Your Privacy

1. Data Protection Principles

We are committed to complying with all applicable data protection law and principles, which means that your Personal Information will be:

1. Processed lawfully, fairly and in a transparent way; 
2. Collected for specific, explicit and legitimate purposes stated in this policy and not used in any way that is incompatible with those purposes; 
3. Adequate, relevant and limited to what is necessary for those purposes; 
4. Accurate and, where necessary, kept up to date; 
5. Kept for no longer than is necessary for those purposes; and 
6. Processed securely. 

Accountability is an important data protection principle. HealthMe must put in place appropriate technical and organisational measures to meet these requirements and review and update where necessary the measures that have been put into place. Being accountable is key to maintain trust with other parties and may help mitigate any enforcement action if the situation arises. 

2. Collection of Personal Information

HealthMe acts as the data controller for the information you provide or that is collected by HealthMe or its affiliates. HealthMe collects Personal Information to operate effectively as a business and to provide you, the user, with tailored services and products. 

You have choices about the Personal Information we collect. When you are asked to provide Personal Information, you may decline. But if you choose not to provide Personal Information that is necessary in order for us to provide services to you, you may not be able to use that product. 

We provide further information below on the types of Personal Information we obtain and how we use them, throughout your use of our products and services. 

2.1 – Collection of Personal Information ‌

Information you give to us:‌ 

We will collect and process the Personal Information from you that you give to us by filling in forms on our website or software or by corresponding with us by phone, email or otherwise. It includes information you provide when you register to use the site or our software products, subscribe to our service, search for a product, participate in discussion boards or other social media functions on or via the site or software products, enter a competition, promotion or survey, submit a query, and when you report a problem with the site or our software. All Personal Information is kept private and will not be shared without obtaining your prior consent. ‌ 

If you are asked to provide this express consent, we will clearly and unambiguously explain to you what Personal Information we will be sharing, with whom and for what purpose. Consent for sharing of Personal Information (see section 3.3) will be asked for separately to this privacy policy.‌ 

The (“Personal Information”) you give us may include the types described below (the purpose of data collection is written next to each):‌ 

• Your name; to create a HealthMe account 
• Email address; to create a HealthMe account 
• Phone number; to create a HealthMe account 
• Date of birth; to populate your electronic health record on your HealthMe account. 
• Demographic information; to populate your electronic health record on your HealthMe account. 
• Password; to create a HealthMe account. We are not able to access user passwords.
• General identifiers; your NHS number may be collected to ensure you are correctly identified by your Healthcare Provider if you are a mobile app user enrolled in a HealthMe Partner Program (VPP). 

We may also collect sensitive personal information about your health. This is described in further detail below. The purpose of data collection is written next to each.‌‌ 

General health information: 

• Details of past medical history; to ensure your electronic health record is accurate. 
• Treatment course/cycle; to ensure your electronic health record is accurate. 
• Healthcare provider name; to be able to share your electronic health record and manage your care. 
• Healthcare provider contact details; to help you manage all aspects of your care via the HealthMe mobile app.‌ 
• Other health information; all other health information that is required for the purposes of maintaining an up to date electronic health record as required by your Healthcare provider 

Details of your care: 

• Medication you’re taking; to ensure your electronic health record is accurate. 
• Medical appointments; to help you manage your appointment schedule, provide appointment reminders and help you prepare for them. 
• Severity of symptoms and side effects; to help you track your progress through treatment and prepare for appointments.‌ 

‌

Other: 

• Gender; Understanding gender allows healthcare professionals and our partners to better understand how drugs affect different people and develop them to be more effective. It also allows the HealthMe mobile app to deliver a more personalised user experience. 

• Ethnicity; Understanding ethnicity allows healthcare professionals and our partners to better understand how drugs affect different people and develop them to be more effective. It also allows the HealthMe mobile app to deliver a more personalised user experience.‌ 

‌

Any information about your health and ethnicity is classed as sensitive Personal Information and we ensure that additional safeguarding measures are in place to protect this information. Our lawful basis for processing this sensitive Personal Information is your consent. You can withdraw your consent at any time – for more information please email privacy@HealthMe.ai. 

Part of this information is necessary to complete your user registration and for you to use our software and services (for more information on what we use your data for, see section 3) If you decline to provide this information during the registration process you will not be able to create an account on our software products and use our services.‌ 

Information we receive from other sources:‌ 

We will receive information from anyone that you give permission to enter information into the HealthMe mobile app on your behalf (such as a Caregiver or a Healthcare Provider) (“Permitted Third Party/Parties”). If you allow your Permitted Third Parties permission to edit your information, then they may give us information about your symptoms, medications and treatments. You can change your Permitted Third Parties under your settings in your account and change the permissions allocated to each Permitted Third Party.‌ 

If you are a Permitted Third Party, we may receive information about you from the patient. This information is described in the table below:‌‌ 

Personal information concerning permitted third parties: 

• Your name; to create an account on the HealthMe app and help set up app features that are relevant to their role (e.g. carer support) 
• Phone number; to create an account on the HealthMe app and help set up app features that are relevant to their role (e.g. carer support) 
• Email address; to create an account on the HealthMe app and help set up app features that are relevant to their role (e.g. carer support) 
• Relationship to patient; to help set up app features that are relevant to their role (e.g. carer support) 
• Job title; to help set up app features that are relevant to their role (e.g. carer support) 
• Location; to help set up app features that are relevant to their role (e.g. carer support)‌ 

‌If you decide to allow any third party wearable devices to connect with our Services, we will receive information about you such as your exercise, activity, heart rate, temperature, sleep, weight and blood pressure from these devices via Bluetooth.‌ 

Please note: when moving away from the HealthMe mobile app to utilise third party websites or devices referred to within the HealthMe mobile app, this Privacy Policy will no longer apply and the Privacy Policy of the third party shall apply. 

2.2 – Engagement data, Cookies and other data collection technologies

For all users, when you begin to use our software or services, we monitor engagement and feature usage on our platform by recording every interaction you have with products you are registered on. This includes, but is not limited to, page visits, content viewed and logs made on our platform.‌ 

We also infer your location based on your IP address during registration and for opt-ins. In addition to IP address, our platform automatically collects data about your device, including the model, platform, locale code and UUID (universally unique identifier) every time you visit the HealthMe website or use our software. This information may also be collected in combination with an identifier associated with your device to enable us to recognise your mobile browser or device when you return to the site or our software.‌ 

HealthMe uses cookies  and similar technologies to allow us to store your personal preferences and settings; optimise login processes; maintain a high level of security and to monitor and analyse performance of our online services. On our website, we may use traffic log cookies to track pages you view. The purpose of this is to analyse web page traffic in order to further optimise the journey users must undertake to access content that is relevant to them. You may adjust the settings on your browser to refuse cookies, however, this may lead to limited access to our online services. 

In addition to cookies, we may log information about your device, including the existence of cookies, your IP address and information about your browser. The purpose of this information collection is to diagnose service issues and to administer and track your usage of our platforms.‌ 

Information about your visit may include the full Uniform Resource Locators (URL), clickstream to, through and from the site, and any phone number used to call our customer service number or social media handle used to connect with our customer service team.‌ 

2.3 – Third party aggregate data

Our third parties may gather non-personal digital properties to enrich aggregate analytics, including Google Analytics.‌ 

All of HealthMe’s third-party service providers and other entities in the group are required to take appropriate security measures to protect Personal Information in line with our policies. HealthMe only allows service providers to process Personal Information for specified purposes and in accordance with HealthMe’s instructions.‌ 

3. How HealthMe uses your Personal Information

3.1 – To operate effectively as a business and to perform essential business operations, including developing and providing products optimised for patients and clinicians.

We are motivated to provide products which offer outstanding resources for patients. We will show you and/or a Permitted Third Party this information.‌ 

To enhance your enjoyment and productivity on our platform, we endeavour to identify and recommend the most relevant features through personalised notifications, based on your profile, medications, symptom tracking, health condition(s) and recent activities. To ensure your experience with our products is seamless, we continuously re-examine and iteratively optimise user journeys on our platform. ‌ 

HealthMe may also contact you directly by email to find out how the product you are using is working for you. We do this so that we can improve our products and make them more beneficial to our users. If you choose to provide us with information about your experiences using HealthMe products (e.g. via a questionnaire we send out), we may contact you for clarification with regards to specific information that you provide. Any information you provide will be held by HealthMe (and not shared externally) for 15 years. 

HealthMe uses your Personal Information to identify you and notify you about changes to our service. We infer your location from your device IP address in order to geo-restrict certain content on our platform.‌ 

Product issues, identified by users and communicated through customer support, are effectively diagnosed and resolved using data collected from interactions on the platform. Decisions on product development and evaluations of product performance are based on aggregate analysis and business intelligence. 

HealthMe may use your email address, phone number and/or details to present you with occasional marketing messages where you have opted in to receive these, based on our legitimate interest in marketing our services to you and subject to your right to opt out at any time. We also use third parties (such as LinkedIn, Google, Facebook, YouTube) to serve advertisements that may be of interest to you on other websites. ‌‌ 

We use third party analytics providers including Google, and others, to collect information about the usage of our app and website to enable us to improve how they work and deliver you a better service.

The information allows us to see the overall patterns of usage on our software, helps us record any difficulties you have with them, shows us whether our advertising is effective or not, and allows us to use responses to advertisements to optimise ad performance. 

We use third party software providers including Recapp who we disclose your Personal Information to for the provisions of various services that are necessary for the functioning of the HealthMe App. 

All our third-party service providers and other entities in the group are required to take appropriate security measures to protect your Personal Information in line with our policies. We only allow them to process your Personal Information for specified purposes and in accordance with our instructions. 

In addition to the specific disclosures of Personal Information set out in this section, we may disclose your Personal Information where such disclosure is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person. We may also disclose your Personal Information where such disclosure is necessary for the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure.‌ 

We will disclose your Personal Information to third parties in the event that we sell or buy any business or assets, in which case we will disclose your Personal Information to the prospective seller or buyer of such business or assets subject to the terms of this privacy policy.‌ 

We will disclose your Personal Information to third parties if HealthMe or substantially all of its assets are acquired by a third party, in which case Personal Information held by it about its customers will be one of the transferred assets. 

3.2 – To deliver communications of personal interest including product and content releases, motivational prompts and in response to product queries or support requests.‌

Direct communications 

Communications sent by HealthMe come in the form of emails to the email address provided by you during the registration process and through notifications delivered to your device. HealthMe may send you communications relating to new and existing product and content releases and updates. We send such communications so that you are aware of changes we are making to the content or features of our products, or new releases, which could affect the usefulness of our core services to you. 

Third party communications 

We may ask you during registration whether you want to receive third party communications such as promotional material related to other services outside of our platform. You, of course, have the right to opt out of such email communication at any time by using the unsubscribe link, found at the bottom of every email, or by updating your account setting in the app. HealthMe will not send you communications unrelated to its core services, unless you specifically tell us you are interested in receiving them. 

3.3 – To track and report your HealthMe data and insights with your prior knowledge and explicit consent

HealthMe partners with healthcare providers, academic institutions, contract research organisations, pharmaceutical companies and other healthcare companies for one or more of the following purposes: 

• As part of a patient support program. 
• As part of a clinical trial, real-world evidence study or other clinical research. 
• For academic research. 
• Any other clinical or research study where sharing your data is strictly necessary 

HealthMe may collect personal data via surveys or questionnaires outside of the HealthMe mobile app in order to assess your eligibility to take part in such a program, personal data provided will be processed in line with this policy. 

As part of each program we will always endeavour to limit the sharing of Personal Information to purposes where it is strictly necessary and complies with applicable regulation. Otherwise we will endeavour to anonymise and aggregate any data we share with our partners. Your data will only be shared as part of a program if you provide explicit consent for it to be shared. This consent is asked for separately to this Privacy Policy and you will be unambiguously informed of this by both HealthMe and the relevant partner. You have the right at any time to opt out of this sharing by sending a written request to privacy@HealthMe.ai. 

3.4 – Anonymised & aggregated information for commercial partners

HealthMe may share anonymised and aggregated (non-personal) information about our patient users’ conditions with our strategic partners: research institutions, pharmaceutical companies and other organisations in the medical sector. The purpose is to improve the overall care received by patients. The information that we share with our strategic partners is fully anonymised and aggregated unless you provide explicit consent to do so with one or more of HealthMe’s Partners (see section 3.3). It cannot be used to identify you in any way. 

We may also share with our commercial partners aggregated information that does not personally identify you, but which shows general trends, for example, the number of users of our service. ‌ 

4. Transparency and Choices

In this section, we have summarised the rights that all users of HealthMe software products and services have under data protection law. We recommend that you read the relevant laws and guidance from the regulatory authorities for a full explanation of these rights. 

Your principal rights under data protection law are: 

1. the right to be informed; 
2. the right of access; 
3. the right to rectification; 
4. the right to erasure; 
5. the right to restrict processing; 
6. the right to data portability 
7. the right to object; and 
8. rights in relation to automated decision making and profiling. 

You have the right to ask us to confirm whether or not we hold or process your Personal Information and, where we do, access to the Personal Information, together with certain additional information. That additional information includes details of the purposes of the processing, the categories of Personal Information concerned and the recipients of the Personal Information. Providing the rights and freedoms of others are not affected, we will supply to you a copy of your Personal Information, or do one of the following: 

1. We may ask you to verify your identity, or ask for more information about your request; or 
2. Where we are legally permitted to do so, we may decline your request, but we will explain why if we do so. 

You have the right to have any inaccurate Personal Information about you rectified and, taking into account the purposes of the processing, to have any incomplete Personal Information about you completed. 

In some circumstances, you have the right to the erasure of your Personal Information without undue delay. Those circumstances include: the Personal Information is no longer necessary in relation to the purposes for which it was collected or otherwise processed; you withdraw consent to consent-based processing; you object to the processing under certain rules of applicable data protection law; the processing is for direct marketing purposes; and the Personal Information being unlawfully processed. However, there are exclusions of the right to erasure. The general exclusions include where processing is necessary, for example: for exercising the right of freedom of expression and information; for compliance with a legal obligation; or for the establishment, exercise or defence of legal claims. 

You have the right to request that your Personal Information is no longer processed for example, due to the inaccuracy of the Personal Information or the reason for the Personal Information being processed. 

If you have given additional consent for your Personal Information to be shared to a third party, including academic institutions, medical device companies and pharmaceutical companies, you have the right to withdraw this consent at any time. You have the right to request that your Personal Information be transferred to another party. 

If you consider that our processing of your Personal Information infringes data protection laws, you have a legal right to lodge a complaint with a supervisory authority responsible for data protection. You may do so in the EU member state of your habitual residence, your place of work or the place of the alleged infringement.‌‌ 

To the extent that the legal basis for our processing of your Personal Information is consent, you have the right to withdraw that consent at any time. Withdrawal will not affect the lawfulness of processing before the withdrawal. If you opted in to third party marketing communications when you registered, you may opt-out at any time within the app, or by emailing privacy@HealthMe.ai. 

Lastly, you will not be subject to decisions that will have a significant impact on you based solely on automated decision-making. 

You may exercise any of your rights in relation to your Personal Information by written notice to us or via any of the methods specified in section 7. We will respond to requests to exercise your rights in relation to your Personal Information within 1 month. 

To contact us in relation to any of these requests, please use the email address privacy@HealthMe.ai. 

5. How long we keep your information ‌

We will keep your Personal Information in our database for as long as you wish to remain on our database in order to receive the benefits of our services. You can edit or update your Personal Information at any time. We may also contact you periodically to prompt you to update your Personal Information. This prompt will give you an opportunity to notify us if you want us to remove you from our database. If you do not respond to these prompts we will take this to mean that you want to continue using HealthMe. If you do respond to these prompts and wish to remove your personal information we will remove your personal information from our database within 1 month.‌ If you do not exercise your right to erasure HealthMe will retain your data for a minimum of 30 years, after which personal information will be deleted, and non-personal data will be stored anonymously.

Please note that if you have consented to a project of the type described in section 3 which has now concluded, we will only be able to delete the Personal Information stored in our databases. As described in section 3.4 HealthMe may share anonymised and aggregated information with partners and therefore this cannot be removed. However, shared information is not Personal Information.‌ 

6. Information Security and International Transfers

HealthMe is committed to protecting the security of Personal Information by endeavouring to ensure appropriate technologies and processes are maintained to avoid unauthorised access or disclosure. We utilise, for all data storage and processing purposes, Amazon Web Services (“AWS”). Specifically, all our AWS storage containers and databases are located in London (UK) (with possible transit through US/EU storage containers). All Personal Information collected by HealthMe software products is encrypted to the highest possible degree both when it is stored in our databases and when it is being transmitted. 

7. Changes to this Privacy Policy and Further Information

We may revise this Privacy Policy from time to time. The most current version of the policy will govern our use of your information and can be found at https://www.HealthMe.ai/privacy-policy. If we make a change to this policy that, in our sole discretion, is material, we will notify you via a notification via our software or email to the email address associated with your account. By continuing to access or use our services after those changes become effective, you agree to be bound by the revised Privacy Policy.‌ If there is a material change in the purpose of the data processing you have consented to we will re-obtain consent through acceptance of a revised Privacy Policy. 

If you would like further information about privacy at HealthMe, you may use the following email address to contact us: privacy@HealthMe.ai. 

In the UK, general information on protection of Personal Information, including your rights and freedoms under the General Data Protection Regulation, is available via the Information Commissioner’s Office (“ICO”). Their website address is www.ico.org.uk.