PRIVACY BASICS (last update June 2018)
We have changed our data processing to comply with the Regulation (EU) 2016/679 (EU GDPR) by following the data minimisation principle and anonymising /pseudonymising personal data where feasible.
How is your data kept private. We store your personally identifiable data in Your Profile (name, email, age, gender, Profile ID, IP address, country, region, time zone) and your Health Profile (your health data) in separate databases, meaning that whatever you type into our Chat is not connected to information that could personally identify you. This way, we can make improvements to our Services without knowing anything personal about you. In limited cases, we will need to access your Health Profile by Profile ID/hashed IP address to trace bugs, solve technical errors, ensure security, clinical safety and distribute answers. Push Notifications are sent in an anonymised manner using push tokens, which allow messages to be sent to you but do not directly identify you. We do not share Your Profile/Health Profile data with OneStop Health™ Partners and we enable the usage of IP addresses only for the purposes of our Services.
As a Guest User you can use our Services by sharing the minimal amount of data we need to provide our Services to you and without you being directly identified. We will not collect any historical personal information (name, email etc.) and you will receive a new Guest User Profile as well as Health Profile for each session. We will collect temporary location data so that we can show you relevant OneStop™ Health Partners in your country. You will be able to use limited Services that do not require the storing of data by way of directly identifying you, such as read articles, use our OneStop™ Health Service and Sympthom Checker. Should you want us to personalise your experience, you will need sign in with Google/FB and become an authenticated user.
As an Authenticated User you will share more data with us so that we can offer you all features. Your Profile will include name, email, age, gender, Profile ID, social media picture Url, IP address, country and region, time zone. Your Health Profile consists of Chat History, Profile ID, consultation ID's, articles in Health A-Z you viewed, top tips, Self-Assessments and Quizzes you have done, as well as the data you voluntarily shared with us, such as Medical Conditions (smoker, obesity, high blood pressure, diabetes, chronic kidney disease, chronic obstructive lung disease, coronary heart disease, stroke, cancer etc.), Health Info (Medical and Family History, Vital Signs, lifestyle and health assessments etc.), Health Tracker data (health metrics from third parties you authorise to disclose the data to us) and Notes you make within the App. We also collect an IP address and assign a Your.MD identifier (Profile ID) and consultation identifier (Consultation ID) for each consultation. With the help of the Your.MD identifier, we are able to connect Your Profile with your Health Profile in limited cases only.
Right to object and to restriction of processing. We are processing your data on legitimate interests’ basis when using our Services as Guest (either on Android App or Web App), using our Website or receiving business emails and so you have the right to object to our processing. We have limited the amount of data we collect and cannot directly identify you. To exercise your right to object or restrict processing, please send us an email to email@example.com.
Right to access and data portability, copy, rectification. As an authenticated user using our Android App, you can request your data by visiting Your Profile/Settings/Profile and choosing the ‘’Request Your Data’’ option. You can use the Personal Info section of Your Profile to change the data you inserted. If you are using our iOS App you can change the data you inserted in the Account or Profile section of the App and send an email to firstname.lastname@example.org for more info. When using messengers, please contact your messenger provider and send us an email to email@example.com. You have the right to request rectification of inaccurate personal data that can not be rectified within our Services by sending an email to: firstname.lastname@example.org. We will send you the personally identifiable data within 30 days of the receipt of your request. In case we need to acquire your data from third parties, this might take longer.
Legal basis for data processing
As a Guest user, we will process your data for internal analytics to improve your services, for security purposes (so that we can intervene in case of security breaches, check bugs and crashes), to adhere to the medical devices regulation, ensure clinical safety and provide safe Services. We wanted to give you an option to use our services even if you are not prepared to consent to the full data collection to adhere to the data minimisation requirement as well as for general social benefits, to enable more accessible free access to health information (e.g. legitimate interests). As an authenticated Android, iOS App and Messenger user, we process your data based on your consent, which you can withdraw at any time. When you are using our Website we process your data on legitimate interests basis to improve our Service and your experience. While exploring the possibilities of collaboration with business representatives of potential B2B customers/salespersons we collect and process business emails based on our legitimate comercial interests.
Data Protection Officer. Should you have any data processing or privacy related questions, please contact us at: email@example.com. In case we are not able to help or upon your appeal, we will refer your request 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 we or our DPO is not able to solve, 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, https://datenschutz-hamburg.de/pages/kontakt/ or if you are a UK customer, with Information Commissioner's Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF, https://ico.org.uk/make-a-complaint/.
Why we need your data. We process your data to offer our Services such as Symptom Checker (so that you can access past consultations), Health A-Z (so that you can view articles about diseases/conditions), Health Tracker (to track health, fitness metrics and your feelings), Symptom Tracking functionality (to enable you to track your symptoms over time), to display Alerts/Reminders (to help you manage your health), Goals (to receive articles about topics of your interest), Notes (to insert your notes), Push Notifications (contextual, event based and Health Goals you chose to receive), to enable you to use our assessments, Quizzes, Tools and to recommend third-party services via our OneStop Health™ Platform. We use the information we collect to constantly improve our Services and to personalise your experience. We use your data to recommend services in your location based on your consultation/searches. We encrypt all user and profile data at rest and all personal information is double encrypted with two keys at both the infrastructure and application level.
Third Party Technology and Providers. You can use our Service with various messengers such as Kik, Skype, Telegram. By doing so your data processing shall be governed by such messenger’s individual privacy policies you accepted when registering for their service, so please read those carefully before starting to use such services. We check how you use our Services to improve them and personalise your experience with the help of analytic providers. You can use our Services via various messengers and by doing so, you accept such parties’ data policies. We use third-party providers for surveys, email verification and sending newsletters.
Data deletion. We follow generally accepted industry standards and internal procedures to protect the information submitted to us, during transmission, storing and processing. We store your data for as long as needed to provide our Services. We process your request to delete/access data within thirty (30) days of its receipt. We delete the logs we keep of the IP addresses you have used after approximately 6 months.
WE RESPECT YOUR PRIVACY
(last update June 2018)
We respect your privacy and we take protecting it seriously. If you have any privacy related concerns, please contact us at: firstname.lastname@example.org
Your.MD Services (hereinafter referred to as: "Services") is offered by Your.MD Limited, incorporated and registered in the UK with company number 08727263 whose registered office is at Your.MD Ltd, 5th Floor, 43 Whitfield Street, London, W1T 4HD, UK (hereinafter referred to as: "Your.MD", "We").
COLLECTION OF INFORMATION
In order for you to be able to use our Services, we need to collect limited information (the term "data" or "information" is used collectively for the information stated below).
Device model, screen information, mobile service provider, installed App version, OS version, location (country and city), time zone (when using Your.MD services via mobile apps)
User agent (web browser type and version), screen information, geolocated country and region, time zone (when using Your.MD services via web app)
IP address at the time of usage ("IP address"), Your.MD unique identifier namely profile ID, consultation ID, social network picture URL at the time of log in
User’s interaction with the App/Services
Kik, Skype, Telegram and other messenger identifiers (when using Your.MD services on these messenger platforms)
Logs with technical information as stated above
Logs on your usage of the Services as described in Analytical Information section
Logs with Symptom Checker Information as described in Symptom Checker Information Section
IP address, Your.MD unique identifier namely profile ID, consultation ID
Logs with technical data as described under Technical Information
Logs with Symptom Checker Information as described under Symptom Checker Information
Analytics provider’s unique user ID
Various information on how you use the Service such as: Sessions (when you started a session, and how you used it), App remove (if you deleted the mobile App), App update (when you upgraded to the new version), Authentication (tracking whether you attempted to authenticate, if you were successful and whether you used Google or Facebook), Acquisition channel (which Google/Facebook ad you clicked on to get to our Services – Google Ads, FB Ads, older version of the App, organic or paid channel), Chat Activity (whether you did any of the following in chat: a) Symptom check (all data inputted by the user, plus the outcome and feedback), b) general search (all data inputted by the user, plus the outcome and feedback), c) Quiz/Self- Assessment (plus outcome and feedback), d) Three strike, e) Navigation path through Chat menu, f) Tutorial, g) OneStop™ Health partner Q&A, g) Consultation report Activity (whether you: opened a consultation report, viewed all tabs of the report - for different conditions, clicked through to OneStop™ Health, clicked to full article, provided Consultation feedback, deleted reports, viewed consultation history), Health A-Z Activity (Whether you use the Health A-Z - all articles you view, save, share or download), OneStop Health™ Activity (whether you view a partner, search for a partner, view or click on the partner link), Health Tracker activity (Whether you are logging your feelings, syncing with Google / Samsung Health, viewing graphs, Notification activity (whether you opt out and to what notifications), Opening menu (what you select in the opening menu), General App Analytics (general activity within our Services such as whether you view the About Us section), Screen Activity (every screen you view, time spent on a specific screen)
Logs on your usage of the Quizzes, Self-Assessment and tools, BMI calculator (your answers, score etc.), the articles you view in the Health A-Z, Top Tips and on our OneStop Health™ Platform.
Symptom Checker Information
Your Profile: full name as per Google/FB profile, year of birth or age, gender, e-mail address, social media picture Url, country and region (not specific enough to identify a street), time zone, Services preferences (push notifications, Health Goals, Symptom Tracking, Alerts/Reminders enabled etc.), Country of residence, FB and/or Google account information (used for sign in and identification purposes only), messenger’s information, acquisition channel.
Health Profile consists of Chat History, Profile ID, Consultation ID, articles in Health A-Z you viewed, top tips, self-assessments and quizzes you have done as well as the information you decide to share with us, namely: Health Tracker data (enables you to store information about your wellbeing. In some cases, you can also sync the Health Tracker with your health and fitness apps health metrics such as steps, weight, heart rate, blood pressure, sleep), Notes (data you voluntarily insert into Health Tracker for example your mood; available only for some versions of our Services), Medical Conditions (such as high blood pressure, smoker, coronary artery/heart disease, stroke, chronic kidney disease, diabetes, obesity, chronic obstructive lung disease, cancer), Health Info such as Medical and Family History (of diseases such as coronary artery disease, diabetes, stroke, specific cancers), Vital Signs (including heart rate, blood pressure, oxygen saturation, temperature, weight and height), Lifestyle and Health Assessments (such as mood assessments).
Additional Users Profiles - name (family name not required), year of birth, gender.
Third Party Profile - name (family name not required), year of birth, gender.
Chat and Health Profile History (your search history, selected symptoms, duration, rejected symptoms, questions and answers to clarify symptoms, probable conditions, personal factors that affect the diagnosis (age and gender), reasons for you not understanding our Symptom Checker, whether the questions asked are deemed relevant, the fact that you do not have the condition our Symptom Checker calculated based on your entries, Push Notification tokens, triage message, consultation ID).
USE OF INFORMATION
We use your data to provide our Services and to make constant improvements with troubleshooting, testing, research, internal analytics and surveys to ensure the best user experience. When you use the services of any of the Providers available through our OneStop Health™ Platform you accept our Provider’s privacy policies available in the section “Our Providers".
We use Your Profile (and Additional User profiles you may insert) information for the purposes of the Symptom Checker to help us better understand your reported symptoms. We normally do not tie Your Profile with the Health Profile when checking the performance of the Services. In limited cases, we need to tie Your Profile/Health Profile by using IP address/Profile ID for solving technical errors, bugs, security and clinical safety reasons as well as to distribute answers. You can set up an account by signing in with your Google or Facebook account. By doing so you give us permission to access and use your information as permitted by such services. We will use your Google/Facebook email address and registered name obtained from such services for identification purposes. If you use the same Google/FB account for Web App and mobile App sign in, you will be able to access past consultation Reports from Web App in our mobile App. This would also mean that we can send you Notifications to Mobile App based on your behaviour in our Web App. We might also start offering signing in with your email address and a password, which shall be done with the help of Firebase Authentification tool.
*Pseudonymisation is a procedure by which identifying fields within a data record are replaced by one or more artificial identifiers, or pseudonyms. There can be a single pseudonym for a collection of replaced fields or a pseudonym per replaced field. This means the processing of personal data is done in a manner that the personal data can no longer be attributed to you. It is done without the use of additional information, provided that such additional information is kept separately and is subject to technical and organisational measures to ensure that Your Profile data are not attributed to you in an identifiable form.
We do not use this data for the Symptom Checker's calculation: health tracker data such as mood, step metrics, your Notes, weight, heart rate, blood pressure, sleep, Influencing Factors (such as high blood pressure, smoker, coronary artery disease, stroke, chronic kidney disease, diabetes, obesity, chronic obstructive lung disease, cancer), Family History (of diseases such as coronary artery disease, diabetes, stroke, specific cancers), Vital Signs (including heart rate, blood pressure, oxygen saturation, temperature, weight and height) and your Subjective Scores (such as mood assessments) for Symptom Checker calculation.
OneStop Health™ Platform
Our Health Tracker service enables you to store information about your wellbeing and your Chat History (for some versions, while in other consultations are stored in the "Profile" area of our Services under section "Consultations"). Some version will store this information only if you tell us that the result of our Symptom Checker was useful. Newer versions allow you to delete Consultation Reports by clicking on the trash bin icon at the top right side of the Report. You can also add your own data via the notes section (only in some versions of our Services) and sync with your health and fitness apps data to get useful insights relevant for your health. We will use this data on pseudonymised basis to help improve our Services. Some versions enable storing your own Notes. Notes will be stored for your convenience only and will not be used by us. You can access your Notes by contacting us at email@example.com when using the versions without the Notes feature available. Please make sure you do not store any sensitive information (such as but not limited to medical health records, doctor's diagnosis, prescriptions etc.) in Notes. We store this information only in technical logs, but not in Your Profile and we do not use them for the Symptom Checker calculation.
Quizzes, Self-Assessments and Tools, BMI calculator, Top Tips.
We store the data related to your interactions with these sections and use them solely to improve the user experience. We do not take this data into account when you are using the Symptom Checker and we do not add it into Your Profile. We collect your answers to our quizzes, self-assessments, BMI calculator and the scores/outcome.
Health A-Z (Health Library)
You can find health information within the "Health A-Z" ("Library") section of our Services. You can store preferred Articles in newer versions of our Services by clicking on the "Save Article" icon and the Article will be saved in the "Health A-Z" under the "Saved Items" section. You can review saved articles without an internet connection.
HealthKit for iOS users
Our App uses HealthKit to make your user experience better. Any personal data gathered from HealthKit and also any other health or fitness data (“HealthKit Data") gathered from our Services will never be used for advertising or data mining purposes neither used for, or disclosed to any third parties. We will use HealthKit Data solely for providing our Services, namely for the purpose of providing health, motion, and/or fitness services in connection with our Services, to improve health management, or for the purpose of health research, all with your permission only. We do not conduct health-related human subject research.
Influencing Factors, Family History, Vital Signs, Your Subjective Scores
Influencing Factors (such as high blood pressure, smoker, coronary artery disease, stroke, chronic kidney disease, diabetes, obesity, chronic obstructive lung disease, cancer), Family History (of diseases such as coronary artery disease, diabetes, stroke, specific cancers), Vital Signs (including heart rate, blood pressure, oxygen saturation, temperature, weight and height), lifestyle and health assessments (such as mood assessments) can be collected if you decide to voluntarily share them with us, but won't be used for the Symptom Checker's calculation. This data is stored in the Health Profile.
We also give your data to Kickbox, the email address verification service provider we use to validate email addresses and find out whether or not they can be delivered to. Kickbox collects information under our direction. They may transfer personal information to companies that help them provide their service to us. Transfers to subsequent third parties are covered by the service agreement between Kickbox and us. Kickbox acknowledges that you have the right to access your personal information. Kickbox has no direct relationship with you. If you seek access, or to correct, amend, or delete inaccurate data you should direct your query to the us by sending an email to firstname.lastname@example.org. If requested to remove the data Kickbox will respond within 30 business days. Kickbox will retain personal data they process on our behalf for as long as needed to provide services to us. Kickbox will retain this personal information as necessary to comply with their legal obligations, resolve disputes, and enforce their agreements. For more information about Kickbox data processing visit https://docs.kickbox.com/v2.0/docs/privacy-policy#section-the-organization-collecting-information-at-this-website.
When we collect your email by conducting a Survey, we will use it only for the purposes of the Survey. If you for example confirm that you would like to receive notifications when we develop a specific feature, we will inform you when this feature is available. If you carry out a risk assessment survey, we will send you the results of the assessment via email.
Improving our Services
We use your data to improve our services and your experience with conducting internal analytics, troubleshooting, root cause analysis in the event of an error or bug, testing, research and surveys. We store your Health Profile and Your Profile data in separate databases, meaning that whatever you type into our chat is not connected to information that could personally identify you (Your Profile data). This way we can check how well we did without knowing anything personal about you. For example, if we want to improve the Health Tracker, your data will be aggregated in most cases and if we need to access a specific Profile, we will do so by using the Your.MD ID so that your name or email will not be seen or needed. In limited cases, we will need to access your Chat History and IP address/Your.MD identifier/Consultation ID to trace bugs, solve technical errors, ensure technical and clinical safety and distribute answers.
We cannot provide all services necessary for the successful operation of our Services by ourselves. We therefore share collected information with our Providers for the purposes of offering the Services to you and improve your user experience.
We use the information we collect with the help of our Analytics Providers to constantly improve our Services and make it better for you. We chose our Providers carefully and we set the most restrictive controls they offer to ensure they do not use your data for any purposes other than providing services to us. The Analytics Providers process the information we share - namely various information on how you use the Services by their own unique user ID’s, but they also have access to your IP address. We do no share your name, email or Profile ID’s with analytics providers, but they have access to the year of birth, gender, country & region (but not street level), push notification preferences (signing up for Health Goals) and acquisition channel.
Analytics Providers are considered as data processors according to the GDPR. That means that they collect and process data on our behalf, pursuant to our instructions. We are data controllers who retain full rights over the collection, access, retention, and deletion of our/your data at any time.
Analytical Providers’ use of data is controlled by the terms of their contract with us and any settings enabled by us through the user interface of their product.
Google Analytics for Firebase
Google Analytics for Firebase Analytics allows us to collect data on the usage of the Services via our mobile App and also when you are using our Services as a Guest. We use your data only for the purposes of our internal analytics to improve our Services and we do not allow sharing of your data with other parties and their products or services. Google Analytics for Firebase collects these data: Online Identifiers, including cookie identifiers, IP Address and device identifiers. Google Analytics for Firebase collects an App-Instance Identifier — a randomly generated number that identifies a unique installation of an App for the first time. We are using the following Google Analytics for Firebase features: Authentication, Remote Config., Crash Reporting, Events (about usage of our App in an pseudonymized way), Analytics in general, Firebase Cloud Functions and Firebase Communication Manager. We use the Firebase Authentication only to enable you to sign in with your Google or FB account, to facilitate your account management. Firebase Authentication uses your data, namely your Password, Email address, Phone number, User agent and IP address. It also uses user-agent strings and IP addresses to provide added security and prevent abuse during sign-up and authentication. It keeps logged IP addresses for a few weeks and retains other authentication information until the Firebase customer initiates deletion of the associated user, after which data is removed from live and backup systems within 180 days.
We do not collect any other data from your Google or FB account and we so not send any data to Google or FB. We use Firebase Analytics' own unique user ID (app.instance id), which does separate one mobile phone from another, but does not personally identify you.
For more information, please see
AWS Analytics does not access or use your data for any purpose other than to provide services to us, as legally required and for maintaining the AWS services. We have chosen strong encryption for your data. For more information, please see AWS Analytics is only use in our iOS app.
When you visit the Web App (even if as Guest user) or our website, your web browser automatically sends the IP address and information on how you use the Services. We use your data only for the purposes of our internal analytics to improve our Services. We do not use any other features apart from the Google Analytics ("GA") and we do not allow sharing of your data with Google’s other products and services. We never disclose any of your Chat History to Google. Google can share your data only in limited situations where a) it concludes that it is required by law or has a good faith belief that access, preservation or disclosure of customer data is reasonably necessary to protect the rights, property or safety of Google, its users or the public; or b) in certain limited circumstances when third parties carry out tasks on Google's behalf (e.g., data storage) with strict restrictions that prevent the data from being used or shared except as directed by Google. GA uses IP addresses to provide and protect the security of the service, and to give website owners a sense of where in the world their users come from (also known as "IP geolocation"). Apart from this GA works on aggregated data. Google Analytics provides a method to mask IP addresses they collect, and we requested such masking. When using our Web App as a Guest user, we are not able to see which sessions come for the same individual.
Google Analytics collects first-party cookies, data related to the device/browser, IP address and on website/Web App activities to measure and report statistics about your interactions on our website and/or Web App.
Google Analytics uses IP addresses to derive the geolocation of a visitor, and to protect the service and provide security to us. We have requested IP address anonymisation which means that Google Analytics anonymises the address as soon as technically feasible at the earliest possible stage of the collection network. The IP anonymisation/masking takes place as soon as data is received by the Analytics Collection Network before any storage or processing takes place. The full IP address is never written to disk in this case. Please find more information on IP Anonymisation in Analytics using this Url https://support.google.com/analytics/answer/2763052.
Google uses Google Analytics data to provide the Google Analytics measurement service to us. Identifiers such as cookies and app instance IDs are used to measure user interactions with our Website and/or Apps, while IP addresses are used to provide and protect the security of the service, and to give us a sense of where in the world you come from.
Data Retention. With the Data Retention controls, we can limit or expand the duration for which user-level and event-level data is stored in Google Analytics servers.
User Deletion. We are able to request deletion of a single user’s data from Google Analytics by passing a single user identifier to the Google Analytics User Deletion API.
User-level Data Access and Portability. We may pull event information for any given user identifier via our User Explorer report. This feature enables us to analyse and export event level data for a single user. In addition, our 360 customers may integrate with BigQuery to create a full export of all event data associated with their users in a single query able repository.
Data privacy and security. Google has EU Privacy Shield certificate and uses standard ISO 27001 security measures.
For more information, please visit https://www.privacyshield.gov/participant?id=a2zt000000001L5AAI and https://www.iso.org/isoiec-27001-information-security.html.
For more information about Information security and Operational security and disaster recovery please visit: https://support.google.com/analytics/answer/6385009, https://support.google.com/analytics/answer/6004245.
Please see these links for general information: https://www.google.com/policies/privacy/partners, https://support.google.com/analytics/answer/6004245?hl=en, https://www.google.com/policies/privacy/.
Google Analytics Cookies
AppsFlyer provides a software development kit which allows the tracking of mobile application use, installations and downloads. We use it as a download attribution (basically analytics) that allows us to determine where a user came from (e.g. Facebook, Google Ads, organic user). We use it to track and analyse the characteristics and your activities, and for such purpose upload some of your data to their platform and servers. Such data is provided to AppsFlyer by integration and implementation of AppsFlyer’s SDK and APIs into our App. The data they receive from us refers to downloads, impressions, clicks and installations of our mobile applications, mobile device usage and data regarding in-app events. We may use their services to collect and analyze the data parameters, namely (i) unique identifiers and technical data, such as IP address, User agent, IDFA (Identifier For Advertisers) or Android ID (in Android devices); (ii) technical data regarding your operating system, device attributes and settings, applications, advertising opt-out signals, Google Advertiser ID, in-app events, device motion parameters and carrier. AppsFlyer’s data is stored on EU-based servers as well as on AWS and Google Cloud in the US.
The personal data collected or processed through AppsFlyer Services will be used for: (i) creating aggregate data and anonymous data, (ii) providing the Services, and (iii) improving and maintaining their Services. For example, they use such data to help diagnose problems with their servers, to diagnose and prevent fraudulent activity, to consider and develop new services and features and to improve the services and make them more useful.
Fabric is a business division of Google Inc. and we use their service “Fabric Crashlytics” for crash reporting and beta testing of our mobile App. It helps us understand what’s happening in our App, by providing us information about the functioning of publicly released and beta versions of our App.
Crashlytics collects information that includes, but is not limited to, device state information, unique device identifiers, device hardware and OS information, information relating to how an application functions, and the physical location of a device at the time of a crash. They also collect personal information, namely Installation UUID and crash traces. They use this data to help us associate crash data with specific instance of our app. Crash traces and their associated identifiers are kept for 90 days.
Crashlitycs transfer, store, and use your information in the United States and any other country where they or any third party service providers acting on their behalf, operate. The privacy and data protection laws in some of these countries may vary from the laws in the country where you live.
The information Crashlytics collects about you and your activities is our property, not of Crashlytics. The information collected by the Services that you use is used to provide us with insight into the functionality of and engagement with our Apps, including any problems that occur. Crashlytics algorithms process and analyse the data separately for each application provider ("Developer"). However, Crashlytics may aggregate information across Developers in a non-personally identifiable way. Such aggregate and anonymous information is used by Crashlytics to (i) improve the Services, (ii) create analysis of trends or behaviors, and (iii) other similar uses, but always in an aggregate and anonymous way.
Crashlytics and Google Inc. comply with the EU-US Privacy Shield principles regarding the collection, use, sharing, and retention of personal information from the European Union.
For more information about Fabric data processing, plase visit: https://try.crashlytics.com/terms/privacy-policy.pdf?utm_source=email&utm_medium=email&utm_campaign=fabric_gdpr https://docs.fabric.io/android/fabric/data-privacy.html#identifiable-data-collected, https://policies.google.com/privacy
Our Internal Analytics
Our internal analytics is based on using Chat History and an IP address/Your.MD identifier/Consultation ID, but the data is stored in a separate database. This means we can review Chat History without seeing any of Your Profile data, so your data is kept confidential with pseudonymisation. We analyse Chat History to constantly improve our Services and make them better for you.
ONLINE SURVEY PROVIDER
Is an online software service company that specializes in online form building and online surveys that we use for our online surveys. For more info about Typeform, please see https://www.typeform.com/. When you decide to participate in one of our Surveys, Typeform will collect this information: your responses (that are managed by us and we take the responsibility for such data which may include personal data), usage data (data about interaction with Typeform services), device and application data (IP address, browser type, operating system, geolocation), referral data (the source that referred you to us – link on Site, email etc.), email address (to send you typeform notifications email). All data is hosted on Amazon’s AWS service. Their main servers are located in Virginia, USA and backup servers are located in Frankfurt, Germany. They use TLS to secure all data in transit. More information on https://www.typeform.com/help/what-happens-to-my-data/. Please see the Opt Out section for more rights on Typeform data processing.
SUPPORT REQUEST PROVIDER
WHEN REQUESTING SUPPORT BY SENDING US AN EMAIL TO CARE@YOUR.MD OR/AND PRIVACY@YOUR.MD DO NOT SEND ANY OF YOUR HEALTH DATA AS OUR SUPPORT SYSTEM AND AGENTS ARE NOT DOCTORS AND CANNOT HELP YOU WITH YOUR MEDICAL QUIARIES.
We use Zendesk® (Zendesk, Inc.) as a support ticket system that allows our support agents to streamline our communications in a single ticket, all within an organized workflow. This leads to quicker resolution of individual support requests. If you will reache out us again, our support agent will automatically have access to important information about you, including when you last requested support, what the issue was, how it was resolved, and even how long you had to wait for a resolution.
Data collection/processing. When you send a support request to email@example.com or firstname.lastname@example.org, Zendesk collects your electronic data, text or. message included in the support request, communications or other materials submitted to and stored in or transmitted via the Zendesk in connection with our use of their Service, which may include, without limitation, Personal Data, namely IP address, email address, “cookie” information and the type of browser and/or device being used to access the Services. They use the collected data to help us access and use the services, to respond to your inquiries, send communication related to the services, and to operate and improve their services. When they collect this information, they only use this data in aggregate form, and not in a manner that would identify you personally. For example, this aggregate data can tell them how often you use a particular feature of the services, and they can use that knowledge to improve their services. Throughout the time that we subscribe to services with Zendesk, we retain ownership of and control over all the data (your/our) in our account.
Disclosure of Data. Zendesk only discloses the data to third parties where disclosure is necessary to provide the services or as required to respond to lawful requests from public authorities. They never sell, rent, or lease our/your data to any third party.
Data Security. They provide us compliance with high security standards, such as encryption of data in motion over public networks, auditing standards (SOC 2, ISO 27001, ISO 27018), Distributed Denial of Service (“DDoS”) mitigations, and a Support team that is on-call 24/7.
Access Management. Zendesk provides an advanced set of access and encryption features to help us effectively protect our/your information. They do not access or use our content for any purpose other than providing, maintaining and improving the Zendesk services and as otherwise required by law.
Zendesk has data centers in three main regions — United States, Asia Pacific, and the European Union. Service Data may be stored in any region, that means that your Personal data may be processed outside the European Economic Area.
Zendesk recognizes that privacy and data security issues are top priorities for us and has achieved a number of internationally-recognized certifications and accreditations (The EU-U.S. and Swiss-U.S. Privacy Shield, Binding Corporate Rules and others) demonstrating compliance with third-party assurance frameworks.
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, port or restrict processing of such personal information) you should direct your query to us. We will request then Zendesk to remove the personal information and they will respond to our request within thirty (30) days. They will retain personal information that they process and store on our behalf for as long as needed to provide the Services to us. For more information, please visit:
We use third party providers to advertise our Services and acquire new users.
We use AdWords, Google’s online advertising program to reach new customers and grow our business. We use features as Search Ads, Display Ads and App Ads. More information about these features on https://adwords.google.com/intl/en/home/how-it-works/.
Cookies help to make advertising more effective. Without cookies, it’s harder for us to reach our audience, or to know how many ads were shown and how many clicks they received. When you visit our Site or see an ad that uses AdWords, either on Google services or on other sites and apps, various cookies may be sent to your browser. These may be set from a few different domains, including google.com, doubleclick.net, googlesyndication.com, or googleadservices.com, or the domain of Google’s partners’ sites.
ONESTOP HEALTH™ PLATFORM PROVIDERS
We will not provide any of Your Profile or Chat History information to our Providers. We choose our Providers carefully and we request that they use your data solely for the purposes of providing their services to you. If you click on the link provided within the chat or click on one of the Providers within the OneStop Health™ section of our Services, you will leave our Services and be redirected to our Providers’ service. Please be aware that by doing so, your data processing will be governed by our Provider’s Privacy Policies. Please see the links below.
Although we choose our Providers carefully, we are not responsible for the actions of these companies, the content of their sites, products or services, the use of information you provide to them, or any products or services they may offer. Our links to the OneStop Health™ Platform Providers and any other third parties’ services does not constitute our sponsorship of, or affiliation with, these companies. Nor is such linking an endorsement of such third party’s privacy or information security policies or practices, or their compliance with laws. Information collected by third parties, which may include personal information is governed by their privacy practices. The Providers and other third parties websites or services may place their own cookies or other files on your computing or smart device, collect information or solicit personal information from you. We encourage you to learn about the privacy practices of Providers and third parties with which you interact. We are not responsible or liable for your interaction with Providers and third parties, the information requests initiated by them, or the subsequent use, treatment or dissemination of information you voluntarily choose to provide to them.
Ask The Midwife
Doctor Care Anywhere
Doctor On Call
Drug Free World
Hay Fever Relief
London Osteoporosis Clinic
Marie Stopes International
MDalgorithms – MDAcne
My Pocket Doctor
National Migraine Centre
We are currently migrating to our own internal tracking and HOKO is not longer providing tracking services. HOKO will kept access to the data until the migration is successfully finished. Our tracking works in the similar way as HOKO and is based on our own tracking code that is shared with our OneStop Health™ partner for billing purposes only.
HOKO tracking. In order for our Services to be free, we need to know how many users visit our OneStop Health™ Providers. We used to use the HOKO tracking Provider to track the visits to OneStop Health™ Providers from our Services. HOKO can use the data collected from you solely to the extent needed to track sessions for Your.MD and to adapt the service to our preferences, whereas any other usage of such data including, but not limited to, building a users’ profile, tracking for the purposes of behavioral advertising, disclosing users’ data to third parties is strictly prohibited. HOKO may transfer (or otherwise make available) data only to third parties that process such information on HOKO's behalf in order for HOKO to be able to provide the HOKO Service, under the condition that such third parties adhere to the same limitations about the usage of data as HOKO. We plan to use our own tracking and stop using HOKO in the future.
For more information, please see
THIRD PARTY TECHNOLOGY
To make our Services simple to use, you can use it with these messengers: Telegram, Kik and Skype (“Messengers"). To make our Health Tracker more efficient, you can also sync your data from other service providers with our Health Tracker. When you use our Services via Messengers or in combination with other services, your data processing is governed by their individual privacy policies you accepted when registering for their service, so please read their respective privacy policies carefully before you start using their services.
When using Messengers you are able to chat with our chatbot available on the selected messenger. Features like the Library, OneStop Health platform, Health Tracker, Consultation history or Profile are not included in messengers. However you are able to access Articles and OneStop Health™ Providers via Chat (e.g. if you search for “Migraine” we will show the Migraine article which you will be able to view on our website and/or if you search for a OneStop Health™ Provider by entering its name you will be given information about the service they provide and how to access to it). All messengers sessions use an operational system called Morse that does the integration of the individual messenger platform into our systems. Via Morse the Messengers are able to use the same internal systems as our App uses, including Your Profile and Health Profile.
Messengers data Processing
We collect Health Data that you enter during the consultation as well as general personal information about you, namely the year of birth and your gender. By entering this data our chat bot is able to calculate the most likely condition based on your reported information and symptoms. We will capture the IP address in our technical logs and fully encrypt them. The technical logs are expired (deleted) after six months. We will not be able to reveal the IP address, but shall use the logged data that includes the encrypted IP address for security to ensure root cause analysis of bugs and outages, and for safety validation. We anonymize chat personal and profile data (age, gender) by storing it in a separate database which contains not personally identifiable information, and hence this data cannot be tied back to any personally identifiable information such as the IP address. Messengers might send us personal information you authorise them to share with us when you give your consent. This includes an identifier they use for your account and account data. The unique ID that is given to you and comes from the messenger platform to us it is not personally identifiable identifier (we cannot see who you are) and it is always the same. It enables us to see when “you” return to use our service.
FB and Google Accounts
You can set up an account by signing in with your Google or Facebook account. By doing so you give us permission to access and use your information from that service as permitted by that service. We use your email to identify your identity in the Profile tables. We enable Google or Facebook authentication when you use Web App or mobile App. This way you can access past consultation reports from the Web App when you log in to mobile App with the same credentials. Some services enable you to use them as a Guest, so without Google/FB authentification, but this means that you will not be able to retrieve your information.
SHARING OF INFORMATION
Sometimes we need to disclose the Information for other lawful purposes, as customary for all developers.
Apart from sharing the information with our Analytics and OneStop Health™ Providers, as stated in Section “Our Providers" and “Usage of Information", we may also disclose information in the following cases:
if required by law, for example to comply with a court order, subpoena, regulation, legal process or other governmental request;
to exercise or protect the rights, property or personal safety of the Company, our users or others;
to enforce this privacy statement, including investigation of potential violations thereof;
upon fulfilling legal requirements of local legislation to supply certain services/information a third party might legally request from us
to detect, prevent, or otherwise address fraud, security or technical issues;
if Your.MD is 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 information via our website;
to respond to claims that any content published within our Services violates any right of a third party;
STORING OF INFORMATION AND SECURITY
We follow generally accepted industry standards and internal procedures to protect information submitted to us, during transmission, storing and processing. We are encrypting all user and profile data at rest and all personal information is double encrypted with two keys at both the infrastructure and application level. 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 or associated back to you. We delete the logs that we keep of the IP addresses you have used after approximately 6 months. If you have any concerns about the security of our Services, please contact us at email@example.com.
We have restricted access to production environments and monitoring of user activities. The information is encrypted and key protected, and we have integrated commercially reasonable efforts to assure that your information remains secure when maintained by us. However, please be aware that no security measures are perfect or impenetrable.
To ensure security of processing we engage third party providers for penetration testing (“Security Testing”) - a controlled form of hacking in which a professional tester, working on behalf of an organization, uses the same techniques as a criminal hacker to search for vulnerabilities in the company’s networks or applications. Please be aware that during Security Testing, the third-party provider may have access to Your Profile and/or Health Profile data (“Your Data“). We contractually bind providers of Security Testing to take all necessary technical and organizational measures to protect Your Data and they are not allowed to transfer Your Data to third parties or to use it for any other purposes than to perform the Security Testing for us.
We use AWS hosting for storing of information and they provide multiple security certificates. For more information, please see https://aws.amazon.com/security/.
DELETION OF INFORMATION
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. When the information is no longer needed, we shall delete it using reasonable measures to protect the information from unauthorized access or use. We will delete the personally identifiable data within 30 days of the receipt of your request.
Storing might be different depending on the territory of collecting the information and the applicable legislation, but we always strive to store the information only as long as it is needed for the purposes of providing, improving or personalizing our Services.
We make sure we do not collect more information than is needed to provide our Services and we strive to limit our Providers to do so as well. We have integrated protocols to allow us to process Chat History in a pseudonymized way, but you are always free to opt out of the information collection by not using our Services or uninstalling the App.
You can deactivate notifications by changing the notification settings in accordance with the instructions of the operating system running on your device.
E-mail: You can opt out from e-mail notifications by unsubscribing or sending us a request to firstname.lastname@example.org or email@example.com. If you seek access, or to correct, amend, or delete inaccurate data held by Kickbox, you should direct your query to firstname.lastname@example.org. If requested to remove the data Kickbox will respond within 30 business days.
iOS: You will be asked to accept or refuse push notifications after the App is downloaded. If you do not accept, you will not receive push notifications. Please note that if you accept, mobile phones will allow you to disable push notifications later on by using the settings on your mobile phone.
Android: After an App is downloaded, you will automatically receive push notifications. You can always disable those within the mobile phone settings.
Health Goals: You can turn on/off the Health Goals notifications in the Profile Section of our Services.
Analytics: You can opt out of our information processing and Google Analytics for Firebase by sending an email to email@example.com and/or opt out of Google Analytics by installing this browser add-on https://tools.google.com/dlpage/gaoptout. 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. Note that this add-on only disables Google Analytics measurement.
You can opt-out of AppsFlyer Analytics tracking by yourself by sending an email to firstname.lastname@example.org or by completing the form on their website https://www.appsflyer.com/optout. The opt-out is specific to AppsFlyer activities and does not affect other tools that we may use. If you choose to opt-out, AppsFlyer will stop tracking data for that device going forward. The services will stop across all applications on not only ours.
Deleting Your Account: If you do not want to use our Services anymore, you can always delete the Mobile App and/or stop using the Web App and/or Messengers. We will delete your account on receipt of the request sent to email@example.com. The same will be done if you withdraw your consent for data processing needed to provide Your profile and the Services. We reserve the right to delete your account after a long period of inactivity. We will delete the personally indetifiable data within 30 days of the receipt of your request.
Telegram messenger: Telegram has developed a new @GDPRbot to enable you to: Request a copy of all your data that Telegram stores and to Contact Telegram's Data Protection Officer. For more information visit https://telegram.org/faq#q-what-about-gdpr.
Typeform: Enables you to exercise your right to access, rectification, erasure, restriction and objection by opening a support ticker via the Help Centre. You can send a request via https://typeform.com/help.
Kik: You can request deletion, correction or updating of your personal information by following the instructions EUROPEAN USERS available here https://www.kik.com/privacy-policy/.
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, port or restrict processing of such personal information) you should direct your query to us. We will request then Zendesk to remove the personal information and they will respond to our request within thirty (30) days. They will retain personal information that they process and store on our behalf for as long as needed to provide the Services to us.
As you can see we use our Providers for limited purposes only and we strive to limit their usage of the information. For this reason we do not offer Provider specific opt-out service, but you can always opt out from analytics and tracking we use by uninstalling our App or stop using our Services. You can opt out from Third Party Technology (messengers we use) and OneStop Health™ Platform data collection by not using these specific services. You can use some of our Services as a Guest, meaning that minimal amount of data to offer the Services and no personal information that could directly identify you will be collected.
GA help us understand how our visitors engage with our Services. They may use a set of cookies to collect information and report Site usage statistics without directly personally identifying individual visitors to Site. We use the data collected by GA to help us improve the quality of our Site and to analyse Site usage. GA processes the information we share - namely various information on how our users use the Site using their own unique user ID’s, however they also have access to our users IP address and any other data that they collect from our users directly. GA stores cookies on users’ device to keep track of how they use our Site. We can use such analysis to gain insights about how to improve the functionality and experience of the Site.
When you visit our Site, your web browser automatically sends the IP address and information on how you use the Services to us. We use this data only for the purposes of our internal analytics to improve our Services. We do not use any other features apart from the GA and we do not allow sharing of their data with Google’s other products and services.
Limited information we collect via Website: User agent (web browser type and version), screen information, geolocated country and region, time zone, IP address at the time of usage, Acquisition channel (on which ad from Google/Facebook you clicked to get to our Website, which channel was used to get our Website), Logs with technical information, Logs on users’ usage of the Website (articles you view in the Health A-Z, partners you view on OneStop Health™ Platform, clicks on OneStop Health™ partners), General Analytics (general activity within the Website such as whether they view the About Us section etc.), Screen Activity (every screen they view, time spent on a specific screen).
The Services are also offered via our Web App at webapp.your.md. The Web App offers limited functionality as explained in our Terms of Service. You can use our Web App only as "Guest". For more information on Guest user data processing, please see the GDPR statement. Google Analytics provides a method to mask IP addresses they collect, and we requested such masking. When using our Web App as a Guest user, we are not able to see which sessions come for the same individual. Google Analytics collects first-party cookies, data related to the device/browser, IP address and on website/Web App activities to measure and report statistics about your interactions on our website and/or Web App. We do store IP address in our technical logs, but are not using it. We use technical and health data for internal statistics on aggregated level.
CONTACT AND ACCESS TO PERSONAL INFORMATION
If you have any questions, please contact us at: firstname.lastname@example.org
Your.MD is a trademark of YOUR.MD AS, incorporated and registered in Norway with company number 999260993 whose registered office is at c/o Advokatfirmaet Simonsen Vogt Wiig AS, Filipstad Brygge 1 , 0252 Oslo,Norway and it is offering the Your.MD Services (hereinafter referred to as: “Services" or “App") via its subsidiary Your.MD Limited, incorporated and registered in UK with company number 08727263 whose registered office is at this date at Your.MD Ltd, 5th Floor, 43 Whitfield Street, London, W1T 4HD, UK (hereinafter collectively referred to as: "Your.MD").
We are committed to keep your information accurate, complete and up-to-date. You can request that we correct or delete the information, provided that we are not required to retain such information by law or for legitimate business purposes. To make such request or ask us about this privacy statement please send us an email to email@example.com. We may decline to process requests that are unreasonably repetitive, require disproportionate technical effort, jeopardize the privacy of others, are extremely impractical, or for which access is not otherwise required by local law. We will not respond to any inquiry emails which we are not able to understand, the request is not clearly specified or to health questions.
Data Protection Officer. Should you have any data processing or privacy related questions, please contact us at: firstname.lastname@example.org. In case we are not able to help or upon your appeal, we will forward your inquiry to our External Data Protection Officer, ePrivacy GmbH, represented by Prof. Dr. Christoph Bauer, Große Bleichen 21, 20354 Hamburg. Should you have any concerns or complaints we or our DPO is not able to solve, 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, https://datenschutz-hamburg.de/pages/kontakt/ or if you are a UK customer, with Information Commissioner's Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF, https://ico.org.uk/make-a-complaint/.
Matteo Berlucchi, CEO