Privacy Policy

Who we are

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, represented by Matteo Berlucchi, CEO, 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, 36 Egerton Road, Bournemouth, BH89AY, (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 privacy@livehealthily.com.

How we use your data

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.

LEGAL BASIS

Contract performance. This covers data that is processed by us in order to provide you with the Services that you have requested, by initiation of the Services.

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 exploring business opportunities, for scientific research and to enable us to offer a safe and secure service.

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 to your account, completing assessments, or using other services we offer. We will use this data to personalise Services such as the Smart Symptom Checker, and to recommend health plans, track your symptoms, assess your health, and display articles of interest to you.

APPS for users who create an account. Legal basis: contract performance and consent for processing health data. Data collected: as stated in ‘The data we collect’ section of this Policy.

Smart Symptom Checker. We use your data so the chatbot can calculate the most likely condition based on your reported symptoms. We might use the Smart Symptom Checker's results to show you relevant care options from third party providers ("Advertisers"), or to offer follow-up notifications for relevant conditions, symptom tracking, Health plans, and receive articles about specific topics.

Health library. You can search the Health library and save your preferred articles. Some articles include a 'When to see a doctor', which helps you assess the need to visit a health professional. We might show you relevant care options from third party providers based on your Health library search. For example, if you read an article about asthma, we will show you to a third party provider that offers services for this condition.

Journal. Within Journal you can find information about your health journey, meaning that can store data about your wellbeing so you can track your symptoms and/or habits over time (Trackers), and Notes. Assessments for third parties are not stored as Reports, but we do save a record in our Technical Information logs. Journal data (Trackers and Notes) will not be used in the Smart Symptom Checker’s calculation.

If you have used older versions of our Apps please note that you will no longer have access to past assessment reports within Journal. If you want to access your past assessment reports, go to Your account settings/Your data/Export data and export this data directly to your device.

Your personal details. You can decide to create an account for yourself or use our Services without one by using our Web App. We use your account data to allow you to use our Services and personalise your experience.

Your trackers with Goals functionality. You can track your symptoms and/or habits (free trackers and custom trackers) over time and sync with your health and fitness app data to get useful insights relevant for your health. You can also set a goal you aim to achieve, monitor your weekly progress, and receive a weekly report. This data will not be used in the Smart Symptom Checker's calculation.

Health plans. If you set up trackers with goals functionality within health plan we will use this information to provide the Services to you. We will send you daily reminders for symptom tracking and health tips on how to improve your wellbeing.

Account. 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 account 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.

Sync with other apps. The information gained through the use of ‘Sync with other apps’ will never be used to serve ads or disclosed to a third party that provides a health or fitness services without prior obtaining your permission.

Connect with wearables. If you decide to connect your wearables with our Services we will import your data from the selected third party. We will do that with your authorisation and use your data only to provide the requested Services to you. For example, if you decide to connect your Fitbit watch with our Services, we will use your data, such as health and activity-related data to display this information within our Services and to show you trends in comparison with our Services.

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 Smart Symptom Checker.

Push Notifications. We will send you push notifications based on the health data you provide when you use our Services. For example, 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 care option third party 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.

Advertising. We will show you health and wellbeing products and services (“Ads”) from third party providers ("Advertisers”) based on the information you provide when using our Services or the content you are viewing on our Site. We use the information that was calculated by our chatbot to present you with products and services that might be useful to you. You are not obligated to use these products or services. Our bot is constantly learning, so we cannot guarantee that the product or service we present to you based on information you share when interacting with our chatbot or based on the chatbot outcome is what you need, but it will always be related to the outcome. To protect your privacy we don’t share information about your symptoms or information about the outcome with advertisers or advertising platforms. We do this with the help of web page location zones (“Zones”), for example article, category summary, consultation. Each zone has a unique ID and is Healthily specific and Healthily created, meaning that it cannot be linked to you. The ads that you see are therefore linked to a specific zone, rather than you. While our bot strives to give you the best possible information it cannot consider all factors that your doctor can, so please always consult your doctor before acting on any of the recommendations our bot gives you.

We are not in any way responsible for the actions of advertisers, the content of their sites, their products or services, the use of the information you provide to them, or any of the products or services they may offer and no agency relationship exists between us and these third parties. Our links to any advertiser’s services do not constitute our sponsorship or endorsement of, or affiliation with, or responsibility for these companies. Nor is such linking an endorsement of such third parties’ privacy or information security policies or practices, or their compliance with laws.

If you decide to click on an ad within our Services you will leave Healthily Services and be redirected to Advertiser services. In doing so, the way in which your data is processed will be determined by that Advertiser's privacy policy. We create a local database on the device so we know if you have clicked on any ads. We will not disclose or share your data with any such advertisers.

We use the data we collect from you to present you with health and wellbeing products and 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 such provider, you will be directed to their website and that provider will receive your IP address.

Data collected by such 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.

WEB APP

Smart Symptom Checker

You can access our symptom checker through our website.

Legal basis: contract performance and consent for processing health.

Data collected: as stated in ‘The data we collect’ of this policy, without any directly identifiable personal data.

Report

If you request us to send you the Assessment report (Report) to your email address we will ask you to choose a 6 digits PIN number to secure the Report. This way we make sure that the Report is shared only with you and that no health data is stored together with your email address, meaning that the processing is still private and secure.

SITE

You can access our consumer site here and our business site here.

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.

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: consent and/or legitimate interests, to help us improve our Services (Site) and for general social benefits to enable free access to health information for 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 an Advertisement, 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 to your profile. We check how you use our Services with the help of analytics providers (Amplitude and Google Analytics) and by processing Analytical Information (please see section “The data we collect” of this Policy). With the help of the 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.

FOR SAFETY AND SECURITY

We usually process your data based on IDs attached to your account, 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 exploring business opportunities and consent for marketing our Services and to show you relevant care options from third party providers. Data collected: email, full name (if provided), IP address or other identifier assigned by a third-party service provider.

EMAIL REQUESTS. We will use your email to respond to any queries you send to support@livehealthily.com and/or privacy@livehealthily.com. Please do not share any health data when sending emails to support@livehealthily.com and/or privacy@livehealthily.com as we do not respond to any case-specific health issues.

The data we collect

DIRECTLY IDENTIFIABLE PERSONAL DATA (only for users who decide to create a profile): 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, acquisition channel), identifiers (profile ID attached to your profile data, IP address, analytics IDs, conversation/consultation ID, device 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 Smart Symptom Checker, and Health data provided through specific services such as the Trackers.

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 unique identifiers (profile ID, conversation ID/consultation ID), 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.

ANALYTICAL INFORMATION. Hashed IP address, hashed profile ID or guest profile ID, hashed conversation/consultation ID, analytics provider's unique user ID (Amplitude ID), user's device ID (Amplitude analytics) or client ID (Google Analytics ID), Hotjar ID (Hotjar), 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).

Who has access to your data

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 privacy@livehealthily.com

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.

Kickbox. We use Kickbox, an email address verification service provider, to validate the email address and find out whether an email can be delivered. Kickbox processes information under our direction. Kickbox may transfer personal information to companies that help them provide their service to us. Transfers to subsequent third-parties are covered by the service agreement between Kickbox and Healthily/Your.MD. Kickbox acknowledges that you have all the rights described in section “Your rights” of this Policy. Kickbox has no direct relationship with you. If you want to access, correct, amend, or delete inaccurate information you should direct your query to us by sending an email to privacy@livehealthily.com. If you make a request to delete the information, Kickbox will respond within 30 business days. Kickbox will retain personal information they process on our behalf for as long as is needed to provide services to us. Kickbox will retain any personal information needed to comply with their legal obligations, resolve any disputes, and enforce their agreements. Please refer to the Kickbox Privacy Policy for more information about Kickbox information processing.

Mailchimp. We use Mailchimp to send out transactional emails for our mobile app. MailChimp uses your data to host an email marketing service for us, and may share your data with third-parties for the same purpose. Your data is stored on a secure Mailchimp server. Mailchimp is not allowed to sell your data. Mailchimp will give access to/delete any personal information they hold about you within 30 days of a request. Please refer to the [Mailchimp Privacy Policy](https://mailchimp.com/about/security/) for more information. You can unsubscribe from these emails by clicking the 'unsubscribe from the list' link in the footer of every email you receive from us.

Third-party Health Trackers. You can sync data collected by third-party trackers with our Health Tracker: Apple Health, Samsung Health, Google Fit, Fitbit. We will use this data solely for providing the trackers to you. The information gained through the use of ‘Sync with other apps’ will never be used to serve ads or disclosed to a third party that provides a health or fitness services or medical research without prior obtaining your permission.

Facebook and Google Authentication. Facebook and Google Accounts. You can create your profile by signing in with your Google or Facebook account. By doing so you allow us to process this information. We use your email for authentication purposes in the Profile tables. We enable Google or Facebook authentication when you use the Apps. Some services allow you to use them as a guest without creating a profile, but this means you will not be able to retrieve your information later. Please refer to the Google Privacy Policy and Facebook Data Policy for more information.

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.](https://cloud.google.com/terms/data-processing-addendum)

Fitbit. If you decide to connect your Fitbit product with our Services we will use your data solely for the purposes of providing the Services to you. For more information about connection of Fitbit products with our Services please read How do I connect my Fitbit account with another app, Terms of Service, Privacy Policy.

Fitbit is a registered trademark or trademark of Fitbit, LLC in the United States and certain other countries. A list of Fitbit logos can be found at www.fitbit.com/legal/trademark-list. The Healthily application is designed for use with the Fitbit platform. This application is not authored by Fitbit, and Fitbit does not service or warrant the functionality of this application.

ADVERTISING PROVIDERS

We use third-party providers to show native ads on our Site and Web App.

Kevel. We use Kevel for advertising purposes of our Services by setting APIs infrastructure needed to build custom ad platforms for features such as sponsored listings, internal promotions and native ads. You can find more information on those features here. For more information regarding data collection and usage as part of the ad serving platform, please read Kevel Privacy Policy on Ad Serving.

COMMUNICATION PROVIDERS

We use third-party services for our internal communications and communication with external partners, namely:

Skype www.skype.com/en/, https://www.skype.com/en/legal/,
Slack https://slack.com/,https://slack.com/privacy-policy,
Google Hangouts https://hangouts.google.com/, https://policies.google.com/privacy?gl=SI&hl=en-GB,
Gmail https://www.google.com/gmail, https://policies.google.com/privacy?gl=SI&hl=en-GB,
Zoom https://zoom.us/, https://zoom.us/docs/en-us/trust.html.

We do not share directly identifiable personal data with these services.

MANAGING PROJECTS, HOSTING, SOFTWARE DEVELOPMENT AND CLOUD STORAGE

Gatsby https://www.gatsbyjs.org/,
Github https://github.com/, https://help.github.com/articles/github-privacy-statement/,
Jira https://www.atlassian.com/, https://www.atlassian.com/legal/privacy-policy,
Google drive www.google.com/drive/, https://policies.google.com/privacy?hl=en&gl=US
Dropbox https://www.dropbox.com/privacy2016,
Tableau https://www.tableau.com/tos, https://www.tableau.com/privacy

ANALYTICS PROVIDERS

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.

Amplitude

We use Amplitude for our internal analytics. Amplitude 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. We use Analytical Information to improve and personalise our Apps. Amplitude stores the following data: analytic identifier, location, sex and year of birth (but not your name, email address or any other directly identifiable personal data). All data is stored in an AWS US region. For more information, please refer to Amplitude Privacy Policy.

Google BigQuery

We can draw and analyse data from GAF using Google BigQuery. For more information, please see Google Service Specific Terms. We use Tableau Software for graphic visualisations of the data extracted from Firebase Analytics and BigQuery. For more information, please see the Tableau Software Privacy Policy.

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.

Google Analytics (GA) is used on our Site and Web App. When you visit the Web App or our Site, your web browser automatically sends your IP address and information on how you use the Service to GA. Processing is based on a GA-created browser ID by using cookies. GA uses IP addresses to provide and protect the security of the service, and for us to know the country you use our Services in. GA anonymises the IP address before any storage or processing takes place by obfuscating the last few digits. Please refer to the IP Anonymisation in Analytics. GA processes the data based on a GA identifier called Client ID, which is stored in a cookie. Identifiers such as cookies and GA user IDs measure and report statistics about your interactions on our Site and/or Web App. GA stores cookies on your device to keep track of how you use our Site/Web App statistics without personally identifying you. We use the data collected by GA to improve the quality of our Site and Web App and to analyse Site/Web App usage. For more information, please read How Google uses cookies. Google uses Standard ISO 27001 security measures. For more information on operational security and disaster recovery, please visit: How Google analytics secures your web traffic and Safeguarding your data. For general information, please read the following: How Google uses information from sites or apps that use their services, and the Google Privacy Policy.

Fabric is a business division of Google Inc. and we use their Fabric Crashlytics for crash reporting and beta testing of our mobile App. It helps us understand our App by tracking information about how publicly-released and beta versions of our App are functioning. For more information, please refer to Crashlytics Privacy Policy, Fabric Privacy and Security and the Google Privacy Policy.

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.

Outbrain Pixel is an analytics tool that help us understand whether you have successfully landed on our Site or installed the App. For more information, please read Outbrain Privacy Policy.

SOCIAL MEDIA (Facebook, X, Instagram, LinkedIn)

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, X, Instagram, and LinkedIn.

LAWFUL PURPOSES

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 violates any right of a third party.

How long do we keep your data

We follow generally accepted industry standards and internal procedures to protect the data submitted to us during transmission, storage, 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 care@livehealthily.com and/or privacy@livehealthily.com will be deleted as soon as we respond to your enquiry and/or the information is no longer needed.

We store your data:

if you have consented to the processing, at most until you revoke your consent;
if we need the data for the execution of a contract, at most for as long as the contractual relationship with you exists;
if we use the data on the basis of a legitimate interest, at most for as long as your interest in deletion or anonymisation does not outweigh the data;
insofar as statutory storage obligations exist, until the end of the storage periods.

Your rights

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 privacy@livehealthily.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 behaviour, 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.

As a data subject, you have the following rights:

To request information about the processing of your data, as well as to receive a copy of your personal data. Among other things you may request information on the purposes of the processing, the categories of personal data processed, the recipients of the data (if a transfer is made), the duration of the storage or the criteria for determining the duration;
To receive personal data relating to you in a structured, common and machine-readable format or to transfer it to another person in charge;
To correct your data. If your personal data is incomplete, you have the right to complete the data, taking into account the purposes of the processing;
To have your data deleted or blocked;
To have the processing restricted;
To object to the processing of your data;
To revoke your consent to the processing of your data for the future
To complain to the responsible supervisory authority about unauthorised data processing.

RIGHT TO WITHDRAW YOUR CONSENT

You can change notification preferences within your Account settings and choose ‘My 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 ‘Get notification’ option within your Account Settings/My Settings or you can use the notification settings within your mobile device (please see section “Your rights”, 'Opt-Out of this Policy').

You can withdraw your consent for email collection for research purposes by sending us an email to privacy@livehealthily.com, subject: withdrawal consent for research.

RIGHT TO OBJECT AND TO RESTRICTION OF PROCESSING

We process your data on a legitimate interests basis when you use our Site, or when sending out 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 privacy@livehealthily.com.

RIGHT TO ACCESS, COPY, RECTIFICATION

You can request your data by visiting Your account settings/Your data and choosing the ‘Export data’ option. You will be able to download your data to your device. 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.

You can use the Your personal details section within the App to change the data you added to your Account.

You have the right to request the rectification of inaccurate personal data that cannot be rectified within our Services by sending an email to privacy@livehealthily.com.

RIGHT TO ERASURE

Apps. You can delete your data at any time by visiting Your account settings/Your data and choosing ‘Delete your account’ option. When you select the ‘Delete your account’ 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 Research, please send an email to privacy@livehealthily.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 OF OUR SMART SYMPTOM CHECKER

If you use our Smart Symptom Checker 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.

OPTING OUT

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.

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.

Trackers. You can edit your notification preferences within the Trackers settings.

Kickbox. If you want to access, correct, amend, or delete inaccurate data held by Kickbox you should direct your query to privacy@livehealthily.com. If you request to remove this data Kickbox will respond within 30 business days.

Analytics. You can opt out of our information processing by sending an email to privacy@livehealthily.com and/or opt out of Google Analytics by installing this browser add-on https://tools.google.com/dlpage/gaoptout.

CALIFORNIA RESIDENCE PRIVACY INFORMATION

This section of our Privacy Policy contains information required by California Consumer Privacy Act (hereinafter the "CCPA") that came into force on January 1st, 2020.

If you are a California resident (as defined in section 17014 of Title 18 of the California Code of Regulations), California law requires us to provide you with some additional information regarding your rights with respect to your “personal information”.

We may transfer your personal data to third party processors in order to achieve the purposes of the processing listed in section ‘How we use your data’ above. Please see section ‘Who has access to your data’ to learn about what third party processors do we use.

CCPA provides Californian consumers with the following rights (which do not interfere with GDPR):

Right to request disclosure of any personal information we collected. This means in particular that you have:

the right to request disclosure of the categories of personal information we collected from you, together with the categories of sources from which it was collected (please see section “The data we collect”)

the purpose of the collection (please see section “How we use your data”),

the categories of third parties with whom we shared your personal information (please see section “Who has access to your data”), and

the specific pieces of personal information that have been collected please see section “The data we collect”).

Please see “Right to reassure/access/copy” section to learn how we process your request.

Right to request deletion of any personal information that we collected from you. Please see section “Right to erasure/access/copy”.

Right to non-discrimination..We will not discriminate against you for exercising your CCPA rights. This generally means that we will not deny you Services or provide a different level of Service or quality of Services. However, please bear in mind that, if you ask us to delete your data, it may impact your experience with us, and you may not be able to use our Services which require usage of your personal information to function properly.

Right to Opt-Out of Sale.

Under the CCPA placing third party behavioural advertising cookies on your device could be considered a “sale” of your personal data. For this purpose we are providing an opt-out option on our Site (“Do Not Sell My Personal Information") where you are able to opt out from such placement by clicking on the Cookie Settings link available in the footer of our Site.

Storing, security and data transfers

We follow generally accepted industry standards and internal procedures to protect the information submitted to us.

STORING

We store identifiable personal data and health data in separate databases. This means that whatever you enter or do when using our Services, 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 information.

AWS has multiple security certificates https://aws.amazon.com/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, and 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

g) that AWS may use subcontractors, but will restrict their access only for the purposes of offering AWS services. By using and downloading our Services, you agree to the transfer, storing and processing, as stated herein. We will take all the reasonably necessary steps to ensure that your data is treated securely and in accordance with this privacy policy. Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your data, we cannot guarantee the security of your data transmitted to our Site; any transmission is at your own risk.

Google Cloud Platform. We store all analytical data on the Google Cloud Platform (GCP). We control the stored data while Google is the processor. This means that Google processes the data only for the purposes of providing GCP services and technical support to us, in accordance with data processing and security terms https://cloud.google.com/terms/data-processing-terms. We control what happens to the data and can access it at any time. We have chosen to store the data in the US. Google stores data in a multi-tenant environment on Google-owned servers. The data and file system architecture are replicated in multiple geographically dispersed data centres. Google also logically isolates stored data. We have control over specific data sharing policies. Those policies, in accordance with the functionality of the Services, enable us to determine the product sharing settings applicable to this privacy policy. We may choose to make use of certain logging capabilities that Google may make available via the services. Google has updated their data processing terms for GCP to reflect various models of the E.U Standard Contractual Clauses (SCCs) regarding International Data Transfers. Get more information on Google Cloud Platform and the terms: https://cloud.google.com/blog/products/identity-security/how-google-cloud-helps-eu-companies-under-new-data-transfer-rules

SECURITY

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 privacy@livehealthily.com.

To ensure the 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.

TRANSFERS

Data is being transferred to countries outside the United Kingdom and the European Economic Area. We only transfer personal data to third countries where the ICO and the EU Commission have confirmed an adequate level of protection or where we can ensure the careful handling of personal data by means of contractual agreements or other suitable guarantees, such as certifications or proven compliance with international security standards, which you can review on request."

EU and UK 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.

US Territory. We will retain collected information for the period necessary to fulfil the purposes outlined in this Privacy Policy unless a longer retention period is required or permitted by applicable legislation. 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.

Cookies

For information about cookies, please see our Cookie Policy which is hereby incorporated into this Policy. You can manage cookies on our Site at any time by visiting the Cookie settings section available in the footer of our Site. You can turn off cookies by changing your specific browser settings. You may disable cookies or delete any individual cookie set by Google Analytics. Google Analytics supports an optional browser add-on that - once installed and enabled - disables measurement by Google Analytics for any site you visit. This add-on only disables Google Analytics measurement. You can use Ads Settings to manage the Google ads you see and disable personalisation. Even if you opt out of personalised ads, you may still see ads based on factors such as your general location derived from your IP address, your browser type, and your search terms. You can also manage many companies' cookies used for online advertising via the consumer choice tools created under self-regulation programs in many countries, such as the US-based aboutads.info choices page or the EU-based Your Online Choices. Finally, you can manage cookies in your web browser. For more information visit https://policies.google.com/technologies/ads?hl=en and read our Cookie Policy.

General

Should you have any privacy-related questions, please contact us at privacy@livehealthily.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, 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. Our EU Representative is ePrivacy, Holding GmbH, Große Bleichen 21, 20354 Hamburg, Germany. For more information, click https://www.eprivacy.eu/en/legal.

We update this Privacy Policy to reflect changes in our data processing practices. Because we are constantly adding new services and features, we may not make an immediate upgrade of the Privacy Policy unless material changes occur. We encourage you to periodically review https://www.livehealthily.com/legal/privacy or the Simply legal section of our Services for the latest information on our privacy practices. You will be informed about material changes to our data processing practices with a push notification, or by other means.

Jonathan Carr-Brown, Managing Director