Anima / Privacy Policy

CONTINUUM HEALTH PRIVACY POLICY

Last updated 1 February 2021

 

Continuum Health Limited  is a limited company (registered number: 12205370) whose registered office is at 71-75 Shelton Street, Covent Garden, London, WC2H 9JQ, United Kingdom ("Continuum Health", "us", "we" and "our"). Continuum Health respects your privacy and is committed to protecting your Personal Data (as defined below). This privacy policy (“Privacy Policy”) describes our practices in connection with information that we collect through: 

Collectively, we refer to the Websites, Apps, Social Media Pages, emails, and offline business interactions as the “Services.” 

WHAT WE COLLECT AND HOW WE COLLECT IT

“Personal Data” means any information about an individual from which that person can be identified. We will collect, store, use, and share Personal Data about you in accordance with this Privacy Policy.

Patients

 We collect and use the following categories of Personal Data of patients:

  • Contact details, such as name, date of birth, telephone number, email address and home address. 

  • Health data such as patients’ medical information, including medical symptoms, disabilities, details of medical conditions, medication taken and any other details related to your health that you provide to us.

Healthcare providers

We collect and use the following categories of Personal Data of doctors and/or physicians working at clinics: 

  • Contact details of healthcare providers, such as name, telephone number, email address, work postal address.

Website visitors

We collect and use the following categories of Personal Data of website visitors:

  • Contact details (including name, address, email, telephone number)

How We Collect Personal Data

We and our service providers collect Personal Data in a variety of ways, including:  

  • Through the Services. You may provide us Personal Data when you:

  • Request information in connection with the Services, or otherwise communicate with us;

  • Make use of our Services or assist in facilitating those services; or

  • Create a Continuum Health account on our Website or Apps.

We need to collect Personal Data in order to provide the requested Services to you.  If you do not provide the information requested, we may not be able to provide the Services. If you disclose any Personal Data relating to other people to us or to our service providers in connection with the Services, you represent that you have the authority to do so and to permit us to use the information in accordance with this Privacy Policy.

Use of Personal Data 

We and our service providers use Personal Data for the following purposes:  

  • To provide the Services to users 

    • We use your information to create your account, match you to a relevant clinic, provide you with reports from the clinic and generally to communicate with you.

    • We use your information to produce notes summarizing your health condition to provide this to the relevant clinic. 

    • To provide you with related support relating to our Websites or Apps.

    • To send administrative information to you or to respond to queries submitted via our Websites or Apps.

 

  • To provide the Services to clinics

    • We use contact details of healthcare providers in order to provide patient information to allow the clinic assist patients with their healthcare issues.

    • If you are a clinic, we may need to process your information in order to accept payments or orders placed for our Services. 

 

We will engage in processing health data only with patients’ consent. We also process information in order to fulfil our contractual obligations with patients and clinics by providing our Services. We will engage in customer service and administrative support because we have a legitimate interest to support our healthcare providers and users of our Services. 

  • To provide you with our newsletters and other marketing materials and facilitate social sharing 

    • To send you marketing-related emails, with information about our services and news about our company which may be based on your choices, preferences or expected interests.

We engage in these activities with your consent or where we have a legitimate interest to promote our business by sending you information about similar Services of ours that may be of interest to you. You may opt out of receiving marketing communications at any time – please refer to the “Choices” section below. 

  • To provide personalized information and services 

    • To better understand your interests and preferences, so that we can personalize our interactions with you and provide you with information and/or offers tailored to your interests. We engage in these activities with your consent because it is necessary for the purposes of our legitimate interests. 

  • Accomplishing our business purposes. 

    • For data analysis, for example, to improve the efficiency of our Services.

    • For audits, to verify that our internal processes function as intended and to address legal, regulatory, or contractual requirements.

    • For fraud and security monitoring purposes, for example, to detect and prevent cyberattacks or attempts to commit identity theft.

    • For developing new services and our brand.

    • For enhancing, improving, repairing, maintaining, or modifying our current services, as well as undertaking quality and safety assurance measures.

    • For identifying usage trends, for example, understanding which parts of our Services are of most interest to users.

    • For operating and expanding our business activities, for example, understanding which parts of our Services are of most interest to our users so we can focus our energies on meeting our users’ interests.

We engage in these activities to manage our contractual relationship with you, or to comply with a legal obligation. In some circumstances, we may rely on our legitimate business interest to expand our business activities by promoting the Services.

THIRD PARTY PROVIDERS 

We disclose Personal Data to our third party service providers, to facilitate services they provide to us. These include providers of services such as website hosting, data analysis, payment processing, information technology and related infrastructure provision, customer service, email delivery, auditing, and providing technical and content-related tasks of providing our Websites. 

Other Uses and Disclosures

We may also use and disclose your Personal Data as necessary or appropriate, in particular when we have a legal obligation or legitimate interest to do so:

  • To comply with applicable law and regulations.

  • This may include laws outside your country of residence. 

  • To cooperate with public and government authorities.

  • To respond to a request or to provide information we believe is necessary or appropriate.

  • These can include authorities outside your country of residence.

  • To cooperate with law enforcement.

  • For example, when we respond to law enforcement requests and orders or provide information we believe is important.

  • For other legal reasons. 

  • To enforce our terms and conditions.

  • To protect our rights, privacy, safety or property, and/or that of our affiliates, you or others. 

  • In connection with a sale or business transaction.

  • We have a legitimate interest in disclosing or transferring your Personal Data to a third party in the event of any reorganization, merger, sale, joint venture, assignment, transfer, or other disposition of all or any portion of our business, assets, or shares (including in connection with any bankruptcy or similar proceedings). 

CHOICES 

You have choices about how we use Personal Data for marketing and advertising. 

  • Receiving marketing-related emails from us.  If you no longer want to receive marketing related emails from us on a going-forward basis, you may opt out by contacting us using the Contact Us details below or, where relevant, by following the unsubscribe link shown in marketing communications you receive from us.

We will try to respond to you as soon as reasonably practicable.  If you opt out of receiving marketing related emails from us, we may still send you Service-related messages, from which you cannot opt out.

THIRD PARTY ADVERTISING 

We use third-party advertising companies to serve advertisements regarding goods and services that may be of interest to you when you access and use the Services and other websites or online services.

You may receive advertisements based on information relating to your access to and use of the Services and other websites or online services on any of your devices, as well as on information received from third parties.  These companies place or recognize a unique cookie on your browser (including through the use of pixel tags).  They also use these technologies, along with information they collect about your online use, to recognize you across the devices you use, such as a mobile phone and a laptop.  If you would like more information about this practice, and to learn how to opt out of it in desktop and mobile browsers on the particular device on which you are accessing this Privacy Policy, please visit http://optout.aboutads.info/#/ and http://optout.networkadvertising.org/#/.   You may download the AppChoices app at www.aboutads.info/appchoices to opt out in mobile apps.

COOKIES AND OTHER INFORMATION 

Our Website uses so-called “cookies”. Cookies are text files that are stored in the Internet browser or by the Internet browser on your device (computer, tablet, or phone). We use the term “cookies” to refer to all tools that collect data on our Website (e.g. IP addresses, place and time of the visit). Your data collected in this way is pseudonymized, and is not stored together with your other personal data. This processing is carried out on a legal basis and, where required by law, based on your consent.

More information about how we use cookies is available on our website: https://www.animahealth.com/cookies-policy 

TRANSFERS

Your Personal Data may be stored and processed in any country where we have facilities or in which we engage service providers, and by using the Services you understand that your Personal Data will be transferred to countries outside of your country of residence (including the UK), which may have data protection rules that are different from those of your country.  In certain circumstances, courts, law enforcement agencies, regulatory agencies or security authorities in those other countries may be entitled to access your Personal Data.

Some countries are recognized by the UK as providing an adequate level of data protection according to UK standards (the full list of these countries is available here in the "what countries or territories are covered by adequacy regulations?" section. For transfers from the UK to countries not considered adequate, we have put in place adequacy measures, such as standard contractual clauses to protect your Personal Data. You may obtain a copy of these measures by contacting us using the details set out in the Contact Us section below.

 

SECURITY

The security of your Personal Data is important to us. We have put in place a number of appropriate organizational, technical and physical security measures designed to protect the Personal Data within our organization. Unfortunately, no data transmission or storage system can be guaranteed to be 100% secure.  If you have reason to believe that your interaction with us is no longer secure, please immediately notify us in accordance with the Contact Us section below.

 

RETENTION

We retain Personal Data only as long as needed or permitted in light of the purposes for which they were obtained and consistent with applicable law, regulatory, tax, accounting or reporting requirements. To determine the appropriate retention period for Personal Data, we consider:

  • The nature of the Personal Data.

  • The length of time during which we have an ongoing relationship with you and provide the Services to you (for example, for as long as you have an account with us or keep using the Services).

  • Whether there is a legal obligation to which we are subject (for example, certain laws require us to keep records of transactions for a certain period of time before we can delete them).

  • Whether retention is advisable in light of our legal position (such as in regard to applicable statutes of limitations, litigation or regulatory investigations).  

 

YOUR RIGHTS

You may be entitled under applicable law to request to exercise the following rights: 

  • Access and correction 

Request access to, and a copy of your Personal Data from us. You can also request that any incorrect or incomplete Personal Data that we hold about you are corrected, though we may need to verify the accuracy of the new data you provide to us for example.

  • Restriction 

Request that we  interrupt the processing of Personal Data under certain conditions.

  • Deletion

Request the deletion of your Personal Data stored by us under certain conditions. Please note that we may need to retain certain Personal Data for recordkeeping purposes and/or to complete any transactions that you began prior to requesting a change or deletion.

  • Portability

Request a portable copy of your Personal Data for the purpose of transferring it to another company. 

  • Object

Object to processing of your Personal Data or withdraw your consent under certain conditions. 

  • Right to complain to supervisory authority

Make a complaint with the competent supervisory authority for your country. The competent supervisory authority in the UK for data protection issues is the Information Commissioner's Office (ICO) (www.ico.org.uk). We would, however, appreciate the opportunity to deal with your concerns before you approach the ICO, so please contact us in the first instance.

 

If you would like to request the exercise of any of the above rights where available to you under applicable law, you may contact us using the details in the Contact Us section below or make use of self-service features the Services may offer. We will respond to your request consistent with applicable law.  For your protection, we may only implement requests with respect to the Personal Data associated with the particular email address that you use to send us your request, and we may need to verify your identity before implementing your request. 

WEBSITES WE LINK TO

 

This Privacy Policy does not address, and we are not responsible for, the privacy, information, or other practices of any third parties, including any third party operating any website or service to which the Services link, such as social media websites. The inclusion of a link on the Services does not imply endorsement of the linked site or service by us or by our affiliates. 

USE OF SERVICES BY MINORS

The Services are not directed to individuals under the age of 18, and we do not knowingly collect Personal Data from individuals under 18. 

CHANGES TO THIS PRIVACY POLICY 

The ‘Last Updated’ legend at the top of this Privacy Policy indicates when this Privacy Policy was last revised.  Any changes will become effective when we post the revised Privacy Policy on the Services.  

CONTACT US 

This Privacy Policy applies to data processing by Continuum Health, as data controller. If you have any concerns, suggestions, or complains, you can contact us at: 

 

 

If you have any questions about this Privacy Policy or our privacy practices, you can reach our Data Protection Representative at rachel@animahealth.com