HealthUnlocked Holdings Limited (“HealthUnlocked”) is a private company that aims to transform individual health experiences into support, recommendations, insight and understanding for communities of people facing similar challenges. We do this by enabling people to share personal health experiences and information with people with similar health conditions online using our site (“Our Site”). In turn this provides support, aids self-management, and improves interactions with professionals, with the aim of enhancing day-to-day health and well-being.
At HealthUnlocked we believe in the potential of shared experiences to transform lives and uncover understanding in health. Because this may involve you sharing sensitive information about your health, we also believe in the importance of clear and transparent privacy guidelines. As a user of Our Site it is important that you know how we use and share your information and how you can control what happens to information you share on Our Site.
This Policy will tell you how we protect your personal data when you visit Our Site (regardless of where you visit it from) and explain your privacy rights and how laws protect you.
This Policy is provided in a layered format. Please use the Glossary to understand the meaning of some of the terms used in this Policy.
1. IMPORTANT INFORMATION AND WHO WE ARE
This Policy explains how HealthUnlocked collects and processes your personal data through Our Site, including any data you provide on Our Site when you are using Our Site, including sharing your experiences, contributing to our online discussions, signing up for our emails, and participating in research opportunities.
Our Site is not intended for anyone under the age of 18 and we do not knowingly collect data relating to children. All users of Our Site must represent that they are at least 18 years of age.
If you are under the age of 18, you are prohibited from creating an account and being a member of HealthUnlocked. By registering as a member, you are representing that you are age 18 or older. If we become aware that a child under 18 has provided us with personal information, we take steps to remove such information and will delete the account.
HealthUnlocked is registered in England and Wales under company number 6596274. Its registered office address is: 3rd Floor, 1 Ashley Road, Altrincham, Cheshire WA14 2DT, United Kingdom.
Full name of legal entity: HealthUnlocked Holdings Limited
Name or title of data protection officer: Owen Brady
Email address: firstname.lastname@example.org
Postal address: 95 Mortimer Street, London, W1W 7GB, United Kingdom
If you have questions, concerns or complaints please contact us directly. You also have the right to make a complaint at any time to the Information Commissioner’s Office (“ICO”), the UK supervisory authority for data protection issues www.ico.org.uk.
YOUR DUTY TO INFORM US OF CHANGES
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.
2. THE 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, but not limited to first name, maiden name, last name, username or similar identifier, marital status, title, date of birth, ethnicity and gender.
- Contact Data includes email address, postcode 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, but not limited to your username and password, your interests, preferences, feedback and survey responses.
- Usage Data includes information about how you use our website, products and services.
- Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.
We may export anonymized and aggregated data reports from users within the HealthUnlocked community who have chosen to share their data. If you have not chosen to share your data with third parties, your data will not be included in the aggregated data reports.
We process special categories of personal data when you choose to add this information to your profile and contributions. We use the information within your profile and contributions to recommend relevant people, posts, communities, programs and services to you which match, but not limited to, conditions, health topics or ethnicity. You have the option to share this information with other HealthUnlocked users. You may remove this information from your profile or contributions at any time.
We do not collect any information about criminal convictions and offences, unless this has been voluntarily shared by you on Our Site.
FAILURE 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 access to certain parts of Our Site). In this case, we may have to cancel a product or service you have with us, but we will notify you if this is the case at the time.
3. 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 and Contact Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
- apply for our products or services;
- create an account on our website;
- subscribe to our service or publications;
- request marketing to be sent to you;
- enter a competition, promotion or research; or
- give us some feedback.
4. 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 under the contract we are about to enter into or have entered into with you.
- Where you consent to processing.
- 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 or regulatory obligation.
Click here to find out more about the types of lawful basis that we will rely on to process your personal data.
COMMUNICATIONS WITH YOU
PURPOSES FOR WHICH WE WILL USE YOUR PERSONAL DATA
- where we need to perform under the contract with you, including:
- opening a user account with you and your use of our service;
- where you are going to provide services to us;
- updating you with any changes to the contract between us.
- 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, including;
- to administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data);
- to deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you;
- to use data analytics to improve our website, products/services, marketing, customer relationships and experiences;
- to make suggestions and recommendations to you about goods or services that may be of interest to you;
- as part of a recruitment process; and
- to establish, exercise and/or defend our legal rights including in any legal proceedings;
- where we need to comply with a legal or regulatory obligation, including:
- complying with any applicable regulatory requirements in terms of anti-money laundering rules;
- undertaking conflict of interest checks; or
- data protection rules;
- where you have consented to the particular use of your data, including:
- sending you marketing emails; and
- taking part in surveys.
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 grounds we are relying on to process your personal data.
PROMOTIONAL OFFERS FROM US
You will receive marketing communications (including invitations to take part in research opportunities, such as surveys) from us if you have agreed to receive such communications.
Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of service experience or other transactions.
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 you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.
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, in compliance with the above rules, where this is required or permitted by law.
5. DISCLOSURES OF YOUR PERSONAL DATA
We may have to share your personal data with the parties set out below for the purposes set out in paragraph 4 above.
- Internal Third Parties as set out in the Glossary.
- External Third Parties as set out in the Glossary.
If you do not wish the personal information you provide to be subject to this possibility, you should deactivate your membership by notifying email@example.com and including "DEACTIVATE" in the subject line or by deleting your account in your account settings in Our Site.
There may be exceptional circumstances where we are required by law to make a disclosure of your personal data to certain internal third parties or authorities (for example, where information is provided that suggests an ongoing or potential threat against a child or vulnerable person). We may seek to notify you first where such a disclosure of your personal data is going to be made unless we are legally prohibited from doing so.
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 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.
6. INTERNATIONAL TRANSFERS
Where possible, we look to hold all your personal data inside the United Kingdom (“UK”) or the European Economic Area (“EEA”).
Some of our external third parties are based outside the UK or the EEA so their processing of your personal data may involve a transfer of data outside the UK or the EEA.
Whenever we transfer your personal data out of the UK and the EEA, 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 in compliance with the requirements of the GDPR (as amended in the UK with the Data Protection Act 2018). This means we will only transfer your personal data to countries that have been deemed “adequate” by the European Commission, or where another “appropriate safeguard” is in place.
- For example, where we use providers based outside the UK, including in the United States of America (“US”), we may transfer data to them and will protect personal data shared through the use of EU Commission approved standard contractual clauses and/or on the basis of another transfer mechanism permitted under the GDPR (for example, under an Article 49 derogation).
Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the UK or the EEA.
7. 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.
In order to register with us and become an account holder, you will be invited to provide a password, a username and an email. You are entirely responsible for maintaining the confidentiality of your password and account. You will never be required to reveal your full password to any representative or agent of HealthUnlocked. If you forget your password, we may ask you to answer a specific question such as your username, date of birth or postcode. Furthermore, you are entirely responsible for any and all activities that occur under your account.
You agree to notify firstname.lastname@example.org immediately of any unauthorized use of your account or any other breach of security. We will not be liable for any loss or damage that you may incur as a result of someone else using your password or account, either with or without your knowledge. However, you could be held liable for loss or damage incurred by us or another party due to someone else using your account or password. You may not use anyone else’s account at any time, without the express permission of the account holder. If you think that someone else has access to your password you should change it immediately.
None of your personally identifiable information (i.e. email address, postcode/zipcode, date of birth) is ever visible to other users or third parties without your explicit consent. We encourage you to choose a non-identifiable username as this is visible to other users.
You can choose what information you share with other HealthUnlocked users. If you chose to register using a username which could be used to identify you, or if you share other information using HealthUnlocked which allows you to be identified, information you have chosen to share from your profile or contributions, including special categories of personal data, could be identified as your data. This may also happen if you upload a photo of yourself, or a likeness of yourself, as a profile picture. Prior to posting any photo or likeness of you, choosing a username that may identify you, and/or posting other information that may identify you, you should carefully consider whether you:
- wish to be identifiable on Our Site; and
- want to post information that may be capable of being linked to you.
When you do, and you also make available special categories of data about yourself you will be deemed as having made that data manifestly public.
HealthUnlocked provides industry standard security across all of our platforms and complies with health IT standards. We have secure connections (HTTPS) with 2048 bit encryption certificates across all the areas. All passwords assigned during the signup processes are protected using salted cryptographic hashing, and cannot be decrypted by us.
Our third party cloud provider uses secure servers hosted in a protected environment with secure backups performed regularly and compliant with ISO 27001 and HIPAA. We update our security system regularly and perform ongoing research on new practices and technologies that can improve our services. HealthUnlocked has received assurance from an external auditor for its annual HIPAA Security audit, DSPT and Cyber Essential Plus.
Our service is hosted on third party servers. We have contracts in place with our third-party service providers which require them to implement security measures to protect the data they hold and the current security provisions in place are described above.
8. DATA RETENTION
HOW LONG WILL YOU USE MY PERSONAL DATA FOR?
We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.
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 requirements. Generally, once an account has been closed, we will process your data only for limited purposes, and would generally look to delete or anonymise data on inactive accounts after seven (7) years.
Details of retention periods for different aspects of your personal data are available in our retention policy which you can request from us by contacting us.
In some circumstances you can ask us to delete your data: see “Request erasure of your personal data” below for further information.
9. 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 (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 your 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 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 transfer of your personal data to you or to a third party. We will provide 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 under a contract with you.
Right to 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.
If you wish to exercise any of the rights set out above, please contact us.
NO FEE USUALLY REQUIRED
WHAT WE MAY NEED FROM YOU
TIME LIMIT TO RESPOND
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 or regulatory obligation means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.
European Economic Area means for the purposes of this policy the 27 countries within the European Union (“EU”) plus Iceland, Norway, Liechtenstein and Switzerland.
Special Categories of Personal Data means Sensitive Personal data that reveals or is processed to uniquely identify a person. This includes:
- All government issued related identifications, including social security numbers, healthcare identification numbers, passport numbers
- All financial related details
- All member healthcare records, disease or healthcare interests
- All members personal data including, but not limited to, ethnicity, sexual orientation, genetic data, any information that concerns medical or health conditions
Internal third parties
- Service providers acting as processors that may be based in the UK, EEA or the US who provide IT and system administration services.
- Professional advisers acting as processors including lawyers, bankers, auditors and insurers based in the UK, EEA or the US who provide consultancy, banking, legal, insurance and accounting services.
- HM Revenue and Customs, regulators and other authorities acting as processors or joint controllers based in the UK, EEA or the US who require reporting of processing activities in certain circumstances.