Version number: 1
Effective date: 03/06/2021
1.Who are we?
1.1 We are Healthpath Ltd trading as “Healthpath”. For privacy queries, you can contact us at firstname.lastname@example.org. Other contact details are on our website.
2.What’s the point of this policy?
2.1 It tells you what to expect when we collect your personal information via our website, app or otherwise (including our Healthpath Pro service). Please only use our service if you are completely happy with this policy.
2.2 Generally, the policy covers only information provided to us. If you give personal information to other people, such as payment providers or other websites, please check their privacy policies. Nor does this policy apply to personal information that we collect as a “processor” (e.g., personal information of patients input into our Healthpath Pro service by practitioners or by patients at the request of practitioners).
3.Might the policy change?
3.1 Yes. We will post any new version on our website (please check whenever you visit the site) and may also notify you by email, SMS, in-app message or otherwise. We will assume you agree to the new version of the policy if you use our site or app after its effective date.
4.What do we collect?
4.1 Information which you upload to our service or otherwise give us such as:
4.2 Some of this information will be “special category data”, such as details relating to your health.
4.3 Automated information about your use of our service such as: the internet protocol (IP) address used to connect your device to the internet, connection information such as browser type and version, information about your device including device-type and device identifier, operating system and platform, mobile network data, a unique reference number linked to the data you enter on our system, login details, the site from which you arrived at our service, details of your activity with date / time stamps including pages you visited and your searches / transactions.
4.4 The following information about you may be provided to us by other people:
5. What’s our reason / legal basis for collecting the information?
5.1 Because it’s necessary to take steps at your request to enter into a contract with you and/or to perform such a contract. This applies to initial enquiries and to contact and transaction details.
5.2 Because it’s in our “legitimate interests”, e.g., to manage and improve our service including tracking usage patterns and preventing or detecting fraud or abuse. This applies to automated usage data as well as to posts, reviews and similar information which you display on, or send via, our service and to “refer a friend” contact details. We may also use your contact information to carry out customer satisfaction surveys.
5.3 Because you’ve specifically agreed on our service. This applies to “special category data” (explained above) as well as to contact or other information which you give or allow us to use for newsletters or other marketing. You can withdraw permission at any time as explained on our service or by emailing us at the above email address.
6. How long do we keep personal information?
6.1 Until you close your account and ask us to delete your information by email to the above email address or our contract with you has otherwise ended (or earlier if your account has been inactive for at least 12 months).
6.2 We may hold on to some (or all) of your information for longer (typically up to six years) if reasonably needed for legal, regulatory or tax reasons, deal with disputes, prevent fraud or abuse and/or enforce our terms and conditions.
6.3 We will keep your information which we use only for newsletters or other marketing until you tell us to stop sending you such messages.
6.4 We will generally keep automated browsing information for up to 26 months.
6.5 We will keep friend referral contact information that you supply us for up to 6 months.
7. To whom do we send or make available your personal information?
7.1 To other people who supply us with a service, e.g., labs, couriers, fulfilment companies, website hosts, customer service providers, and businesses which help us send communications or monitor our website and which provide us with e-commerce, analytics, online advertising and other IT services.
7.2 To other users of our service, if you include your real name in your username or otherwise use personal information when posting on a forum.
7.3To regulators, the police and other law enforcement authorities to help deal with fraud and abuse and/or comply with legal requirements.
7.4 To insurers and professional advisers in connection with our insurance cover or to deal with legal claims.
7.5 To potential buyers so far as reasonably necessary, in the case of an actual or proposed (including negotiations for a) sale or merger or business combination involving all or the relevant part of our business.
7.6. Important: We will only disclose health data where absolutely necessary to do so – e.g., to labs to enable testing.
8. Do we send your information outside the UK?
8.1 Your personal information which we collect is stored within the UK and is not transferred to any other countries except as follows.
8.2 We may send some of your personal information to countries within the European Economic Area (EEA) for the purposes explained above.
8.3 Your personal information (e.g., name, email address, IP address, browsing information) may be transferred to the US by the following companies: Apple (app admin), Google / Facebook (analytics / advertising / app admin / login), HubSpot (analytics). Transfer is on the basis of contracts with special standard contractual clauses designed to provide adequate safeguards for your personal information.
8.4We may need to send your contact information to delivery companies in your country, including outside the UK/EEA, to enable us to perform the contract with you.
9. What rights do you have?
9.1If the legal requirements are met: To ask us for access to your personal information, to rectify it if there are mistakes, to delete it or restrict its use in certain circumstances or to “data portability” or to withdraw any consent you’ve given (e.g. marketing).
9.2 You may also have the right to object to use of your personal information in certain circumstances.
9.3 If you have a complaint about how we are dealing with your personal information, please contact us via the email address above. If you are not happy with our response or think we are not handling your personal information in accordance with the law, you have the right to complain to the Information Commissioner’s Office (ICO).
9.4 For more information about your rights, visit the ICO’s website: www.ico.org.uk.