdWords, Google's online advertising program, to reach new customers and grow our business. We use features such as Search Ads, Display Ads and App Ads. You can find more information about these features here. With the aid of advertising cookies we can make advertising more effective. Without cookies, it is more difficult for us to reach our audience, or to know how many ads were shown and how many clicks we received. When you visit our Site or see an ad that uses AdWords, either on Google services or on other sites and apps, various cookies may be sent to your browser. These may be set from a few different domains, including google.com, doubleclick.net, googlesyndication.com, https://ads.google.com/home/, or the domain of Google's partners' sites.
Facebook Ads. With the use of Facebook ads we can redirect you from our Facebook profile to download the Apps from App Store or Google play, or directly to our Web App to enable you to use our Services. For more information on Facebook ads, please refer to the Facebook ads basic and Facebook Data Policy.
Facebook Lead Ads. When you click on Facebook Lead ad and submit the form with information such as your name and email address, we will use this information to send you the content you have requested from us directly to your email address. This information is stored in Mailchimp. All the information you share with us via Facebook Lead is stored on Facebook’ servers as well and Facebook will use it as described in its Data Policy.
Ads are shown to you based on your activity across Facebook Companies and Product, your activity with other bussiness, websites and apps and your location. For more information please read About Facebook Ads.
To protect your privacy rights and control the data processing we have entered into Microsoft Online Services Terms. This includes Microsoft's core privacy and security commitments, data processing terms, Model Clauses, and GDPR terms.
Free Basics Platform. We have integrated our Services with Free Basics to enable you to access our Services where internet access may be less affordable. You will be able to engage with our chatbot and find health information by reading articles. Free Basics by Facebook offers access to websites and third-party services free of charge. You can find our Services here. Or to learn more about Free Basics and how it works, visit Free Basics. Please refer to the Privacy on Free Basics for further information.
ONESTOP HEALTH™ PROVIDERS
Addicaid, AIDE, Akira, Altbibbi, Ask The Midwife,AugmentCare, Antidote, BetterPT, BigWhiteWall, Bisa, Braive, Brook, CCBT, Cera, ConnectMed, Daily Yoga, Doctor Care Anywhere, Doctify, Doctor Insta, Doctor On Call, Doc2Us, Dr. Morton's, Echo, Eyr Medical, First Derm, Firstcheck, GetDoc, GPDQ, Hay Fever Relief, HelloDoctor, HelloDoctor Ethiopia, healthexpress, InnerHour, KRY, KingFit, Knok, Lark, Life Circle, London Osteoporosis Clinic, Marie Stopes International, MDalgorithms – MDAcne, MedicSpot, MedGrocer, Mimi, Minds for life,MyHouseCall,MyLab,MyMeds, My Pocket Doctor, mySugr, National Migraine Centre, NHS Choices, Obino, PAPYRUS, PayAsUGym, Pacify,Pliro, Portea, Project Red Ribbon, Pzizz, Sehat, Sexwise, Siha Health, SH:24, Slide safe, Smoke Free App, Supercarers, TB Alert, The Pip, Thriva, Urban Massage, VIDA, WellaHealth, West Africa Aids Foundation, Zennya, ZoomDoc, 1mg.
We use third-party services for our internal communications and communication with external partners, namely:
We do not share directly identifiable personal data with these services.
MANAGING PROJECTS, HOSTING, SOFTWARE DEVELOPMENT AND CLOUD STORAGE
With the help of analytics providers, we collect Analytical Information to help us improve our Services for you. We chose our providers carefully and set the most restrictive controls available to ensure they do not use your data for any purpose other than providing services to us.
Google Analytics for Firebase
Google Analytics for Firebase (GAF) allows us to collect data on how our apps are used, as described under 'Analytical Information' in section “The data we collect” of this policy. When you install our app, GAF collects the following data: unique identifiers, browser type and settings, operating system, mobile network information, IP Address (which is anonymised before any storage or processing takes place), crash reports, device identifiers, and an pp instance identifier — a randomly generated number that identifies a unique installation of our app. We use Analytical Information to improve and personalise our apps.
To learn more about how GAF processes your data, please refer to the following: Google Analytics for Firebase Use Policy, Information for Visitors of Sites and Apps Using Google Analytics, How Google uses information from sites or apps that use their services, and Terms of Service for Firebase Services.
Google Optimise is used with GAF data to quickly and easily identify areas of our App which require improvement. We use this service to provide A/B tests, and to see which flow or design works best from a user perspective. We do this by splitting users into test or control groups to see which performs best. Visit Google Optimise for more information.
AWS Analytics does not access or use your data for any purpose other than to provide services to us, as legally required, and to maintain AWS services. Strong encryption of your data is in place. You can refer to the AWS Privacy Notice for more information. Please note, AWS Analytics is only used in our iOS App.
Facebook Pixel is an analytics tool that allows us to measure the effectiveness of our advertising by understanding the actions you take on our Site. We have placed a pixel code on the header of our Site so that when you visit our Site and take an action (such as clicking on the Web App), the Facebook pixel is triggered and reports this action. We then know when you take an action and will be able to reach you again in future through targeted Facebook ads. With Facebook Pixel we relay conversions back to Facebook which enables retargeting. For more information, please read the Facebook Data Policy and visit The Facebook pixel.
If you decide to participate in User Tests, this will be performed via UserTesting platform (UserTesting).
THIRD PARTY RESEARCHERS
We share your information in an anonymised manner with third party researchers, namely Imperial College of Science Technology and Medicine, London.
SOCIAL MEDIA (Facebook, Twitter, Instagram)
When using our Services through social media note that the information you share including health data will be processed by social media provider and might be used to build a profile of you and could result in receiving adverts including relating to health issues. This processing is not controlled by us and we do not have access to the data stored within social media about you. For more information read social media privacy notices, Facebook, Twitter, Instagram.
Your data will be disclosed only when necessary for lawful purposes, our legal obligations and rights as stated herein, and will be limited to such purposes:
a) if required by law, for example to comply with a court order, subpoena, regulation, legal process or other governmental request
b) to exercise or protect the rights, property or personal safety of our company, our users or others
c) to enforce this privacy statement, including investigation of potential violations d) upon fulfilling legal requirements of local legislation to supply certain services a third-party might legally request from us
e) to detect, prevent, or otherwise address fraud, security, or technical issues
f) if we are involved in a merger, acquisition, or sale of all or a portion of its assets, you will be notified of any change in ownership or uses of your data
g) to respond to claims that any content published within our Services or our Services violate any right of a third-party.
We follow generally accepted industry standards and internal procedures to protect the data submitted to us during transmission, storing, and processing. We store your data for as long as is needed to provide our Services.We may store it for longer, but only in a way that it cannot be tracked back to you. We delete all personally identifiable data we have about you within 30 days of receiving your data deletion request. Please make sure you request a copy of your data before you ask to delete your data, as your data will not be retrievable afterwards.
We delete the logs we keep of the IP addresses you have used after approximately six months. When the data is no longer needed, we delete it using reasonable measures to protect the information from unauthorised access or use. Any information you send to email@example.com and/or firstname.lastname@example.org will be deleted as soon as we respond to your enquiry and/or the information is no longer needed.
We are committed to keeping your data up-to-date. You can exercise your rights within our App or ask us to do so for other services by sending an email to email@example.com. We may decline to process requests that are unreasonably repetitive, require disproportionate technical effort, jeopardise the privacy of others, are impractical, or if we are required to retain such information by law or for legitimate business purposes. In the event of a suspicious request made in bad faith or accompanying unlawful behavior, we reserve the right to deny any request you make. We will not respond to any enquiry emails which we do not understand, where the request is not clearly specified, or pertains to health questions as we do not offer case-specific advice.
RIGHT TO WITHDRAW YOUR CONSENT
You can withdraw your consent for the use of your Health Background/Health Info data in your Account Settings (old versions: in-App profile) at any time by visiting your Account Settings/Health Background (old versions: profile/settings/privacy). Once you have done so, we won't use this data for our Services, and it will be deleted from your account (in-App profile).
You can change notification preferences within your Account settings (in-App profile) and choosing ‘Manage trackers’ option. By clicking the button next to the tracked symptom, the health tracker history in the App will be deleted and you will no longer receive tracking reminders.
To withdraw consent for general notifications you can choose ‘Notification’ option within your Account Settings/Settings or you can use the notification settings within your mobile device (please see section “Your rights”, 'Opt-Out of this Policy').
To unsubscribe from our newsletters you can click the 'unsubscribe' link which is present in every email you receive.
For Messengers , you can withdraw your consent by sending us an email to firstname.lastname@example.org (subject:messenger - consent withdrawal).
You can withdraw your consent for email collection for research purpose by sending us an email to email@example.com, subject: withdrawal consent for research.
RIGHT TO OBJECT AND TO RESTRICTION OF PROCESSING
We process your data on a legitimate interests basis if you use our service without creating a profile, when using our Site, or receiving newsletters or business emails. We limit the amount of data we collect, and this data cannot directly identify you. To exercise your right to object or restrict processing, please send us an email to firstname.lastname@example.org.
RIGHT TO ACCESS, COPY, RECTIFICATION
You can request your data by visiting your Account Settings/Data (old versions: in-App profile/settings/profile) and choosing the ‘Export data’ (old versions: 'Request Your Data') option. You will be able to download your data to your device (old versions: you will receive a copy of your data via email within 30 days).We will send your data within 30 days of receipt of your request. If we need to acquire your data from a third party, this might take longer.
To prevent malicious activity, we reserve the right to request a copy of your ID, passport, or other official identification documents before sending you the data.
You can use the Account details (Personal Info) section within the app to change the data you added to your Account (profile).
You have the right to request rectification of inaccurate personal data that cannot be rectified within our Services by sending an email to email@example.com.
RIGHT TO ERASURE
Apps. You can delete your data at any time by visiting your Account Settings/Data and choosing ‘Delete your account’ option (old versions: in-App profile/settings/profile and choosing the 'Delete Profile' option). When you select the ‘Delete your account’ ('Delete Profile') option, we anonymise your data by deleting all directly identifiable personal data from our databases and you won't be able to retrieve them. Please make sure you ask for a copy of the data before you request us to erase it, should you want to keep it.
For Messengers, please send an email to firstname.lastname@example.org (subject: messenger - deletion request). Following a request, we will delete the personally identifiable data at our end and refer you to the Messenger to do the same.
For Research, please send an email to email@example.com (subject: deletion request for research).
We will delete the personally identifiable data within 30 days of receiving your request. We reserve the right to delete your profile after a long period of inactivity.
USERS WHO DO NOT CREATE A PROFILE
If you use our Web Apps (Symptom Mapper, Symptom Checker), App without creating a profile (Guest user of old versions of our Apps that have access only to limited Services), you should be aware that we are not able to accommodate your request for the deletion/access/copy of your data because we do not store any data that could directly personally identify you. Similarly, we cannot carry out such a request if you are a Site visitor as we do not store any data that could personally identify you. If you stop using our Services, we will delete all collected data within six months. We do not create a third-party profile when you do an assessment for someone else. For this reason, we are not able to personally identify such a person, nor enable the exercise of rights.
You can request correction/access and erasure of your data at any time by sending an email to firstname.lastname@example.org (subject: Tester program).
UserTesting. If you wish to request access to, correction, or deletion of personal data you have submitted to the UserTesting corporate website, contact UserTesting at [email@example.com](mailto: firstname.lastname@example.org) or as determined in the User Taster Agreement or other service agreement that you have entered into with UserTesting. or as determined in the User Taster Agreement or other service agreement that you have entered into with UserTesting.
We make sure we do not collect more information than is needed to provide our Services and we strive to limit our Providers to do so as well. We have integrated protocols to allow us to process Health Data in a way that does not directly identify you. However, you are always free to opt out of data collection by not using our Services or by uninstalling the app.
Facebook Lead Ads. If you have subscribed to receiving selected content via Facebook Lead ad, you can unsubscribe by clicking “unsubscribe” link which is present in every email you receive.
Notifications. You can deactivate notifications by changing the notification settings in accordance with the instructions of the operating system running on your device. If you are using iOS , you will be asked to accept or refuse push notifications after the app is downloaded. If you do not accept, you will not receive push notifications. If you do accept, mobile phones will allow you to disable push notifications later on by using the settings on your mobile phone.If you are an Android user, you will automatically receive push notifications after the app is downloaded. You can disable these within the mobile phone settings.
Back Pain Hub notifications. You can edit your notification preferences within the Hub Settings.
Kickbox. If you want to access, correct, amend, or delete inaccurate data held by Kickbox you should direct your query to email@example.com. If you request to remove this data Kickbox will respond within 30 business days.
Health Plans. You can stop your personalised health plans at any time within the feature.
Nearby pharmacies and hospitals (Find Services Near You). You can withdraw your consent at any time by disabling your location permission for our app within the settings of your mobile phone. You can exercise your right to access or rectify and delete your data with Google by accessing your account: https://myaccount.google.com/security#signin.
Analytics. You can opt out of our information processing and Google Analytics for Firebase by sending an email to firstname.lastname@example.org and/or opt out of Google Analytics by installing this browser add-on https://tools.google.com/dlpage/gaoptout.
AppsFlyer Analytics. You can opt out of tracking by sending an email to email@example.com or by completing the form on their website https://www.appsflyer.com/optout. The opt out is specific to AppsFlyer activities and does not affect other tools that we may use. If you choose to opt out, AppsFlyer will stop tracking data for that device going forward. The services will stop across all applications, not only ours.
Typeform. Enables you to exercise your right to access, rectification, erasure, restriction and objection by opening a support ticket via the Help Centre. You can send a request via https://typeform.com/help.
Zendesk. Correcting, updating and removing your information. If you seek to exercise your data protection rights in respect of personal information stored or processed by Zendesk on our behalf (including to seek access to, or to correct, amend, delete or restrict processing of such personal information) you should direct your query to us by sending an email to firstname.lastname@example.org. We will then instruct Zendesk to remove the personal information and they will respond within 30 days. They will retain personal information which they process and store on our behalf for as long as is needed to provide services to us.
Calendly. Enables you to exercise your rights to access, data portability, and deletion of your personal data by submitting a verifiable consumer request to email@example.com.
Zoom. Enables you to exercise your rights to access, data portability, rectification, and erasure by submitting a request to firstname.lastname@example.org.
ChatBot. Enables you to exercise your rights in relation to access, update, amend, correct, or delete your personal data by submitting a request to email@example.com.
We follow generally accepted industry standards and internal procedures to protect information submitted to us.
We store identifiable personal data and health data in separate databases. This meansthat whatever you enter or do in our App, it is not connected to data that could personally identify you. We normally process your data with the help of identifiers, namely profile ID, consultation/ conversation ID and analytic identifiers to avoid personal identification. In limited cases when required for user safety or critical systems issues, authorised personnel can access personal data along with Health Data. Your IP address is used to determine location, but it is normally masked (hashed) when stored on our backend.
We store your information for as long as needed to provide our Service. We may store the information longer, but only in a way that it cannot be tracked back to you. We use AWS and Google Cloud Platform for storing of information.
AWS. AWS has multiple security certificates https://aws.toner/security/.The data we collect from you may be transferred to, and stored at, a destination outside and inside of the European Economic Area (EEA), namely the AWS regions in the US and EU. It may also be processed by staff operating outside the EEA who work for us, or for one of our Providers. Your data will still be safe - we have entered into the AWS data processing addendum to make sure your personal information (IP address) is safe, namely:
a) that the AWS will use the data only to provide its storing services
b) that it will not disclose data to any third-party
c) that the AWS restricts its personnel to process your data without their authorisation
d) that we stay in control of correcting, blocking, deleting, retrieving your data
e) that AWS is responsible for implementing and maintaining the technical and organisational measures
f) that AWS is certified under ISO 27001 and agrees to maintain an information security program for the service that complies with the ISO 27001 standards or such other alternative standards as are substantially equivalent to ISO 27001 for the establishment, implementation, control, and improvement of the AWS Security Standards
Firebase Hosting. We use Firebase Hosting for our Site. Firebase Hosting is a production-grade web content hosting for developers. Zero-configuration SSL is built into Firebase Hosting, so content is always delivered securely. Please refer to the Firebase Data Processing and Security Terms for more information.
Tekasco HealthStream system, owned by Tekasco Ltd (“Tekasco”). We use Tekasco HealthStream system for Coronavirus (COVID-19) Symptom Mapper. We control the data stored, while Tekasco is the processor. Tekasco has put in place commercially reasonable physical, electronic, and managerial procedures to safeguard and secure our data from unauthorized access. All Tekasco HealthStream applications and databases are physically managed by Microsoft Azure in secure data centers within the United Kingdom. All data centers are SAS 70 Type II certified, SSAE16(“SOC 2”)/HIPAA/HITRUST Compliant, and feature proximity security badge access and digital security video surveillance. Tekasco security procedures utilise industry best practices from sources including The Centre for Internet Security, Microsoft, Red Hat and more. Tekasco maintains numerous full backups of our data. These backups are stored in a geographically and logically separated environment. Tekasco as well runs monthly Vulnerability Assessments on their production environment. For more information about Tekasco, please visit Tekasco website.
To guarantee your privacy, we securely encrypt, limit, and restrict access to your personal details.
We encrypt all your data at rest and any directly identifiable personal information is double encrypted with two keys at both the infrastructure and application level. We have restricted access to production environments and monitoring of your activities. The information is encrypted and key protected, and we have integrated commercially reasonable efforts to make sure your information remains secure when processed by us. However, please be aware that no security measures are impenetrable. If you have any concerns about the security of our Services, please contact us at firstname.lastname@example.org.
To ensure security of processing we engage third-party providers for penetration testing (security testing) - a controlled form of hacking in which a professional tester, working on behalf of an organisation, uses the same techniques as a criminal hacker to search for vulnerabilities in the company's networks or applications. During security testing, the third-party provider may have access to your personally identifiable data. Security testing providers are contractually bound to take all necessary technical and organisational measures to protect data, and they are not allowed to transfer it to third-parties or use it for any other purpose besides security testing for us.
EU Territory We delete logs we keep of the IP address within six months. We store your personally identifiable data for the duration of the provision of our Services or up to 30 days after your deletion request. This section shall not prevent any technical storage or access to information for the sole purpose of carrying out the transmission of a communication, or as strictly necessary for us to provide the Services you requested. We reserve the right to delete your profile after an extended period of inactivity.
Storing might be different depending on which territory is collecting the information and the applicable legislation, but we always strive to store the information only if it is needed for the purposes of providing, improving or personalising our Services.
Should you have any privacy-related questions, please contact us at email@example.com. If we are not able to help, we will forward your enquiry to our external Data Protection Officer (DPO), ePrivacy GmbH, represented by Prof. Dr. Christoph Bauer, Große Bleichen 21, 20354 Hamburg. Should you have any concerns or complaints that our DPO is not able to resolve, you have the right to lodge a complaint with our supervisory authority Der Hamburgische Beauftragte für Datenschutz und Informationsfreiheit, Prof. Dr. Johannes Caspar, Kurt-Schumacher-Allee 4, 20097 Hamburg. If you are a UK customer, you can lodge a complaint with the Information Commissioner's Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF.
Matteo Berlucchi, CEO