Introduction

We are a healthcare technology company with the aim of facilitating accessible, compassionate health services for all. Nye has designed a platform for NHS practices with that goal in mind. The platform enables patients of an NHS practice to book and consult with you (as their GP or clinician) from the comfort of their home.

We are also committed to ensuring the security of your personal data and protecting your privacy. This policy will inform you as to how we look after your personal data when you use our platform. It will also tell you about your privacy rights and how the law protects you.

Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it.

Who we are

We are Nye Health Ltd. We are a company incorporated and registered in England and Wales. Our company number is 11211158. Our registered office address is at First Floor, 1g Network Point Range Road, Windrush Park, Witney, Oxfordshire, England, OX29 0YN.

When we refer to "Nye" or "we", "us" or "our" in this policy, we are referring to Nye Health Ltd. We are the 'controller' in relation to the personal data you provide to us, which means we determine the purposes and the way in which your personal data is, or will be, processed and are responsible for it.

How to contact us

Questions, comments and requests regarding this policy are welcomed. You may either use our contact form to get in touch with us or you may write to our Data Protection Officer at:

Email: compliance@nye.health

About our service

We are a health and well-being focussed company and our aim is to make the provision of health care more accessible for all. Our service allows patients to book, consult and share medical information with you remotely. Over time, we will add more features to our service.

Purpose of this privacy policy

This privacy policy aims to give you information on how we collect and process your personal data so that you can be confident when you use our platform that you know what your personal data is being used for and that it is being kept safe.

It is important that you read this privacy policy 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 policy supplements the other notices and is not intended to override them.

Third-party links

You should be aware that our platform 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 platform, we encourage you to read the privacy notice of every website you visit or use.

How is your personal data collected?

We use different methods to collect data from and about you including through:

Direct interactions	You may give us your personal data by registering for an account, when you report a problem with our platform and by corresponding with us in person, by email, by phone, by post or otherwise.
Automated technologies or interactions	As you interact with our platform, we may automatically collect personal data. We collect this personal data by using cookies and other similar technologies. Please see below on Cookies for further information.
Third parties or publicly available sources	We may receive personal data about you from various third parties and public sources. This includes the NHS practice or other health care provider which you work for.

What information do we collect about you

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 and process the following different kinds of personal data about you:

Contact data:	includes full name, email address, postal address and/or telephone number
Platform sign-up data:	includes your email address, username, password and any other information you provide to us when you register to use our platform
Practitioner data:	includes educational details, qualifications and credentials, declarations
Correspondence data:	includes information submitted to us via our platform and details of any correspondence between you and us
Problem report data:	includes information about technical errors you tell us about which relate to our platform (e.g. that may be included within screenshots that you share with us)
Safety report and performance data:	includes reports from users of our platform (i.e. clinicians and other administrators) on safety issues related to the platform
Feedback data and performance:	includes any feedback you provide to us about your use of the platform
Marketing data:	includes your preferences in receiving marketing from us and your communication preferences
Technical data:	includes internet protocol (IP) address

If you want any further information about how we might collect or use your personal data, please contact us at compliance@nye.health.

How do we use your personal data?

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:

Where we have your prior consent to use your personal data (e.g. where you have consented to receiving marketing).
Where we need to comply with a legal or regulatory obligation.
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.

We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

Please 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 (compliance@nye.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 practitioner on the platform	Contact data, platform sign-up data, practitioner data and technical data	Necessary for our legitimate interests – to provide our service
To provide our service (i.e. to enable you to consult with your patients remotely)	Contact data, platform sign-up data and technical data	To comply with our legal obligations Necessary for our legitimate interest – to provide our service
To manage our relationship with you. This includes responding to any questions you may ask us; notifying you of changes to the platform; notifying you of any updates to any contractual terms, privacy policies and other relevant information	Contact data and correspondence data	To comply with our legal obligations Necessary for our legitimate interests – to run our business and provide our service
To identify and fix problems if they arise during your use of the platform	Contact data and problem report data	Necessary for our legitimate interests – to run our business
To audit our service	Safety report and performance data	To comply with our legal obligations Necessary for our legitimate interest – to run our business
To audit our service	Safety report data	To comply with our legal obligations Necessary for our legitimate interest – to run our business
To send you promotional or marketing materials and contact you about informative and/or commercial content (e.g. new features and services)	Contact data and marketing data	Necessary for our legitimate interest - in developing and growing our business Consent
To contact you to ask you to provide feedback, complete surveys or for other market research purposes and to use such information to improve our service	Contact data and feedback data	Necessary for our legitimate interest – to analyse and improve our service Consent
To use cookies to operate and customise our platform, including to: identify when you use our platform recognise you when you return to our platform (e.g. we may show you relevant content or provide functionality you used previously) store information about your platform preferences	Technical data	Necessary for our legitimate interests – to operate our platform and to improve user experience Consent
To use cookies to track how you use our platform and use this information to market particular services we think might be of interest to you based on your usage	Technical data and marketing data	Consent

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 lawful 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.

Disclosure of your information

We may have to share your personal information for the purposes set out above with the following third parties:

Third party	Detail
NHS practice:	includes the NHS practice or other health care provider you work for
Service providers:	including those who provide: Webhosting, IT and system administration services Metrics and analytics Marketing services
Professional advisers that enable us to run our business:	including lawyers, bankers, auditors and insurers who provide consultancy, banking, legal, insurance and accounting services.
Authorities:	including regulators and other authorities who require reporting of processing activities in certain circumstances.
Corporate partners:	includes third parties who may invest in our business or to whom we may choose to sell, transfer, or merge parts of our business or our assets. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy notice.

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.

International transfers

Some of our external third parties may, from time to time, be based outside the European Union (EU) so their processing of your personal data will involve a transfer of data outside the EU.

If we transfer your personal data out of the EU, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

The country has been deemed to provide an adequate level of protection for personal data by the European Commission. For further details, see European Commission: Adequacy of the protection of personal data in non-EU countries.
If we use certain service providers based outwith the EU, we may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe. For further details, see European Commission: Model contracts for the transfer of personal data to third countries.
If we use providers based in the US, we may transfer data to them if they are part of the Privacy Shield which requires them to provide similar protection to personal data shared between the Europe and the US. For further details, see European Commission: EU-US Privacy Shield.
In any other case, we will obtain your explicit consent before any transfer takes place.

The table below sets out details of the service providers we use outside of the EU and the relevant safeguards in place.

Service provider	Description of service	Safeguards
Twilio	Mobile Services	https://www.twilio.com/gdpr
Firebase	Notifications and Analytics	https://firebase.google.com/support/privacy/
Sendgrid	Email Services	https://sendgrid.com/resource/general-data-protection-regulation-2/
AWS	Infrastructure	https://aws.amazon.com/blogs/security/u-k-national-health-services-igtoolkit-assessment-report-now-available/
Stripe	Payments	https://stripe.com/guides/general-data-protection-regulation
IT support professionals located outside the EU	Development and Devops	European Commission: Model contracts for the transfer of personal data to third countries

Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.

Data Security

We have put in place appropriate security measures in accordance with industry best practice 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.

All information you provide to us is stored on secure servers. Where we have given you (or where you have chosen) a password which enables you to access our platform, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.

How long we store your personal data for

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.

Below we set out the key retention periods. Further details can be obtained by contacting us.

Data type	How long will you keep my data?
Contact data, platform sign-up data and practitioner data	If your account is inactive for a period of 5 years, we will contact you to ask you whether you would like to keep your account active. If we don’t hear back from you within 1 week your account will be closed and your personal data deleted
Problem report data	2 years after you tell us about the issue
Safety report and performance data	10 years after receipt of report

Where we anonymise your personal data (i.e. so that it can no longer be associated with you) for further research or statistical purposes, then we may use this information indefinitely without further notice to you.

Cookies

Our platform uses cookies to help it function and to improve it. Cookies are small files saved to the user's device that track, save and store information about the user's interactions and usage of the platform. For information about the cookies we use, please see our Cookie Policy.

Your rights

Under certain circumstances, you have rights under data protection laws in relation to your personal data. Please read through the table below to find out more about these rights.

Your right	What this means
Access to your information	You have the right to ask for a copy of the information which we hold on you (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.
Correcting personal data	You have the right to request that we correct personal data that we hold about you. This enables you to have any incomplete or inaccurate information we hold corrected, though we may need to verify the accuracy of the new data that you provide to us. It is important that the personal data we hold about you is accurate and current, so please keep us informed if your personal data changes during your relationship with us.
Deleting personal data	You may ask us to delete or remove personal data where there is no good reason for us continuing to process it. This is more commonly known as the 'right to be forgotten'. 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. Please note, however, that we may not always be able to comply with your request to delete or remove personal data for specific legal reasons which will be notified to you, if applicable, at the time of your request.
Objecting to processing	You have the right to stop us processing your personal data for direct marketing purposes. We will always inform you if we intend to use your personal data for such purposes, or if we intend to disclose your information to any third party for such purposes. You can usually exercise your right to prevent such marketing by checking certain boxes on the forms we use to collect your data. You can also exercise the right at any time by contacting us. You may also object to us processing 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. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
Restriction of processing	This enables you to ask us to suspend the processing of your personal data in the following scenarios: if you want us to establish the data's accuracy; where our use of the data is unlawful but you do not want us to erase it; where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
Transferring your personal data	In certain circumstances, you may request the 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. Please 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.
Withdrawing consent	Where we are relying on consent to process your personal data you can withdraw your consent at any time. Please note that this will not affect the lawfulness of any processing carried out before you withdraw your consent. Where this consent is needed to provide the service, withdrawal may require us to suspend your access to services.
Review by an independent authority	You will always have the right to lodge a complaint with a supervisory body. The relevant authority in the UK is the Information Commissioner's Office. If you do have a complaint, we would appreciate the chance to deal with your concerns before you approach the ICO, so please do contact us in the first instance if possible.

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.

Changes to our privacy policy

This version was last updated on 20th January 2019.

Historic versions of this policy can be obtained by contacting us.