Last modified: 15/01/2019
Welcome to HealthUnlocked’s privacy notice.
HealthUnlocked is a private company that aims to transform individual health experiences into support, insight and understanding for others. We do this by enabling people to share personal health experiences and information online using our site (“Our Site”). In turn this provides support, aids self-management, and improves interactions with professionals, with the aim of improving day-to-day health and well-being.
At HealthUnlocked we believe in the potential of shared experiences to transform lives and uncover understanding in health. Because this may involve you sharing sensitive information about your health and treatment we also believe in the importance of clear and transparent privacy guidelines. As a user it’s important you know how we use and share your data and how you can control what happens to information you share on Our Site.
This privacy notice will inform you as to how we look after your personal data when you visit our website (regardless of where you visit it from) and tell you about your privacy rights and how the law protects you.
This privacy notice is provided in a layered format so you can click through to the specific areas set out below. Please also use the Glossary to understand the meaning of some of the terms used in this privacy notice.
This privacy notice aims to give you information on how HealthUnlocked collects and processes your personal data through your use of this website, including any data you may provide through this website when you share your experiences and contribute to our online discussions, sign up to our newsletter, purchase a product or service or take part in a competition.
This website is not intended for children and we do not knowingly collect data relating to children. In fact we ask users to verify they are over the age of 16 upon signing up to use the service so all our users have represented to us they are over 16.
If you are under the age of 16 then you are prohibited from creating an account and becoming a member of HealthUnlocked. In registering as a member you are acknowledging that you are aged 16 or above. If we become aware that a child under 16 has provided us with personal information, we take steps to remove such information and will delete the child’s account.
It is important that you read this privacy notice together with any other privacy notice or fair processing notice we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy notice supplements the other notices and is not intended to override them.
HealthUnlocked is owned and operated by Everything Unlocked Limited registered in England and Wales under company number 6596274. Its registered office address is: First Floor, Clover House, 147-149 Farringdon Road, London EC1R 3HN, United Kingdom.
Everything Unlocked Limited is the controller and responsible for your personal data (collectively referred to as “Everything Unlocked”, “HealthUnlocked” “we”, “us” or “our” in this privacy notice).
We have appointed a data privacy manager who is responsible for overseeing questions in relation to this privacy notice. If you have any questions about this privacy notice, including any requests to exercise your legal rights, please contact the data privacy manager using the details set out below.
Our full details are: Everything Unlocked Limited
Full name of legal entity: Everything Unlocked Limited, First Floor, Clover House, 147-149 Farringdon Road, London EC1R 3HN, United Kingdom. HealthUnlocked is a trading name of Everything Unlocked Limited.
Name or title of data privacy manager: Adeela Sharif
Email address: email@example.com
Postal address: First Floor, Clover House, 147-149 Farringdon Road, London EC1R 3HN, United Kingdom
You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues www.ico.org.uk. We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.
This version was last updated on 14 January 2019. You will be notified if there are any changes to this Privacy Notice.
It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.
This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy notice of every website you visit.
Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).
We may collect, use, store and transfer different kinds of personal data about you which we have grouped together follows:
We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy notice.
Health organizations and other affiliates of HealthUnlocked (“Affiliates”) can access and export anonymized and aggregated data reports from users within the HealthUnlocked community who have chosen to share their data. If you have not chosen to share your data with third parties, your data will not be included in the aggregated data reports.
We sometimes collect Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data) should you choose to give us this information to provide the HealthUnlocked user experience. We take extensive measures to keep these Special Categories anonymised and secure but cannot guarantee it will remain anonymised if you chose to register using a username making you personally identifiable.
We do not collect any information about criminal convictions and offences, unless this has been voluntarily shared by you on Our Site.
Where we need to collect personal data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you access to certain parts of Our Site). In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.
We use different methods to collect data from and about you including through:
We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:
Click [here] to find out more about the types of lawful basis that we will rely on to process your personal data.
By becoming an account holder, you agree that we may provide you with information about Our Site (whether by email or any other medium) that we consider appropriate. You may opt-out of receiving these materials and notifications in the contacting us or changing your communication preferences in your settings area of your account or by writing to or emailing us to inform us that you wish to be removed from our contact list.
We will process your personal data only where there is a lawful basis to do so, specifically:
Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.
We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising. We have established the following personal data control mechanisms:
We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you (we call this marketing).
You will receive marketing communications (including invitations to take part in surveys) from us if you have not opted out of receiving that marketing.
We will get your express opt-in consent before we share your personal data with any company outside the HealthUnlocked group of companies for marketing purposes.
You can ask us or third parties to stop sending you marketing messages at any time by logging into the website and checking or unchecking relevant boxes to adjust your marketing preferences or by following the opt-out links on any marketing message sent to you or by contacting us at any time.
Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of service experience or other transactions.
If you want to delete cookies that are already on your computer, please refer to the instructions for your particular system here: https://www.aboutcookies.org/default.aspx?page=1.
If you want to learn about how to control cookies, you can find instructions for your particular system here: https://www.aboutcookies.org/default.aspx?page=2.
HealthUnlocked uses authentication cookies to help us track when you sign in and allows you to be signed in automatically when you come back after an extended period of inactivity. The cookie identifies content which should only be visible to you, and allows us to remember the language you speak allowing for a personalized experience at HealthUnlocked.
HealthUnlocked uses third party analytics services including Google Analytics to collect aggregated data to help us understand how our site is being used, and how we can improve based on these statistics. Because these are also first-party cookies, you can manage them in the same way as HealthUnlocked ones.
When you share information on the site with other social networks, their cookies will record that you have done so. If you would like to disable this, you need to disabled cookies from their sites. Sometimes, YouTube videos are posted on the site. If you view these posts your preferences for YouTube are recorded and stored.
We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.
If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
We may have to share your personal data with the parties set out below for the purposes set out in the table in paragraph 4 above.
There may be circumstances where we are required by law to make a disclosure of your personal data to certain authorities (for example, where information is provided that suggests an ongoing or potential threat against a child or vulnerable person). We may seek to notify you first where such a disclosure of your personal data is going to be made unless we are legally prohibited from doing so.
We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.
Where possible we look to hold all your personal data inside the European Economic Area (EEA).
Some of our external third parties are based outside the EEA so their processing of your personal data may involve a transfer of data outside the EEA.
Whenever we transfer your personal data out of the EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:
Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.
We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
In order to register with us and become an account holder, you will be invited to provide a password, a user name and an email. You are entirely responsible for maintaining the confidentiality of your password and account. You will never be required to reveal your full password to any representative or agent of HealthUnlocked. If you forget your password, we may ask you to answer a specific question such as your username, date of birth or postcode. Furthermore, you are entirely responsible for any and all activities that occur under your account.
You agree to notify firstname.lastname@example.org immediately of any unauthorized use of your account or any other breach of security. We will not be liable for any loss or damage that you may incur as a result of someone else using your password or account, either with or without your knowledge. However, you could be held liable for loss or damage incurred by us or another party due to someone else using your account or password. You may not use anyone else’s account at any time, without the express permission of the account holder. If you think that someone else has access to your password you should change it immediately.
None of your personally identifiable information (i.e. email address, postcode/zipcode, date of birth) is ever visible to other users or third parties without your explicit consent. We encourage you to choose a non-identifiable username as this is visible to other users.
If you choose to use a username that may identify you, then certain information you choose to post may be identified as your data. This may also happen if you upload a photo of yourself, or a likeness of yourself, as a profile picture. Prior to posting any photo or likeness of you, choosing a username that may identify you, and/or post other information that may identify you, you should carefully consider whether you:
When you do, and you also make available Special Categories of data about yourself you will be deemed as having made that data manifestly public.
HealthUnlocked provides industry standard security across all of our platform and complies with health IT standards. We have secure connections (HTTPS) with 2048 bit encryption certificates across all the areas. All passwords assigned during the signup processes are protected using salted cryptographic hashing, and cannot be decrypted by us.
Our third party cloud provider uses secure servers hosted in a protected environments with secure backups performed regularly and compliant with ISO 27001 and HIPAA. We update our security system regularly and perform ongoing research on new practices and technologies that can improve our services. HealthUnlocked has received assurance from an external auditor for its annual HIPAA Security audit.
Our service is hosted on third party servers. We have contracts in place with our third party service providers which require them to implement security measures to protect the data they hold and the current security provisions in place are described above.
We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.
To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements. Generally, once an account has been closed we will process your data only for limited purposes, and would generally look to delete or anonymise data on inactive accounts after 7 years.
Details of retention periods for different aspects of your personal data are available in our retention policy which you can request from us by contacting us.
In some circumstances you can ask us to delete your data: see Request erasure below for further information.
Under certain circumstances, you have rights under data protection laws in relation to your personal data. Please click on the links below to find out more about these rights:
Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
Request correction of your personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
Request restriction of processing your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios:
Request transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
Right to withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.
If you wish to exercise any of the rights set out above, please contact us.
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.
Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.
Comply with a legal or regulatory obligation means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.
Other companies in the HealthUnlocked Group some of whom are based in the United States of America and provide IT and system administration services and undertake leadership reporting.
An affiliate refers to any non-profit health organization, patient group, individual, hospital, or medical professional with which HealthUnlocked is in partnership and who has agreed to this Terms of Engagement for Affiliates.
Health organizations and other affiliates of HealthUnlocked can access and export anonymized and aggregated data reports from users within their HealthUnlocked community who have chosen to share their data.
There is no contractual relationship between the users and HealthUnlocked research partners. However, if the user, where invited and eligible, contributes to a particular project, then there may be terms and conditions specific to that activity by which the user may be bound.