Privacy Notice

For the purposes of processing your personal data inside the App, Liva Healthcare UK Limited (“Liva”) is a Data Controller. Liva wishes to protect your privacy as much as possible, and therefore only use your data for specific purposes.

Liva relies on either of the following legal basis to process your personal data:

• Article 6(1)(c) – the processing of some of your personal data is based on your consent; and
• Article 6(1)(c) – the processing of some of your personal data is necessary for the performance of the contract between you Liva related to the subscription you have purchased.

When you have downloaded the Liva App, you will submit data inside the Liva App during registration and while using it. In this regard, we may process the following personal data:

• Your full name. We need this information to be able to identify you and determine that you are eligible to receive the Liva App and coaching services. We receive this information from Clinova and when you register on the Liva app. The legal basis for processing this data is for the fulfillment of a contract.
• Your birthdate. We need this information to determine that you are over the age of 18 and eligible to receive the Liva app and coaching services. This information is also used to inform the lifestyle advice and guidance given to you. The legal basis for processing this data is for the fulfillment of a contract.
• Your email address. We need this information in combination with your unique password to identify you when you log into the Liva app and to complete registration, and to send you any communications necessary for your continued use of the service. The legal basis for processing this data is for the fulfillment of a contract.
• Your telephone number. We need this information to contact you to render technical and general support services to you. The legal basis for processing this data is for the fulfillment of a contract.
• Demographic information which includes your gender, and gender identity. We need this information to inform the lifestyle advice and guidance given to you, providing this information is voluntary. The legal basis for processing this data is based on your consent.
• Health and lifestyle information which can include information about diseases, your height, weight, tobacco and alcohol consumption, exercise habits, meal pictures and other relevant health and lifestyle data. We need this information to render lifestyle coaching services to you. The legal basis for processing this data is for the fulfillment of a contract.
• Information about medication use. The app allows you to register any medications you are taking in order to send you notifications on when to take your medication. The use of this feature is voluntary. The legal basis for processing this data is based on your consent.
• Communications with your health coach and other members inside the app. We need this information for your health coach to provide health coaching services to you. The legal basis for processing this data is for the fulfillment of a contract.
• Any other general or sensitive data not listed herein which you voluntarily provide in the Liva App, for example, in messages to your health coach or Groups. The legal basis for processing this data is based on your consent.

In addition to demographic information referred to above, you may be presented with surveys inside the App where we will ask for information pertaining to your programme for us to assess the efficacy of the same. Your survey answers will be anonymous which means researchers and evaluators will not be able to identify you from the answers that you provide.

We also retrieve information from Apple HealthKit or Google Fit about your daily number of steps. When downloading the app, you are asked whether you want your steps to be imported directly into the app. In the app, you can go to 'Health' and 'Sources' to enable/disable this permission at any time.

As part of delivering the services to you, Boots Online Doctor and Liva need to share your subscription information with each other. Boots Online Doctor needs to share this information with Liva to confirm that you have been successfully subscribed to access the App. Liva needs to share this information with Boots Online Doctor to confirm that you are receiving services from Liva. The legal basis for sharing this data between Liva and Boots Online Doctor is for the fulfillment of a contract.

Liva may engage independent contractors as health coaches. All our health coaches are healthcare professionals (dieticians and/or nutritionists) who are contractually and professionally subject to duty of confidentiality. Liva gives health coaches access to your personal and sensitive information that you provide inside the App so they can give you the support and guidance you need. Liva’s sharing of your personal data with our health coaches is required to render lifestyle coaching services to you and the legal basis is for the fulfillment of a contract.

Liva has concluded data processing agreements with all health coaches who are independent contractors, with Liva as Data Controller and health coaches as Data Processors of your data. All our health coaches are based in the UK or EU. This means that your health coach will only process your data within the UK or EU.

The health and lifestyle data that you and other users record in the app represents an important resource for research into health, medicine and lifestyle changes. Only aggregated and pseudonymised data from the app is made available for research purposes. Researchers therefore cannot identify you from the data we provide.

Your information is stored in a closed database and only made available to those persons and entities as described in these terms. Liva will only retain your personal data for as long as necessary to deliver the services to you, and for no longer than 12 months after your last activity in the App, or until such time as you may request the deletion of your personal data.

Liva has engaged the following data processors who are involved in the processing of your personal data in the App:

• Liva Healthcare A/S (“Liva DK”) who provides data hosting and data processing services to Liva. Liva DK manages and maintains the app as well as all data collected inside the App. Liva DK is located in the EU and processes your data within the EU.
• Amazon Web Services EMEA SARL (“AWS Europe”) which provides data hosting services for the app and all data you provide in the app as described above. AWS Europe is located in the EU and stores all your data in a secure environment in the EU. A data processing agreement is in place for the processing of your data by AWS Europe. AWS Europe’s privacy policy can be found here.
• Google Ireland Limited (“Google”) which provides calendar booking services for the Liva app. Google only processes your full name when you make an appointment with your health coach inside the App. Google is located in the EU and stores your data in a secure environment in the EU. There is a data processing agreement in place for the processing of your data by Google. Google’s Privacy Policy can be found here.
• Smartsurvey UK Limited (“Smartsurvey”) which provides survey services inside the App. Before your data is sent to Smartsurvey, it is pseudonymised, meaning that the data is anonymous for Smartsurvey. Smartsurvey cannot draw any conclusions about individual persons. We have concluded an addendum on data processing with Smartsurvey to ensure a data protection level that corresponds to the EU, according to which they undertake to comply with European data protection. You can get more information about the use of your data on the privacy page of Smartsurvey here.
• Mailerlite Limited (“Mailerlite”) which provides email communication services to Liva. Liva shares with Mailerlite your name and email address for them to address correspondence to you from Liva. Mailerlite is situated in the EU and only processes your data inside the EU. Liva and MailerLite have a data processing agreement in place for the processing of your data by MailerLite. Mailerlite’s privacy policy can be found here.
• Inscale Asia Sdn. Bhd. (“Inscale”) which provides software development services to Liva. Inscale is located in Malaysia, and may process all data you input into the App to assist with the development and maintenance of the App. We ensure that any data transferred to Inscale is handled in accordance with EU data protection regulations. Specifically, we ensure that Inscale operates under a data processing agreement that includes EU Standard Contractual Clauses (SCCs) to ensure an adequate level of protection for personal data. Inscale is also contractually obligated to process personal data only in accordance with our instructions and to implement appropriate technical and organizational measures to safeguard the data. Inscale’s privacy policy can be found here.

In terms of the United Kingdom and European Unions’ General Data Protection Regulations, you have the following rights:

• Right to access your personal data. You have the right to be informed at any time what data we process about you, where we receive it from, and what we use it for and for how long we store it.
• Right to have incorrect data corrected or deleted. If you believe that the personal data we process about you is inaccurate, you have the right to have it corrected. You must contact us and inform us of the inaccuracies and how they can be corrected. When you contact us with a request to have your personal data corrected or deleted, we will investigate whether legal conditions are met, and if so, implement changes or deletion as soon as possible and inform you of the outcome.
• Right to object to the processing of your personal data. You have the right to object to our processing of your personal data. If your objection is justified, and there is no other legal basis in terms of which we are required to continue processing your data, we will cease to process your data.
• Right to transfer your data to another service provider. You have the right to receive the personal data you have made available to us and those that we have collected about you from third parties with your consent. If we process data about you as part of a contract to which you are a party, you can also have your data sent to you. You also have the right to transfer your personal data to another service provider. If you wish to exercise your right to data portability, you will receive your personal data from us in a commonly used format.
• Right to restrict the processing of your personal data. You have the right to request that we restrict the processing of your personal data under certain conditions. Should you request that we restrict the processing of all or some of your personal data, this may result in us being unable to continue rendering services to you since those services may require the processing of personal data that is subject to your request for restriction.
• Right not to be subject to a decision based on automatic processing. You have the right to object to the processing of your personal data in such a manner that it results in automated decisions being taken about you, including profiling, and which produces legal effects concerning you or which similarly affects you.

You can exercise your data subject rights by sending us an email to help@livahealth.com

You can also submit any complaints regarding the processing of your data to the United Kingdom’s Information Commissioner’s Office here.

Contact:

Liva Healthcare UK Limited
Registration No. 10717560
65 Woodbridge Road
Guildford, Surrey
United Kingdom
GU1 4RD
Email: help@livahealth.com