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Your.MD Thyroid Checker Privacy Policy

(v.2 April 2020)


Your.MD respects your privacy and is committed to protecting your personal data. This policy, alongside our Your.MD Thyroid Checker Terms of Service, explains how we process your data when you use our services.

1. WHO WE ARE

Your.MD is a trademark of YOUR.MD AS, incorporated and registered in Norway with the company number 999260993. The registered office is at c/o Advokatfirmaet Simonsen Vogt Wiig AS, Filipstad Brygge 1, 0252 Oslo, Norway. It offers Your.MD Services (hereinafter referred to as: “Services") via its subsidiary Your.MD Limited, incorporated and registered in the UK with the company number 08727263. The registered office is Your.MD Ltd, 5th Floor, 43 Whitfield Street, London, W1T 4HD, UK (hereinafter collectively referred to as: ‘Your.MD’ or ‘we’).

Should you have any privacy-related questions, please contact us at privacy@your.md, subject: Thyroid Checker.

2. HOW WE USE YOUR DATA

We use your data to personalise your experience when you use our Thyroid 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.

LEGAL BASIS

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 data, for processing your 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.

WE USE YOUR DATA:

  • TO PROVIDE OUR SERVICES AND PERSONALISE YOUR EXPERIENCE

We use your data to understand your health so that we can provide relevant information personalised to your needs. We will use this data to personalise the thyroid checker experience. Legal basis: contract performance and consent as special condition for processing 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 Thyroid Checker so we can make improvements to the service we offer you. We use identifiers and we carry out troubleshooting and testing. We also analyse your activities to understand how you use and interact with our Services. Legal basis: legitimate interests, to helps 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 IDs attached to your profile. To safeguard your privacy, we store health data and data which could indirectly personally identify you in separate databases. We do store technical logs of your activities in the Thyroid Checker. In line with best practice, only authorised 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.

  • FOR COMMUNICATION PURPOSES

We use your data to respond to your request and/or queries sent to care@your.md and/or privacy@your.md. 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 care@your.md and/or privacy@your.md as we do not respond to any case-specific health issues.

  • FOR MERCK REPORTS

We provide the following information to Merck on monthly basis: how many users used the Thyroid Checker, finished the consultation, were identified as susceptible to suffer a specific condition all in an aggregated and anonymised form, meaning your data and health data is never disclosed. Merck 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 anonymised should this need to happen.

3. THE DATA WE COLLECT

DIRECTLY IDENTIFIABLE PERSONAL DATA (only applicable for users who decide to write to us): email address.

INDIRECTLY IDENTIFIABLE PERSONAL DATA: First name or nickname, age, gender, location (country, region - not specific enough to identify the street), time zone, service preferences, acquisition channel), identifiers (profile ID attached to your profile data, IP address, analytics IDs, conversation/consultation ID, device ID).

HEALTH DATA. Any type of health data you share when using Thyroid 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, Your.MD's unique identifiers (profile 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 in the Health A-Z

ANALYTICAL INFORMATION. Hashed IP address, hashed profile ID, hashed conversation/consultation ID, analytics provider's unique user ID (Firebase ID) or client ID (Google Analytics ID), third-party cookies. 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).

4. WHO HAS ACCESS TO YOUR DATA

We cannot provide all services necessary for the successful operation of Your.MD 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. However, we will use your email to send you newsletters and surveys. For privacy-related requests, send an email to privacy@your.md, subject: Thyroid 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.

Zendesk. We use Zendesk® (Zendesk, Inc.) as a support ticketing system which enables Your.MD employees who respond to your emails to streamline communications in a single ticket, all within an organised workflow. This allows individual requests to be dealt with more quickly. Any information you share with us via email will be received by a Your.MD support employee who will have access to information you share. This includes statistics such as when you last requested support, the nature of the issue, how it was resolved, and how long you had to wait for a resolution. Please refer to the Zendesk Privacy Policy, Zendesk Ticketing System, Zendesk EU Data Protection and How Zendesk Protects Personal Data for more information.

ANALYTICS PROVIDERS

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.

Google Analytics (GA) is used on our Thyroid Checker and Site (when you are visiting our Site). When you visit the Thyroid Checker website, your web browser automatically sends your IP address and information on how you use the Service to GA. Processing is based on a GA-created browser ID by using cookies. GA uses IP addresses to provide and protect the security of the service, and for us to know the country you use our Services in. GA anonymises the IP address before any storage or processing takes place by obfuscating the last few digits. Please refer to the IP Anonymisation in Analytics. GA processes the data based on a GA identifier called Client ID, which is stored in a cookie. Identifiers such as cookies and GA user IDs measure and report statistics about your interactions on our Site and/or Web App. GA stores cookies on your device to keep track of how you use our Site/Web App statistics without personally identifying you. We use the data collected by GA to improve the quality of our Site and Web App and to analyse Site/Web App usage. For more information, please read How Google uses cookies. Google has an EU Privacy Shield certificate and uses Standard ISO 27001 security measures. For more information on operational security and disaster recovery, please visit: How Google analytics secures your web traffic and Safeguarding your data. For general information, please read the following: How Google uses information from sites or apps that use their services, Safeguarding your data and the Google Privacy Policy.

LAWFUL PURPOSES

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.

5. HOW LONG DO WE KEEP YOUR DATA

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 unauthorised access or use. Any information you send to care@your.md and/or privacy@your.md will be deleted as soon as we respond to your enquiry and/or the information is no longer needed.

6. YOUR RIGHTS

We are committed to keeping your data up-to-date. You can exercise your rights by sending an email to privacy@your.md, subject: Thyroid Checker. We may decline to process requests that are unreasonably repetitive, require disproportionate technical effort, jeopardise 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 behaviour, 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 WITHDRAW YOUR CONSENT

You should be aware that we are not able to give you an option to withdraw the consent for processing health data because we do not store any data that could directly personally identify you. You can withdraw your consent by stop using the Thyroid Checker.

RIGHT TO OBJECT AND RESTRICTION OF PROCESSING

We process your data on a legitimate interests basis, when using our Site or when responding to your queries. We limit the amount of data we collect, and this data cannot directly identify you. To exercise your right to object or restrict processing, please send us an email to privacy@your.md, subject: Thyroid Checker objection/restriction of processing.

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. If you stop using our Services, we will delete all collected data within six months.

OPTING OUT

Google Analytics. You can opt out of Google Analytics by installing this browser add-on https://tools.google.com/dlpage/gaoptout.

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 privacy@your.md. 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.

7. STORING, SECURITY AND DATA TRANSFERS

We follow generally accepted industry standards and internal procedures to protect information submitted to us.

  • STORING

We store Indirectly Identifiable Personal Data and Health Data in separate databases. This means that whatever you enter in Thyroid Checker, it is not connected to data that could indirectly identify you. We normally process your data with the help of identifiers, namely profile ID, consultation/ conversation ID and analytic identifiers to avoid personal identification. In limited cases when required for user safety or critical systems issues, authorised 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 of 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 authorisation
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 organisational 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
g) that AWS may use subcontractors, but will restrict their access only for the purposes of offering AWS services. By using and downloading our Services, you agree to the transfer, storing and processing, as stated herein. We will take all the reasonably necessary steps to ensure that your data is treated securely and in accordance with this privacy policy. Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your data, we cannot guarantee the security of your data transmitted to our services; any transmission is at your own risk.

Google Cloud Platform. We store all analytical data on Google Cloud Platform (GCP). We control the stored data while Google is the processor. This means that Google processes the data only for the purposes of providing GCP services and technical support to us, in accordance with data processing and security terms https://cloud.google.com/terms/data-processing-terms. We control what happens to the data and can access it at any time. We have chosen to store the data in the US. Google stores data in a multi-tenant environment on Google-owned servers. The data and file system architecture are replicated in multiple geographically dispersed data centres. Google also logically isolates stored data. We have control over specific data sharing policies. Those policies, in accordance with the functionality of the Services, enable us to determine the product sharing settings applicable to this privacy policy. We may choose to make use of certain logging capability that Google may make available via the services. Google complies with legal frameworks relating to the transfer of data such as EU-US and Swiss-US Privacy Shield. Get more information on Google Cloud Platform and the terms: https://cloud.google.com/product-terms.

Firebase Hosting. We use Firebase Hosting for our Site. Firebase Hosting is a production-grade web content hosting for developers. Zero-configuration SSL is built into Firebase Hosting, so content is always delivered securely. Please refer to the Firebase Data Processing and Security Terms for more information.

  • SECURITY

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 privacy@your.md, subject: Thyroid Checker.

  • TRANSFERS

EU 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.

US Territory We will retain collected information for the period necessary to fulfill the purposes outlined in this Privacy Policy unless a longer retention period is required or permitted by applicable legislation. 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 personalising our Services.

8. COOKIES

For information about cookies, please see Your.MD Thyroid Checker Cookie Policy which is hereby incorporated into this Policy. You can turn off cookies at any time by changing your specific browser settings.

Google Analytics Cookies. Google Analytics mainly uses first-party cookies to report on user interactions on websites that use Google Analytics. Google Analytics stores cookies on your computer to keep track of how you use our Thyroid Checker. We use Cookies to analyse your activity to improve the Thyroid Checker. For example, by using Cookies, we can look at aggregate patterns like the average number of symptom checks that were not finished. We can use such analysis to gain insights about how to improve the functionality and experience of the Thyroid Checker. You may disable cookies or delete any individual cookie set by Google Analytics. Google Analytics supports an optional browser add-on that - once installed and enabled - disables measurement by Google Analytics for any site you visit. This add-on only disables Google Analytics measurement. You can use Ads Settings to manage the Google ads you see and disable personalisation. Even if you opt out of personalised ads, you may still see ads based on factors such as your general location derived from your IP address, your browser type, and your search terms. You can also manage many companies' cookies used for online advertising via the consumer choice tools created under self-regulation programs in many countries, such as the US-based choices page or the EU-based Your Online Choices.

9. GENERAL

Should you have any privacy-related questions, please contact us at privacy@your.md, subject: Thyroid Checker. If we are not able to help, we will forward your enquiry to our external Data Protection Officer (DPO), ePrivacy GmbH, represented by Prof. Dr. Christoph Bauer, Große Bleichen 21, 20354 Hamburg. Should you have any concerns or complaints that our DPO is not able to resolve, you have the right to lodge a complaint with our supervisory authority Der Hamburgische Beauftragte für Datenschutz und Informationsfreiheit, Prof. Dr. Johannes Caspar, Kurt-Schumacher-Allee 4, 20097 Hamburg. If you are a UK customer, you can lodge a complaint with the Information Commissioner's Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF.

We may update this Privacy Policy to reflect the changes in our Information processing practices. Because we are constantly adding new services and features, we might not make an immediate upgrade of the Privacy Policy, unless in case of material changes to our Data processing practices. The most current version of this Privacy Policy will govern our use of the Data we collect from you and it is available at https://www.your.md/thyroid-checker-privacy/. Because we do not create your profile account you will need to consent to the most recent version each time you use the Services.

Your.MD,

Matteo Berlucchi, CEO