Last updated: December 11, 2022
Healthy.io Ltd, a company registered in Israel and Healthy.io (UK) Ltd, a company registered in the UK (together with their affiliates, and/or related companies -“Healthy.io”, “we”, “our” or “us”) put great efforts in making sure that the Personal Data processed by us is safe and used properly, and that our data practices are properly communicated to our users. This Privacy Notice describes how we collect, store, use and disclose Personal Data relating to any individuals (“User(s)” or “you”) in relation to:
Specifically, this Privacy Notice describes our practices regarding:
If you are a User of the Services, please read this Privacy Notice carefully and make sure that you fully understand it.
Privacy is important to us, and we are strongly committed to transparency and fairness in our data processing activities. Please remember that you are not legally required to provide us with any Personal Data, and may do so (or avoid doing so) at your own free will.
If you do not wish to provide us with your Personal Data, or to have it processed by us, please do not use our Services. You may also request to delete certain data or opt-out of certain processing activities (see Section 8), but please keep in mind that limiting our processing may also result in us not being able to provide you with the full range of our Services, or with the best user experience when using our Services.
1. DATA COLLECTION
Throughout this Privacy Notice, the term “Personal Data” means any information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular individual. However, Personal Data does not include any de-identified or aggregated information.
We collect the following categories of Personal Data: Personal Data received from you: To use the Product you will be required to provide us with your phone number. In addition, you may voluntarily provide us with additional Personal Data, such as your full name and email address (for example, when you contact us through the Services), and any other Personal Data you may disclose to us in your communications with us.
Test results: When performing the urinalysis test using the App, you will provide us with a scan of the results using your smartphone camera. Such a scan, when analyzed by our algorithm and back-end servers, will allow us to determine your urinalysis test results. The test results are then anonymized and stored separately from any identifiable information.
Data automatically collected or generated: We may collect certain technical data about you such as your device type model and operating system, your IP address, and other device identifiers. We collect or generate such data either independently or with the help of our Service Providers (as detailed in Section 5 below).
Usage information: we use third-party web analytics services on our App to collect and analyze usage information; engage in auditing, research, or reporting; assist with fraud prevention; to better tailor our Services and features; and provide certain features to you. Information mandated by applicable law: information we are required or otherwise authorized to collect under applicable laws to authenticate or identify you or to verify the information we have collected from you via our Services.
2. DATA USES
We use your Personal Data as necessary for the performance of our Services; for complying with applicable law; and based on our legitimate interests in maintaining and improving our Services and offerings, understanding how our Services are used, optimizing our marketing, customer service and support operations, and protecting and securing our Users, ourselves and members of the general public.
Where you choose to use the Product, we ask for your explicit consent to process health information which is considered a special category data under the UK GDPR.
If you reside or are using the Service in a jurisdiction governed by privacy laws which determine that "consent" is the only legal basis for the processing of personal data (in general, or specifically with respect to the types of Personal Data you choose to share via the Services), your acceptance of our Terms and Conditions and of this Privacy Notice will be deemed as your consent to the processing of your Personal Data for all purposes relating to the Services as detailed in this Privacy Notice. If you wish to withdraw such consent, please contact us at [email protected].
Specifically, we use Personal Data for the following purposes:
To facilitate, operate, and provide the Services;
To authenticate the identity of our Users, and to allow them to access and use our Services;
To provide our Users with assistance and support;
To develop, customize and improve the Services and our Users’ experience, based on common or personal preferences, experiences, difficulties and feedback;
To contact our Users with general or personalized service-related messages (such as password-retrieval or surveys);
To support and enhance our data security measures, including for the purposes of preventing and mitigating the risks of fraud, error or any illegal or prohibited activity;
To create aggregated statistical data, inferred non-personal data or anonymized or pseudonymized data (rendered non-personal), which we or our business partners may use to provide and improve our respective services; and
To enforce legal claims, including investigation of potential violations of this Privacy Notice;
To comply with any applicable laws and regulations.
3. DATA LOCATION
Your Personal Data will be maintained, processed and stored by us on secure cloud-based servers located in the UK. In some circumstances, we and our authorized Service Providers (defined below) maintain, store and process Personal Data in the United States, the European Union, Israel and other locations as reasonably necessary for the proper performance and delivery of our Services, or as may be required by law.
Healthy.io (UK) Ltd.’s parent company, Healthy.io Ltd., is headquartered in Israel, a jurisdiction which is considered by the European Commission and the Information Commissionaires Office (“ICO”) to be offering an adequate level of protection for Personal Data subject to the GDPR or UK GDPR. While privacy laws may vary between jurisdictions, Healthy.io and its affiliates and Service Providers are each committed to protect Personal Data in accordance with this Privacy Notice, customary industry standards, and such appropriate lawful mechanisms and contractual terms requiring adequate data protection, regardless of any lesser legal requirements that may apply in the jurisdiction to which such data is transferred.
4. DATA RETENTION
We retain data solely as necessary for the purposes described in this Privacy Notice. To determine the appropriate retention period, we consider the amount, nature, and sensitivity of the Personal Data, the potential risk of harm from unauthorized use or disclosure of your Personal Data, the purposes for which we process your Personal Data and whether those purposes can be achieved through other means, as well as applicable legal requirements.
We will also keep and use such Personal Data for as long as is required in order to comply with our legal and contractual obligations, or to protect ourselves from any potential disputes (i.e., as required by laws applicable to records and bookkeeping, and in order to have proof and evidence concerning our relationship or your use of our Services, should any legal issues arise in the future), in accordance with our data retention policy.
The IP address is retained on a separate database (not linked to any other data items) for forensic and information security purposes, and is deleted after 12 months.
You may ask us to delete any Personal Data by sending us an email as stated in Section 8 below. We may delete any data from our systems, without notice to you, including once we deem it no longer necessary for the purposes set forth in this Privacy Notice. We may also retain your data in an anonymized form.
Please note that unless required by applicable law, we will not be obligated to retain your data for any particular period and are free to securely delete it for any reason and at any time, with or without notice to you.
If you have any questions about our data retention policy, please contact us at: [email protected].
5. DATA SHARING
Legal Compliance: we may disclose or allow government and law enforcement officials access to certain Personal Data, in response to a subpoena, search warrant or court order (or similar requirement), or in compliance with applicable laws and regulations. Such disclosure or access may occur if we believe that we are legally compelled to do so and solely to the extent that we believe is strictly necessary to comply, or that such disclosure is appropriate in connection with efforts to investigate, prevent, or take action regarding actual or suspected illegal activity, fraud, or other wrongdoing.
Service Providers: we may engage selected business partners, third-party companies and individuals, affiliates, subcontractor and sub-processors (collectively “Service Providers”) to perform services complementary to our own (e.g. courier services, payment processing, IT and system administration services, data backup, security and storage services, data analytics, marketing etc.). These Service Providers may have access to some or all of your Personal Data processed by us, depending on each of their specific roles and purposes in facilitating and enhancing our Services, and may only use it for such purposes. Sharing your Feedback or Recommendations: If you submit a public review or feedback, note that we may (at our discretion) store and present your review to other users of our Site. If you wish to remove your public review, please contact us via email at [email protected].
Protecting Rights and Safety: we may share your Personal Data with others if we believe in good faith that this will help protect the rights, property or personal safety of Healthy.io, any of our Users or any members of the general public.
Healthy.io’s Subsidiaries and Affiliated Companies; Change of Control: We share Personal Data internally within our family of companies, for the purposes described in this Privacy Notice. In addition, should Healthy.io or any of its affiliates undergo any change in control or ownership, including by means of merger, acquisition or purchase of its assets, or will be found eligible for a governmental grant, your Personal Data may be shared (to the extent necessary and customary) with the parties involved in such an event. If we believe that such an event might materially affect your Personal Data then stored with us, we will notify you of this event and the choices you may have via e-mail or prominent notice on our Services.
For the avoidance of doubt, Healthy.io may share and transfer your Personal Data in additional manners, pursuant to your explicit approval; if we are legally obligated to do so; or if we have successfully rendered such data non-personal and anonymous. We may transfer, share or otherwise use non-personal data in our sole discretion and without the need for further approval.
How does this personal data sharing comply with the Common Law Duty of Confidentiality (CDLC)?
For users of the Services in Ireland: the test results may also be shared with third-party health service providers which will provide the diagnosis and prescription for the pharmacy. The CDLC is satisfied as this is for the purpose of direct care and you provide your explicit consent during the registration process. For users of the Services in the UK: The CDLC is satisfied, as except as described above, your Personal Data will not be shared with third parties.
We may contact you with important information regarding our Services. For example, we may notify you (through any of the means available to us) of order summaries and delivery updates, changes or updates to our Services, billing issues, etc. While we will not send you promotional communications without your consent and means to opt-out, You will not be able to opt-out of receiving service-related communications.
7. DATA SECURITY
In order to protect your Personal Data held with us and our Service Providers, we are using industry-standard physical, organizational and technical security measures (such as access control, secure servers, firewalls, internal policies, encryption, database backup etc.). However, please be aware that regardless of any security measures used, we cannot and do not guarantee the absolute protection and security of any Personal Data stored with us or with any third-parties.
8. DATA SUBJECT RIGHTS
Individuals have rights concerning their Personal Data. If you wish to exercise your privacy rights under the laws that apply to you (for example, the EU General Data Protection Regulation (“GDPR”) or the UK General Data Protection Regulation (“UK GDPR”). These rights (each to the extent available to you under the laws which apply to you) include the right to request access to, and rectification or erasure of your Personal Data held with Healthy.io, or the right transfer certain Personal Data to another data controller (as defined below), and to withdraw your consent at any time. You also have the right to complain to a supervisory authority (such as the ICO) about our processing of your Personal Data. Please note that these rights are not absolute and may be subject to our own legitimate interests and regulatory requirements.
You may exercise any of the above rights by contacting us by e-mail at: [email protected].
When you ask us to exercise any of your rights under this Privacy Notice or applicable law, we may need to ask you to provide us certain credentials to make sure that you are who you claim you are, to avoid disclosure of Personal Data relating to other individuals, and to ask you to provide further information to better understand the nature and scope of data that you wish to access or have deleted etc. Such additional data will be then retained by us for legal purposes (e.g. as proof of the identity of the person submitting the request), in accordance with Section 4 above. We may redact from the data which we will make available to you, any personal data related to others.
9. DATA CONTROLLER/PROCESSOR
Certain data protection laws and regulations, such as the GDPR or the UK GDPR, typically distinguish between two main roles for parties processing Personal Data: the “data controller”, who determines the purposes and means of processing; and the “data processor”, who processes the data on behalf of the data controller. Below we explain how these roles apply to our Services, to the extent that such laws and regulations apply.
Healthy.io is the “data controller” of its Users’ data and assumes the responsibilities of a data controller (solely to the extent applicable under law), as set forth in this Privacy Notice. In such instances, our Service Providers processing such data will assume the role of “data processor”.
10. ADDITIONAL INFORMATION AND CONTACT DETAILS
Updates and amendments: We may update and amend this Privacy Notice from time to time by posting an amended version on our Services. The amended version will be effective as of the published effective date. We will provide a reasonable notice if any substantial changes are involved, via any of the communication means available to us, or on the Services. Your continued use of the Services after we make changes is deemed to be acceptance of those changes, so please check this Privacy Notice periodically for updates.
External links: While our Services may contain links to other websites or services, we are not responsible for their privacy practices, and encourage you to pay attention and to read the privacy policies of each and every website and service you visit. This Privacy Notice applies only to our Services.
Our Services are not designed to attract children under the age of 16: We do not knowingly collect Personal Data from children and do not wish to do so. If we learn that a child is using the Services, we will attempt to prohibit and block such use and to promptly delete any Personal Data stored with us which we deem to relate to such child. If you believe that we might have any such data, please contact us at [email protected].
Data Protection Officer: Healthy.io has appointed a Data Protection Officer (DPO), for monitoring and advising on Healthy.io's ongoing privacy compliance and serving as a point of contact on privacy matters for data subjects and supervisory authorities. If you have any comments or questions regarding our Privacy Notice, if you have any concerns regarding your privacy, or if you wish to make a complaint about how your Personal Data is being processed by Healthy.io, please contact our DPO at [email protected]
UK Representative: Healthy.io UK Ltd. has been designated as Healthy.io’s representative in the United Kingdom for data protection matters pursuant to Article 27 of the UK GDPR. Healthy.io UK Ltd. may be contacted on matters related to the processing of personal data. To make such an inquiry, please send an email to [email protected].
Questions, Concerns or Complaints: If you have any comments or questions about this Privacy Notice or if you have any concerns regarding your privacy, please contact us at [email protected].
You have a right to make a complaint if you are unhappy about how your personal data is processed. If you have any concerns regarding your personal data processed by us, please contact us at [email protected].
Please note that the ICO will not normally consider an appeal until you have exhausted your rights of complaint. Please see the ICO’s website (link below) for further advice.
Post: Information Commissioner's Office