Privacy Policy - Definition Health

Privacy Policy for Definition Health Limited

We respect your privacy and are determined to protect your personal data. The purpose of this Policy is to inform you as to how we look after your personal data when you visit our website or use our digital platform (our Sites). We’ll also tell you about your privacy rights and how the data protection law protects you.

Who We Are and Important Information

What is the Purpose of this Policy?

This Policy is intended to explain how we collect and process your personal data through your use of our Sites, including any data you may provide when you submit an enquiry or otherwise contact us.

This website is not intended for children and we do not knowingly collect data relating to children. If you believe that a child’s data has been collected by us by mistake, or without a parent or guardian’s consent, then please contact us to request removal (see below).

It is important that you read this Policy together with any other privacy policy or fair processing policy we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we use your data. This Policy supplements other notices and privacy policies and is not intended to override them.

Data Controller

Definition Health Limited (company number 09791305) is the data controller and responsible for your personal data (collectively referred to as Definition, LifeBox, we, us or our in this Policy). We are registered as a data controller with the UK Information Commissioner’s Office with the number ZA464440.

We have appointed a data protection officer (DPO), Sandeep Chauhan, who is responsible for overseeing questions in relation to this privacy policy. If you have any questions about this privacy policy, including any requests to exercise your legal rights, please contact the DPO using the details below:

Definition Health Limited, Amelia House, Crescent Road, Worthing, West Sussex, United Kingdom, BN11 1QR

E: DPO@definitionhealth.co.uk

Third-party links

Our Sites may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements.

When you leave our Sites, we encourage you to read the privacy policy of every website you visit.

The Personal Data we collect about you

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:

Identity Data includes first name, maiden name, last name, username or similar identifier, marital status, title, date of birth and gender and any social media accounts used to interact with us.
Contact Data includes address, email address and telephone numbers].
Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access this website.
Profile Data includes your username and password, purchases or orders made by you, your interests, preferences, feedback and survey responses.
Usage Data includes information about how you use our Sites, products and services.
Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.

We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy policy.

Definition does not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data) for our own data purposes. Nor do we collect any information about criminal convictions and offences. We do not use Automated Decision-Making or profiling to process your personal data.

If you are given access to our Sites (including our digital healthcare solutions LifeBox, LifeBox Recovery and Secure Virtual Clinic) via a medical institution where you are to receive medical treatment or procedures, then you may be required to submit health or medical data for that medical institution’s sole use and in which instances we will act solely as a data processor for that institution, and will not process your data except as expressly instructed by them.

If you fail to provide personal data

Where we need to collect personal data by law, or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with access to our Sites).

How is your personal data collected?

We use different methods to collect data from and about you including through:

Direct interactions. You may give us your Identity, Contact and Profile Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
access our Sites;
create an account on our Sites;
request marketing to be sent to you;
enter a competition, promotion or survey; or
give us feedback or contact us.
Automated technologies or interactions. As you interact with our Sites, we may automatically collect Technical and Usage Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies and other similar technologies. Please see our cookie policy (below) for further details.
Third parties or publicly available sources. We may receive personal data about you from various third parties as set out below:
- Technical Data from the following parties:
  - analytics providers such as Google based inside or outside the UK;
  - advertising social media-based inside or outside the UK; and
  - search information providers based inside or outside the UK.
- Identity and Contact Data from medical institutions or other entities in the UK that makes our Sites available to you, and with whom we are contracted to provide a service for your use.

How we use your Personal Data

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

Where we need to perform the contract we are about to enter into or have entered into with you or a third party that makes our Sites available to you.
Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
Where we need to comply with a legal obligation.

Generally, we do not rely on consent as a legal basis for processing your personal data although we will get your consent before sending third party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us.

Purposes for which we will use your Personal Data

We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.

Purpose/Activity

Type of data

Lawful basis for processing including basis of legitimate interest

To register you as a user of our Sites

(a) Identity

(b) Contact

(a) Performance of a contract with you or with a third party that has made our Sites available to you (for example, a medical institution customer of ours where you are having treatment)

(b) Consent

To process and deliver services to you via our Sites

(a) Identity

(b) Contact

(e) Marketing & Communications

(a) Performance of a contract with you or with a third party that has made our Sites available to you (for example, a medical institution customer of ours where you are having treatment)

(b) Necessary to comply with a legal obligation with you or with a third party that has made our Sites available to you (this may include the UK NHS, for example)

(c) Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services)

(d) Consent

To manage our relationship with you which will include:

(a) Notifying you about changes to our terms or this Policy

(b) Asking you to leave a review or take a survey

(a) Identity

(b) Contact

(d) Marketing and Communications

(a) Performance of a contract with you or with a third party that has made our Sites available to you (for example, a medical institution customer of ours where you are having treatment)

(b) Necessary to comply with a legal obligation (this may include the UK NHS, for example)

To enable you to partake in a survey

(a) Identity

(b) Contact

(d) Usage

(e) Marketing and Communications

(a) Performance of a contract with you or with a third party that has made our Sites available to you (for example, a medical institution customer of ours where you are having treatment)

(b) Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services)

To administer and protect our business and our Sites (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)

(a) Identity

(b) Contact

(d) Usage

(a) Performance of a contract with you or with a third party that has made our Sites available to you (for example, a medical institution customer of ours where you are having treatment)

(b) Necessary to comply with a legal obligation with you or with a third party that has made our Sites available to you (this may include the UK NHS, for example)

(c) Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services, for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring)

To use data analytics to improve our Sites, services, marketing, customer relationships and experiences

(a) Technical

(b) Usage

Necessary for our legitimate interests (to define types of customers for our services, to keep our Sites updated and relevant, to develop our business and to inform our marketing strategy)

To make suggestions and recommendations to you about our Sites or services that may be of interest to you

(a) Identity

(b) Contact

(d) Usage

(e) Profile

(f) Marketing and Communications

(a) Necessary for our legitimate interests (to develop our services and grow our business)

(b) Consent

Marketing

We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising, and will only provide marketing to you with your consent:

Promotional offers from us; You may receive marketing communications from us if you have requested information from us or purchased services from us and, in each case, you have opted into receiving that marketing.

Opting out; You can ask us or third parties to stop sending you marketing messages at any time by contacting heretohelp@definitionhealth.co.uk.

Where you opt-out of receiving these marketing messages (withdraw your consent), this will not apply to personal data provided to us as a result of your continued use of our Sites.

Change of purpose

We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose.

If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

Please note that we may process your personal data without your knowledge or consent, but only in compliance with the above rules, where this is required or permitted by law.

Disclosures of your Personal Data

We will only share your personal data with the parties set out below for the purposes set out in the table (Purposes for which we will use your personal data) above.

External Third Parties as set out in the Glossary, including those with whom we have a contractual or legal obligation and who have made our Sites available to you (Purposes for which we will use your personal data).
Third parties to whom we may choose to sell, transfer or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this Policy.

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers (sub-processors) to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

International Transfers

We aim to use UK-based data centres and the UK or EU-based service providers to support our Sites and will not otherwise transfer your personal data outside the UK without your consent.

Whenever we transfer your personal data out of the UK, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data, this includes countries within the EU.
Where we use certain service providers, we may use specific contracts approved for use in the UK which give personal data the same protection it has in the UK.

Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the UK.

Data Security

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions, and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

We aim to use where possible only ISO27001 (in the UK/ EU) or SOCII (in the US) certified service providers.

Data Storage

LifeBox uses Amazon Web Services (AWS) for the hosting and storage of data. All AWS data is stored in the EU London region. Data stored in our AWS database (DynamoDB) is encrypted at rest using 256-bit Advanced Encryption Standards (AES).

Data is encrypted in transit using industry-standard Transport Layer Security (TLS).

All video consultations carried out within Secure Virtual Clinic (SVC) are powered by Zoom technology. Zoom encrypt a session’s video, audio and screen sharing during transit with 256-bit Advanced Encryption Standards (AES).

Data Retention

How long will you use my personal data?

We follow the UK GDPR principles of data minimisation and only collect relevant personal data necessary for use of and access to our Sites.

To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements. Once the retention period has expired, data will be automatically deleted using secure deletion procedures.

For hospital records, the retention period is a minimum of eight years following treatment (ref. https://www.nhsx.nhs.uk/information-governance/guidance/records-management-code).

Hospitals can ask Definition Health to delete data. On request, Definition Health would discuss the nature/purpose of the delete request and take the most appropriate actions within agreed timescales.

In some circumstances, you can ask us to delete your data (see your legal rights below for further information). On request, Definition Health will follow the Information Commissioner’s Office (ICO) guidelines to securely delete all personal data within the required 30-day timeframe.

In some circumstances, we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes using an industry-standard data masking strategy. In this case, we may use this information indefinitely without further notice to you.

If and when regulations are changed or clarified, Definition Health would follow new regulations.

Your Legal Rights

Under certain circumstances, you have rights under data protection laws in relation to your personal data. Please click on the links below to find out more about these rights:

Request access to your personal data.
Request correction of your personal data.
Request erasure of your personal data.
Object to processing of your personal data.
Request restriction of processing your personal data.
Request transfer of your personal data.
Right to withdraw consent.

If you wish to exercise any of the rights set out above, please contact us at: heretohelp@definitionhealth.co.uk.

No fee usually required – with some exceptions

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances.

What we may need from you

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

Time limit to respond

We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

Glossary

Lawful Basis:

Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.
Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.
Comply with a legal obligation means processing your personal data where it is necessary for compliance with a legal obligation that we are subject to.
Consent means you have any freely given, specific, informed and unambiguous indication of your wishes in relation to our collection and use of your personal data.

Third Parties:

External Third Parties;
Service providers acting as processors based in the UK, EU or US who provide [IT and system administration services].
Professional advisers including lawyers, bankers, auditors and insurers based in the UK and EU who provide consultancy, banking, legal, insurance and accounting services.
Medical institution and provider customers or ours, or other medical entities such as the UK NHS, who make our Sites available to you.

Your Legal Rights

You have the right to:

Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.

Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.

Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.

Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.

Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios:

If you want us to establish the data’s accuracy.
Where our use of the data is unlawful but you do not want us to erase it.
Where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims.
You have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.

Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.

Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.

Cookies

Our Sites use cookies to collect information.

What is a cookie?

Cookies are small files of letters and numbers that are downloaded onto your computer or mobile or other handheld device when you access certain websites. Cookies allow a website to recognise a user’s device and help your browser navigate through the website by allowing you to log in automatically or remembering settings you selected during earlier visits (among other functions). Cookies do not harm your computer. If you would like to learn more about cookies in general you can visit www.allaboutcookies.org.

Our use of cookies

Cookies help us to provide you with a good experience when you browse our Sites (particularly our website) and allow you to make full use any personalised features available on via our Sites.

We use cookies for the following main purposes:

for technical purposes essential for the operation of our Sites, such as keeping track of your current session.
to distinguish you from other users of our Sites, so we can personalise your experience and so we can remember choices you make (such as your user name, language or the country you are in) when you return to our Sites.
to collect statistical information about how many people use our Sites, so we can improve the way our Sites works and measure the success of our services.
to enable us to fulfil our contractual obligations to third parties, for example, to ensure that our customer medical institutions’ patients have access to our Sites.
analysing visitor behaviour and numbers to our Sites.

Our 4 main types of cookies:

Strictly necessary cookies – These are cookies that are required for the operation of our Sites. They include, for example, cookies that enable you to log into secure areas.

Site analytics or performance cookies –These help us to improve the way our Sites work, for example, by ensuring that users are finding what they are looking for easily. These cookies allow us to measure and analyse how our customers use our Sites, to improve functionality.

Customer preference or functionality cookies – These are used to recognise you when you return to our Sites. This enables us to personalise our content for you, greet you by name and remember your preferences.

Targeting or advertising cookies – These cookies record visits to our website, the pages visited and the links followed. We use this information to make our website more relevant. These cookies also help us understand the effectiveness of our service offerings

Unless you have adjusted your browser settings so that it will refuse cookies, cookies will be set when you access this website. You can enable or disable cookies by changing your website browser settings to accept or reject cookies as required. How to do this will depend on the browser you use.

Changes to this Notice and Your Duty to Inform us of Changes

We keep our privacy policy under regular review. This version was last updated in October 2021.

We will inform you of any future changes to this Policy and only continue to collect and use your personal data with your agreement.

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.

Queries, requests or concerns

To exercise all relevant rights, queries or complaints in relation to this policy or any other data protection matter between you and us, please in the first instance contact heretohelp@definitionhealth.co.uk

If this does not resolve your complaint to your satisfaction, you have the right to complain to the UK Information Commissioner’s Office on 0303 123 1113 or via email or post, the address of which can be found via Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF.

Definition Health is registered as a data processor with the UK Information Commissioner’s Office with number ZA464440.