Healthily respects your privacy and is committed to protecting your personal data. This policy, alongside our Healthily Cold, Flu and COVID-19 Checker Terms of Service, explains how we process your data when you use our services.
YOUR.MD AS, incorporated and registered in Norway with the company number 999260993 whose registered office is at c/o Advokatfirmaet Simonsen Vogt Wiig AS, Filipstad Brygge 1, 0252 Oslo, Norway is offering its Services which may be branded as Healthily, via its subsidiary Your.MD Limited, incorporated and registered in the UK with the company number 08727263 whose registered office is at Your.MD Ltd, 5th Floor, Lincoln House, 296-302 High Holborn, London WC1V 7JH, UK (hereinafter collectively referred to as: ‘Your.MD’, ‘Healthily’, ‘we’ or ‘us’).
Your personal data is controlled by Your.MD Ltd who is the data controller in regard to its Services. Should you have any privacy-related questions, please contact us at firstname.lastname@example.org, subject: Cold, Flu and COVID-19 Checker.
We use your data to personalize your experience when you use our Cold, Flu and COVID-19 Checker (the “Checker”). We also use your data to improve the safety and security of the Services we provide, and for the purpose of analytics and communications.
Contract performance. This covers data that is processed by us in order to provide you with Services that you have requested.
Consent. Where you have consented to our use of your personal data, including health data.
Legitimate interests. This covers data processed by us for the purposes that can be reasonably expected within the context of your use of our Services to pursue our legitimate interests, in order to improve our Services and your experience, for general social benefits to enable free access to health information, to enable us to offer a safe and secure service.
TO PROVIDE OUR SERVICES AND PERSONALISE YOUR EXPERIENCE
We use your data to understand your health so that we can provide relevant information personalized to your needs. We will use information about your reported symptoms to assess the likelihood of having a cold for example. Legal basis: contract performance and consent as a special condition for the processing of your health data. Data collected: As stated in ‘The data we collect’ section of this policy.
FOR INTERNAL ANALYTICS
We collect data on how you use our Checker so that we can make improvements to the service we offer you. We use identifiers and we carry out troubleshooting and testing. We also analyze your activities to understand how you use and interact with our Services. Legal basis: legitimate interests, to help us improve our Service. Data collected: Analytical information, Technical Information, as stated in ‘The data we collect’ section of this policy.
FOR SAFETY AND SECURITY
We usually process your data based on session identifiers.. To safeguard your privacy, we store health data and data which could indirectly personally identify you (session identifier) in separate databases. We do store technical logs of your activities in the Checker. In line with best practice, only authorized 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.
We use your health data (symptoms) and your location (not specific enough to identify a street) to show you Walmart health and wellbeing products that might help you. We never share your personal data with Walmart. Legal basis: consent. Data collected: health data in ‘The data we collect section’.
FOR COMMUNICATION PURPOSES
We use your data to respond to your request and/or queries sent to email@example.com and/or firstname.lastname@example.org. Legal basis: legitimate interests. Data collected: email, full name (if provided), IP address or other identifier assigned by a third-party service provider. Your data will be transferred to Zendesk , a third-party service provider that we use for a support ticketing system. Please do not share any health data when sending emails to email@example.com and/or firstname.lastname@example.org as we do not respond to any case-specific health issues.
FOR WALMART REPORTS
We provide the following information to Walmart on a monthly basis: how many users used the Checker, finished the consultation, were identified as susceptible to suffer a specific condition, all in an aggregated and anonymized form, meaning your data and health data is never disclosed. Walmart has the right to appoint an independent auditor to verify the data. In such case, we might need to disclose more data, but don’t worry, your data will be anonymized should this need to happen.
DIRECTLY IDENTIFIABLE PERSONAL DATA: email address. Source: directly form you if you decide to write to us.
INDIRECTLY IDENTIFIABLE PERSONAL DATA: age, gender, location (country, region - not specific enough to identify the street), time zone, acquisition channel, identifiers (session ID attached to your profile data namely age and gender), IP address, analytics IDs, conversation/consultation ID, device ID). Source: indirectly from you when you interact with our Service.
HEALTH DATA. Any type of health data you share when using the Checker. Source: directly when you interact with our Checker.
TECHNICAL INFORMATION. User agent (web browser type and version), device model, screen information, mobile service provider, OS version, location (country and city), time zone, IP address at the time of usage, Healthily unique identifiers (session ID, conversation ID/consultation ID), records of events with Technical Information and your interaction with our Services. For example, logs on your usage of the Services, which include chat information, articles you have viewed. Source: when you interact with our Service.
ANALYTICAL INFORMATION. Hashed IP address, hashed profile ID, hashed conversation/consultation ID, analytics provider's unique client ID (Google Analytics ID).
Information on how you use our Services:
General Activity (e.g. time spent)
Sessions (e.g. when you started the session, duration)
Acquisition channel (e.g. which ad you clicked on to get to our Services)
Activity within our Services and features (e.g. your data and activities, consultation outcomes, whether you sent an input that failed to be understood by our chatbot, logs on your usage of our Services, screens you have seen, what you have clicked on).
Source: when you interact with our Service.
We cannot provide all services necessary for the successful operation of Healthily 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. For privacy-related requests, send an email to email@example.com, subject: Cold, Flu and COVID-19 Checker.
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.
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.
We can draw and analyze data (log data) from GA using Google BigQuery. For more information, please see Google Service Specific Terms.
We engage third party ad network to display ads within our Service.
We will show you personalised ads based on information you provide when using our Service. We never share your personal data (including health data) with advertisers.
We use the information that was calculated by our Checker to present you products that might be useful to you. You are not obligated to use these products. Our bot is constantly learning, so we cannot guarantee that the product we present to you based on information you share when interacting with our Checker or based on the Checker's outcome is what you need, but it will always be related to the outcome. 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 advice 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 does 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.
Your data will be disclosed only when necessary for lawful purposes, our legal obligations and rights as stated herein, and will be limited to such purposes: a) if required by law, for example to comply with a court order, subpoena, regulation, legal process or other governmental request b) to exercise or protect the rights, property or personal safety of our company, our users or others c) to enforce this privacy statement, including investigation of potential violations d) upon fulfilling legal requirements of local legislation to supply certain services a third-party might legally request from us e) to detect, prevent, or otherwise address fraud, security, or technical issues f) if we are involved in a merger, acquisition, or sale of all or a portion of its assets, you will be notified of any change in ownership or uses of your data g) to respond to claims that any content published within our Services or our Services violate any right of a third-party.
We follow generally accepted industry standards and internal procedures to protect the data submitted to us during transmission, storing, and processing. We store your data for as long as is needed to provide our Services. We may store it for longer, but only in a way that it cannot be tracked back to you. We delete all personally identifiable data we have about you within 30 days of receiving your data deletion request. Please make sure you request a copy of your data before you ask to delete your data, as your data will not be retrievable afterwards.
We delete the logs we keep of the IP addresses you have used after approximately six months. When the data is no longer needed, we delete it using reasonable measures to protect the information from unauthorized access or use. Any information you send to firstname.lastname@example.org and/or email@example.com will be deleted as soon as we respond to your enquiry and/or the information is no longer needed.
We are committed to keeping your data up-to-date. You can exercise your rights by sending an email to firstname.lastname@example.org, subject: Cold, Flu and COVID-19 Checker. We may decline to process requests that are unreasonably repetitive, require disproportionate technical effort, jeopardize the privacy of others, are impractical, or if we are required to retain such information by law or for legitimate business purposes. In the event of a suspicious request made in bad faith or accompanying unlawful behavior, we reserve the right to deny any request you make. We will not respond to any enquiry emails which we do not understand, where the request is not clearly specified, or pertains to health questions as we do not offer case-specific advice.
RIGHT TO ERASURE/ACCESS/COPY
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. And we are not able to verify such request. If you stop using our Services, we will delete all collected data within six months.
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. For this reason, we are not able to personally identify such a person, nor enable the exercise of rights.
Health data for provision of the Services. We need your health information to provide the Service to you. If you untick the box within the Privacy Settings available on the Privacy Matters screen you won’t be able to use our Checker.
Health data for advertising purposes. You can opt out of ads being shown within the Checker by clicking on the Privacy Settings within the Privacy Matters screen. If you opt out, we won’t show you Walmart health and wellbeing products that might help.
Google Analytics. You can opt out of Google Analytics by clicking on the Privacy Settings within the Privacy Matters screen. If you opt out, we won’t place analytic cookies on your device.
Zendesk. Correcting, updating and removing your information. If you seek to exercise your data protection rights in respect of personal information stored or processed by Zendesk on our behalf (including to seek access to, or to correct, amend, delete or restrict processing of such personal information) you should direct your query to us by sending an email to email@example.com. We will then instruct Zendesk to remove the personal information and they will respond within 30 days. They will retain personal information which they process and store on our behalf for as long as is needed to provide services to us.
If you are a California resident (as defined in the 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 point 2 ‘How we use your data’ above. Please see point 4 ‘Who has access to your data’ to learn about what third party processors do we use.
CCPA provides Californian consumers the following rights (which does not interfere with GDPR):
Right to request disclosure of any personal information we collected. This means in particular that you have:
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.
During the preceding 12 months, we did not, do not currently, and will not in the future sell or transfer your personal data to third parties (and will never do it without providing a right to opt out).
We follow generally accepted industry standards and internal procedures to protect information submitted to us.
We store Indirectly Identifiable Personal Data and Health Data in separate databases. This means that whatever you enter in the Checker, it is not connected to data that could indirectly identify you. We normally process your data with the help of identifiers, namely session ID, consultation/ conversation ID and analytic identifiers to avoid personal identification. In limited cases when required for user safety or critical systems issues, authorized personnel can access Indirectly Identifiable 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. 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 authorization
d) that we stay in control of correcting, blocking, deleting, retrieving your data
e) that AWS is responsible for implementing and maintaining the technical and organizational 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
To guarantee your privacy, we securely encrypt, limit, and restrict access to your personal details. The information is encrypted and key protected, and we have integrated commercially reasonable efforts to make sure your information remains secure when processed by us. However, please be aware that no security measures are impenetrable. If you have any concerns about the security of our Services, please contact us at firstname.lastname@example.org, subject: Cold, Flu and COVID-19 Checker.
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.
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 personalizing our Services.
Should you have any privacy-related questions, please contact us at email@example.com, subject: Cold, Flu and COVID-19 Checker.
Matteo Berlucchi, CEO