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Privacy Policy:

Adora Digital Health Limited

(“We”, “Us” and “Our”)
 

1.Introduction

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We are Adora Digital Health Limited (UK Company Registration Number: 13103602).

We understand that menopause can be a complex time and the experience is different for everyone. Here at Adora Digital Health Ltd (Adora), we aim to provide support personal to you.
 

You may interact with us through the following means:
 

  • www.adora.health (our “Website”); or

  • through the Adora Menopause App (our “App”); or

  • through the Adora webinars ("Webinars"); or

  • literature, reports or downloads ("Literature"); or

  • forms and questionnaires ("Questionnaires")
     

Together, the Website, App, Webinars and Literature constitute the “Media”.

This privacy notice provides you with details of how we collect and process your (the user (“you” and/or “your”)) personal data through your use of the “Media”, including any information you may provide through the Media when using, or receiving updates from, the same.
 

This Media is not intended for use by children and we do not knowingly collect data relating to children.
 

We are the data controller and we are responsible for your personal data.
 

It is important that you read this privacy policy together with any other privacy policy or fair processing policy 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 policy supplements other notices and privacy policies and is not intended to override them.
 

​Contact Details
 

Our full details are:
 

  • Full name of legal entity: Adora Digital Health Limited (company number: 13103602).

  • Email address: privacy@adora.health.

  • Registered office address: is Salisbury House, Station Road, Cambridge, England, CB1 2LA.
     

We have appointed a Data Protection Officer (DPO)  who is responsible for overseeing questions in relation to this privacy policy. If you have any questions about this privacy policy, including any requests to exercise your legal rights, please contact the DPO using the details set out above.
 

If you are not happy with any aspect of how we collect and use your data, you have the right to complain to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). 
 

We should be grateful if you would contact us first if you do have a complaint so that we can try to resolve it for you.
 

It is very important that the information we hold about you is accurate and up to date. Please let us know if at any time your personal information changes by emailing us at privacy@adora.health giving to us the details of such changes.
 

2. What data do we collect about you?
 

Personal data means any information capable of identifying an individual. It does not include anonymised data.
 

We may process certain types of personal data about you as follows:

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Types of Personal Data
Details
Identity Data
may include your name, email address, date of birth and gender.
Contact Data
may include your address, email address and telephone number.
Technical Data
may include your login details, internet protocol addresses, browser type, device model, browser plug-in types and versions, time zone,setting and location, operating system and platform and other technology on the devices you use to access this Media. It may also include how often you open the App, logout, and log in, and whether you have accepted biometrics and notifications. What pages you have viewed and what activities you have completed when on the media.
Profile Data
may include your name, email address, organisation code, your interests and preferences.
Usage Data
may include information about how you use the Media and any of our product(s) (if any) service(s).
Marketing & Communicaions Data
may include your preferences in receiving marketing communications from us and our third parties and your communication preferences.

We also collect, use and share Aggregated Data and Anonymised Data such as statistical or demographic data for our businesses purpose.  Aggregated Data and Anonymised Data could be derived from your personal data but is not considered personal data in law as this data will 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.  We may also send Usage Data to your employer to understand the collective effectiveness of the Media within a given company or organisation.  We may also share anonymised health data with third party organisations such as academic researchers, pharmaceutical companies or healthcare providers.  This is intended to improve the understanding of menopause and women's health or to research better solutions to the symptoms of menopause.

 

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 policy.

In addition to the above, we may process sensitive data related to your health. Please see the below for more details.                                                                                                                                               
 

Special Category Data
 

Personal data that we process also includes  'special category' or ‘sensitive data’ (see summary below). Special category      data refers to data that 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. 
 

In order to provide our service(s), we collect certain ‘sensitive data’ about you concerning your health (specifically in the context of menopause) to provide our service(s) to you. We do not collect any information about criminal convictions and offences.
 

​Please see the information below containing summary of how we process your data, including sensitive data relating to your health, and related matters.

 

Overview of the rules related to the processing of your data
 

We are required to collect and process your data in accordance with UK data protection laws. Such laws are enshrined primarily in the UK General Data Protection Regulations) (“UK GDPR”). As part of the UK GDPR, we are required to confirm to you, amongst other things, the lawful bases under which we process your data (for, amongst other things, the purposes of article 6 of the UK GDPR). 
 

In addition to the above, the UK GDPR contains additional protections for you relating to the processing of sensitive data (in particular in article 9 of the UK GDPR), and the processing of such is generally prohibited unless an exception applies. Such exceptions are normally referred to as ‘conditions’ for processing such sensitive data. We have set out below the condition upon which we rely for processing data related to your health (which, as noted above, is considered under UK GDPR to be sensitive data).
 

Please note that, where we are required to collect personal data by law, or under the terms of our agreement(s) with you (related to the use of the Media and otherwise) and you do not consent to and/or otherwise provide us with that data when requested, we may not be able to perform the agreement(s) and/or provide other service(s) to you (including in particular the compiling, production and delivery to you of a health report).
 

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​3. How we collect your personal data
 

We collect data about you through a variety of different methods including:  
 

  • Direct interactions: You may provide data by filling in forms on the Media (or otherwise) or by communicating with us by post, phone, email or otherwise, including when you:

  • create an account on any of our Media;

  • subscribe to our service(s) or other publications;

  • use our chatbot, or provide information to us, through the Media to enable us to    compile a health report for you;

  • request resources or marketing be sent to you; or

  • give us feedback;

  • Direct interactions (via third parties): You may provide us data concerning your health through our chatbot (which is powered by Cognigy GmbH) or Questionnaires (powered by Google, Typeform SL or Hubspot Inc) through the Media in order for us to provide to you our services and, in particular, compile a health report for you;

  • Automated technologies or interactions: As you use the Media, we may automatically collect Technical Data and/or Usage Data about your equipment, browsing actions and usage patterns. We collect this data by using cookies, server logs and similar technologies. We may also receive Technical Data and/or Usage Data about you if you visit other websites that use our cookies. Please see our cookie policy at https:www.adora.health/cookie-policy for further details;

  • Third parties or publicly available sources: We may receive personal data about you from various third parties and public sources as set out below:

  • Google Analytics (based outside of the EU)

  • Amazon Web Services; and

  • Cognigy GmbH.

  • Typeform SL

  • Google

  • Hubspot Inc

  • Zoom

  • Eventbrite

  • SurveyMonkey

  • WIX
     

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4. How we use your personal data
 

  • We will only use your personal data when legally permitted. The most common uses of your personal data are:

  • where we need to perform the contract between us and/or provide to you our service(s);

  • where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests; and

  • where we need to comply with a legal or regulatory obligation.

  • where appropriate or otherwise required (specifically in the context of any health-related sensitive data that we collect from you) we do rely on consent as (one of) the legal grounds for processing your personal data. You have the right to withdraw consent at any time by emailing us at privacy@adora.health but please note that, by withdrawing consent, we may not be able to provide any service(s) to you and/or comply with the terms of any agreement(s) with you.
     

Purposes for processing your personal data
 

Set out below is a description of the ways we intend to use your personal data and the legal grounds on which we will process such data (i.e. our bases for lawfully processing your data under UK GDPR (in particular article 6 UK GDPR). We have also explained what our legitimate interests are, where relevant.
 

​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 email us at privacy@adora.health 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.

Purpose/Activity
Type of Data
Lawful basis for processing
To register you as a new user
Indentity and contact
Performance of our agreement(s)/service(s) with you.
Logging in as a new user
Identity and contact and data related to to your health
Performance of our agreement(s)/services(s) with you, consent, necessary for our legitimate interest to deliver our service(s), keep our records updated and to study how customers use our products/services.
Utilising and interacting with our chatbit via the Media
Identity and contact and data related to to your health
Performance of our agreement(s)/services(s) with you, consent, necessary for our legitimate interest to deliver our service(s), keep our records updated and to study how customers use our products/services.. This will result in user behaviour analytics and reports.
Production of information, reports or notes for you and updating you on new and available features in our services (for example webinars).
Identity and contact and data related to to your health
Performance of our agreement(s)/services(s) with you, consent, necessary for our legitimate interest to deliver our service(s), keep our records updated and to study how customers use our products/services.
To manage our relationship with you which will include: notifying you about changes to our terms or other documents (including this privacy policy) and asking you to leave a review or take a survey.
Identity and contact profile and marketing and communications.
Performance of our agreements(s)/services(s) with you; necessary to comply with a legal obligation; necessary for our legitimate interests to keep our records updated and to study how customers use our products/services.
To administer and protect our business and our Media (including troubleshooting, data analysis, testing, system mainenance, support, reportimng and hosting of data).
Necessary for our legitimate interests for running our business, provision of administration and IT services, network security, to prevent fraud and in th econtext of a business reorganisation or group restructuring exercise, and necessary to comply with a legal obligation.
To deliver relevent content, referals and advertisments to you and measure and understand the effectiveness of the same.
Itentity, contact, profile, usage, marketing communications, technical
Necessary for our legitimate interests to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy.
To use data analytics to improve our Media product(s)/if any/service(s). Marketing, customer relationships and experiences.
Technical and usage
Necessary for our legitimate interest to define types of customers for our product(s) (if any) and service(s) to keep our Media updated and relevent, to develop our business and inform our marketing strategy.
To make suggestions and recommendations to you about good(s) or service(s) that may be of interest to you.
Identity, contact, technical, usage and profile
Necessary for our legitimate intertest to develop our products/services and grow our business.

Processing of special category data related to your health

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As noted in clause 2 above, (and notwithstanding the table above) we collect and process certain data related to your health. This is primarily collected and processed when logging into the Media, interacting with our chatbot and when producing a health report for you.
 

Specifically, we will collect the following items of health data from you via the Media:
 

Medical and personal history details:
 

  • Procedures (e.g. hysterectomy)

  • Previous conditions (e.g. breast cancer, uterine cancer)

  • Prescribed medicines (e.g. HRT, Birth control)

  • Physiological symptoms (e.g. aching joints, night sweats)

  • Psychological symptoms (e.g. mood, panic attacks, brain fog)

  • Age
     

Lifestyle choices:
 

  • Health choices (e.g. exercise, smoking, drinking)

  • Treatment choices (e.g. conventional or alternative medicine)

  • Smoking, drinking exercise choices.

 

Work environment:
 

  • Employment status

  • Employment type and conditions

  • Employment environment

 

Ethnicity and Background:
 

  • Ethnicity

  • Socioeconomic background

  • Income

     

     

Data from Connected Devices:
 

  • Wearables health data (with your explicit consent) such as fitbit, Apple watch, Oura ring.

 

 

For the purposes of, amongst other things, article 9 of UK GDPR we ask for your explicit consent to processing this special category data at the time you register as a user of the Media.  By giving this explicit consent you agree to us collecting and processing such special category data concerning your health for the purposes set out in the table above.

     

We will contact you at appropriate intervals to check that you are happy for us to continue to process your special category data.

 

You have the right to withdraw this consent at any time by emailing us at privacy@adora.health but please note that, by withdrawing consent, we may not be able to provide any service(s) to you and/or comply with the terms of any agreement(s) with you.

 

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Marketing communications

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You will receive marketing communications from us if you have:
 

  • requested information or services from us; or

  • if you provided us with your details and ticked the box or otherwise consented at the point of entry of your details for us to send you marketing communications, and in each case, you have not opted out of receiving that marketing.

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We will get your express opt-in consent before we share your personal data with any third party for marketing purposes.
 

You can ask us or third parties to stop sending you marketing messages at any time by emailing us at privacy@adora.health at any time.
 

Where you opt out of receiving our marketing communications, this will not apply to personal data provided to us as a result of a product/service purchase, warranty registration, product/service experience or other transactions.

 

Change of purpose

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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 find out more about how the processing for the new purpose is compatible with the original purpose, please email us at privacy@adora.health.
 

If we need to use your personal data for a purpose unrelated to the purpose for which we collected the data, we will notify you and we will explain the legal ground of processing. In the event that we need to use your sensitive personal data for any other purpose(s) beyond that to which you have explicitly consented, we will contact you to obtain consent to such new purpose(s).
 

We may process your personal data without your knowledge or consent where this is required or permitted by law.
 

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5. Discolsures of your personal data
 

We may have to share your personal data with the parties set out below for the purposes set out in the table in section4 above:
 

  • Providers of our medical helpline service (Dr Morton's), where applicable to your use of the Media and to the extent required for them to contact you to provide or administer that service.  In these circumstances Dr Morton's acts as a separate controller of your personal data.  Please see Dr Morton's privacy policy here https://www.drmortons.co.uk/services/a_foot_privacy_policy.php#:~:text=Electronic%20records%20of%20Telephone%20calls,do%20not%20give%20this%20consent

  • Service providers who provide IT and system administration services.

  • Professional advisers including lawyers, bankers, auditors and insurers who provide consultancy, banking, legal, insurance and accounting services.

  • HM Revenue & Customs, regulators and other authorities based in the United Kingdom and other relevant jurisdictions who require reporting of processing activities in certain circumstances.

  • Email Service Providers such as Microsoft and Google.

  • Third parties to whom we sell, transfer, or merge parts of our business or our assets.
     

In addition to the above:
 

  • Please be aware that we use Amazon Web Services to store your personal data. Please see Amazon Web Services’ data privacy policies (found here) for how Amazon Web Services processes and stores your data on our behalf.

  • Please be aware that we use Cognigy GmbH’s software to provide our chatbot service to you. As part of such service, Cognigy GmbH will process your personal data on our behalf. Please see Cognigy GmbH’s data privacy policy (found here) for how Cognigy GmbH’s processes your data on our behalf.​

 

We require all third parties to whom we transfer your data to respect the security of your personal data and to treat it in accordance with the law. We only allow such third parties to process your personal data for specified purposes and in accordance with our instructions.

 

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6. International Transfers

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Countries outside of the European Economic Area (EEA) do not always offer the same levels of protection to your personal data, so European law has prohibited transfers of personal data outside of the EEA unless the transfer meets certain criteria.
 

Some of our third parties service providers are based outside the European Economic Area (EEA) so their processing of your personal data will involve a transfer of data outside the EEA.

Whenever we transfer your personal data out of the EEA, we do our best to ensure a similar degree of security of data by ensuring at least one of the following safeguards is implemented:
 

  • We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission; or

  • Where we use certain service providers, we may use specific contracts or codes of conduct or certification mechanisms approved by the European Commission which give personal data the same protection it has in Europe; or

  • Where we use providers based in the United States, we may transfer data to them if they are part of the EU-US Privacy Shield which requires them to provide similar protection to personal data shared between the Europe and the US.
     

If none of the above safeguards is available, we may request your explicit consent to the specific transfer. You will have the right to withdraw this consent at any time.
 

Please email us at privacy@adora.health if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.
 

 

7. Data Security
 

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 such data. 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.

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8. Data Retention
 

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.

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By law we have to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for six years after they cease being customers for tax purposes.

In some circumstances you can ask us to delete your data: see below for further information.

In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.

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9. Your legal rights

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Under certain circumstances, you have rights under data protection laws in relation to your personal data. These include the right to:
 

  • request access to your personal data;

  • request correction of your personal data;

  • request erasure of your personal data;

  • object to processing of your personal data;

  • request restriction of processing your personal data;

  • request transfer of your personal data; and

  • right to withdraw consent.
     

You can see more about these rights at:
 

https://ico.org.uk/for-organisations/guide-to-the-general-data-protection-regulation-gdpr/individual-rights/ 
 

If you wish to exercise any of the rights set out above, please email us at privacy@adora.health.

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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.

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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.

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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.

 

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10. Third Party Links

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Our Media 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 Media, we encourage you to read the privacy notice of every website you visit.

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11. Cookies

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You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of our Media may become inaccessible or not function properly. For more information about the cookies we use, please see https://www.adora.health/cookie-policy.

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