Privacy Policy

1. Privacy Policy Introduction

1.1 We are committed to safeguarding the privacy of our website visitors and those that use our Health Apps; in this policy we explain how we will treat your personal information. 1.2 By using our Health Apps and this website, you agree with this privacy policy.

2. Collecting Personal Information

2.1 We may collect, store and use the following kinds of personal information: a. information about your computer and about your visits to and use of this website including your IP address, geographical location, browser type and version, operating system, referral source, length of visit, page views and website navigation paths; b. information that you provide to us when registering with our website or as a user of our Health Apps, including your email address c. information about you as medical patient provide to us by your medical provider or the NHS to enable us to perform our services including your name, gender, date of birth, NHS Number, relationship status, relevant medical history, contact details and employment details; d. information about you as user of our Health Apps and services, as provide to us by yourself or your employers, including your name, profile pictures, date of birth, job title, billing information, contact details, company name and address; e. information that you provide to us for the purpose of subscribing to email notifications and/or newsletters including your name and email address; f. information that you provide to us when using the services on our website, or that is generated in the course of the use of those services including the timing, frequency and pattern of service; g. information relating to any purchases you make of our services including your name, address, telephone number and email; h. information that you post to our website for publication on the internet including your username, your profile pictures and the content of your posts; i. information contained in or relating to any communication that you send to us or send through our website (including the communication content and meta data associated with the communication; and j. any other personal information that you choose to send to us. 2.2 Before you disclose to us the personal information of another person, you must obtain that person’s consent to both the disclosure and the processing of that personal information in accordance with this policy.

If you are receiving care from a health or care organisation, that organisation may share your NHS number with other organisations providing your care. This is so that the health and care organisations are using the same number to identify you whilst providing your care. By using the same number the health and care organisations can work together more closely to improve your care and support. Your NHS number is accessed through an NHS England service called the Personal Demographic Service (PDS). A health or care organisation sends basic information such as your name, address and date of birth to the PDS in order to find your NHS number. Once retrieved from the PDS, the NHS number is stored in our case management system. These data are retained in line with our record retention policies and in accordance with the Data Protection Act 1998, Government record retention regulations and best practice. Further information is available on our website. We will share information only to provide health and care professionals directly involved in your care access to the most up-to-date information about you. Access to information is strictly controlled, based on the role of the professional, and where the user has a direct care relationship with you. The use of joined up information across health and social care brings many benefits. One specific example where this will be the case is the discharge of patients into social care. Delays in discharge (commonly known as bed blocking) can occur because details of social care involvement are not readily available to the staff on the hospital ward. The hospital does not know who to contact to discuss the ongoing care of a patient. The linking of social care and health information via the NHS number will help hospital staff quickly identify if social care support is already in place and who the most appropriate contact is. Ongoing care can be planned earlier in the process, because hospital staff will know who to talk to. You have the right to object to the processing of your NHS number in this way. This will not stop you from receiving care, but will result in the benefits outlined above not being realised. To help you decide, we will discuss with you how this may affect our ability to provide you with care, and any other options that you have. If you wish to opt-out from the use of your NHS number in this way, you can contact us by emailing info@ufonia.com.

3. Using Personal Information

3.1 Personal information submitted to us will be used for the purposes specified in this policy or on the relevant pages of the website. 3.2 We may use your personal information to: a. administer our website and business; b. personalise and improve our website for you; c. enable your use of the services available on our website; d. supply to your services purchased e. send statements, invoices and payment reminders to you, and collect payments from you; f. send you non-marketing commercial communications; g. send you email notifications that you have specifically requested; h. send you our email newsletter, if you have requested it you can inform us at any time if you no longer require the newsletter; i. send you marketing communications relating to our business [or the businesses of carefully-selected third parties which we think may be of interest to you, by post or, where you have specifically agreed to this, by email or similar technology you can inform us at any time if you no longer require marketing communications; j. provide third parties with statistical information about our users (but those third parties will not be able to identify any individual user from that information); k. deal with enquiries and complaints made by or about you relating to our website; l. keep our website secure and prevent fraud; and m. verify compliance with the terms and conditions governing the use of our website including monitoring private messages sent through our website private messaging service. n. undertake research including using anonymised data, to support the broader ongoing development of our Health Apps and related services 3.3 If you submit personal information for publication on our website, we will publish and otherwise use that information in accordance with the license you grant to us. 3.4 Your privacy settings can be used to limit the publication of your information on our website and can be adjusted using privacy controls on the website. 3.5 We will not, without your express consent, supply your personal information to any third party for the purpose of their or any other third party’s direct marketing. 3.6 We will not, without your express consent, use your personal information to undertake research to support our solutions and service

4. Disclosing Personal Information

4.1 We may disclose your personal information to any of our employees, officers, insurers, professional advisers, agents, suppliers or subcontractors insofar as reasonably necessary for the purposes set out in this policy. 4.2 We may disclose your personal information to any member of our group of companies (this means our subsidiaries, our ultimate holding company and all its subsidiaries) insofar as reasonably necessary for the purposes set out in this policy. 4.3 We may disclose your personal information: a. to the extent that we are required to do so by law; b. in connection with any ongoing or prospective legal proceedings; c. in order to establish, exercise or defend our legal rights (including providing information to others for the purposes of fraud prevention and reducing credit risk); d. to the purchaser (or prospective purchaser) of any business or asset that we are (or are contemplating) selling; and e. to any person who we reasonably believe may apply to a court or other competent authority for disclosure of that personal information where, in our reasonable opinion, such court or authority would be reasonably likely to order disclosure of that personal information. 4.4 Except as provided in this policy, we will not provide your personal information to third parties.

5. Retaining Personal Information

5.1 Our data retention policies and procedure are designed to help ensure that we comply with our legal obligations in relation to the retention and deletion of personal information. 5.2 Personal information that we process for any purpose or purposes shall not be kept for longer than is necessary for that purpose or those purposes. 5.3 Notwithstanding the other provisions of this Section 6, we will retain documents (including electronic documents) containing personal data: a. to the extent that we are required to do so by law; b. if we believe that the documents may be relevant to any ongoing or prospective legal proceedings; and c. in order to establish, exercise or defend our legal rights (including providing information to others for the purposes of fraud prevention and reducing credit risk).

6. Security of Personal Information

6.1 We will take reasonable technical and organisational precautions to prevent the loss, misuse or alteration of your personal information. 6.2 We will store all the personal information you provide on our secure (password- and firewall-protected) servers. 6.3 All electronic financial transactions entered into through our website will be protected by encryption technology. 6.4 You acknowledge that the transmission of information over the internet is inherently insecure, and we cannot guarantee the security of data sent over the internet.

7. Amendments

7.1 We may update this policy from time to time by publishing a new version on our website. 7.2 You should check this page occasionally to ensure you are happy with any changes to this policy. 7.3 We may notify you of changes to this policy by email

8. Your Rights

8.1 You may instruct us to provide you with any personal information we hold about you; provision of such information will be subject to: a. the payment of a fee (currently fixed at GBP 10); and b. the supply of appropriate evidence of your identity [(for this purpose, we will usually accept a photocopy of your passport certified by a solicitor or bank plus an original copy of a utility bill showing your current address)]. 8.2 We may withhold personal information that you request to the extent permitted by law. 8.3 You may instruct us at any time not to process your personal information for marketing purposes. 8.4 In practice, you will usually either expressly agree in advance to our use of your personal information for marketing purposes, or we will provide you with an opportunity to opt out of the use of your personal information for marketing purposes.

9. Third Party Websites

9.1 Our website includes hyperlinks to, and details of, third party websites. 9.2 We have no control over, and are not responsible for, the privacy policies and practices of third parties.

10. Updating Information

10.1 Please let us know if the personal information that we hold about you needs to be corrected or updated.

11. Cookies

11.1 Currently our website does not use cookies.

12. Data protection Registration

12.1 We are registered as a data controller with the UK Information Commissioner’s Office. 12.2 Our data protection registration number is ZA563562.

13. Our Details

13.1 This website is owned and operated Ufonia Ltd. 13.2 We are registered in England and Wales under registration number 10692039, and our registered office is at Oxford University Innovation Buxton Court, 3 West Way, Oxford, Oxfordshire, United Kingdom, OX2 0JB. 13.3 You can contact us: Email: DPO@ufonia.co