Privacy Policy

Introduction

This is the privacy and cookies policy for the myrecovery.ai website (Site) and any mobile application we provide (App).

The Site/App is operated by or on behalf of Future Health Works Ltd (we, us and our). For the purposes of the General Data Protection Regulation (GDPR), we are the data controller. Please note, certain services are only available via the App, and not the Site.

We are committed to protecting your privacy online. We appreciate that you do not want your personal information distributed indiscriminately and here we explain how we collect information, what we do with it and what controls you have.

By using the Site/App, you consent to the collection and use of information in accordance with this Privacy Policy.

We reserve the right to change this Privacy Policy from time to time by changing it on the Site or by updating the App. This Privacy Policy was last updated on 12 November 2018.

Information we may collect from you

We may collect and process the following information about you:

  • information (such as your name, email address, postal address and telephone number) that you provide by completing forms on the Site/App, including if you register as a user of the Site/App, upload or submit any material via the Site/App, or request any information;

  • information in connection with an account sign-in facility, such as your login and password details;

  • health information about your surgery or treatment, including pre- and post-intervention care information;

  • other optional information relating to you, your surgery, and how your recovery is progressing, including date of birth, activity data, pain scores, and exercise data;

  • communications you send to us, for example to report a problem or to submit queries, concerns or comments regarding the Site/App or its content; information from videos you have watched or surveys that we may, from time to time, run on the Site/App for research purposes, if you choose to respond to, or participate in, them.

  • If you install the App on to an Android or Apple device which has the respective Google Fit or HealthKit features enabled, Future Health Works Ltd will request access to details of your exercise and fitness level available through your device. You will be prompted by your device to allow access the first time this content is requested by us and, even if you grant Future Health Works Ltd access, you can stop this access at any later point by changing the settings on your device. You are under no obligation to provide this information. However, if you should choose to withhold requested information, we may not be able to provide you with certain services, e.g. if insufficient activity data is uploaded to the App we cannot provide you or your surgeon with activity-related outputs and analytics.

  • When you visit the Site or access or use the App, we may, by means of cookies and/or other similar technologies, automatically collect additional information about you – such as the type of internet browser or mobile device you use, any website from which you have come to the Site, your IP address (the unique address which identifies your computer or mobile device on the internet) and/or the operating system of your computer or mobile device. See the Cookies & other technologies section for more information.

Location data

Your mobile device enables us to show you content that is local to you and to help authenticate the use of the services. We may approximate your location from your device using a combination of your IP address or through the GPS, Bluetooth or WiFi connection information used by your device. We do not collect fine-grained location data - we collect data in 30 minute intervals to an estimated 1 kilometer radius.

Where we collect location data, we will prompt you about sharing your location and you can disable location sharing at any time through the settings of your device - although this may affect the services we can provide you e.g. monitoring and reporting on your activity levels or visits to your surgeon or healthcare professional.

Uses made of your information

The purposes for which we use your personal data and the legal grounds on which we do so are as follows:

  • We use your personal information which we collect to enable us to provide you with the services and information offered through the Site/App and which you request, subject to our EULA and Terms of Service with you;

  • With your explicit consent, provide your surgeon or other health professional with information about the progress of your treatment, for example, survey scores or symptom surveys;

  • Where you have provided your explicit consent, we will use your personal information (always having removed personal identifiers, such as your name, address and contact details) to improve our healthcare products and services, and our artificial intelligence system, so that we can deliver better healthcare to you and other users, and further research into musculoskeletal care and disease progression. This does not involve making any decisions about you - it is only about improving our products, services and software so that we can deliver a better experience to you and other users, and help achieve our aim of making healthcare affordable and accessible to everyone. Strict confidentiality and data security provisions apply at all times.

  • Administer your account with us, as set out in our Terms of Service; and

In accordance with our legitimate interest in managing and planning our business, we may use your personal information which we collect to:

  • audit the downloading of the App and data from the Site/App;

  • improve the layout and/or content of the pages of the Site/App and customise them for users;

  • identify visitors to the Site;

  • conduct analysis and carry out research to further and improve orthopaedic care;

  • analyse aggregated and anonymised outcome data to provide recommendations on patients journeys and develop technology to automate guidance;

  • forecast demand of service and to understand other trends in use, including which features users use the most and find the most helpful, and what features users require from us. This does not involve making any decisions about you - it is only about improving our App so that we can deliver better services to you and other users. Strict confidentiality and data security provisions will apply at all times;

  • troubleshoot bugs within the Site and App; and

  • troubleshoot and help you with any questions/ enquiries.

To help the surgeon or other healthcare professionals involved in your care to better track your progress post-operation, we may contact you via email, requesting you to fill out a survey or answer questions about your treatment and recovery progress. These emails will be sent to you even if you uninstall the App. Please note, we will only use your email address to provide you information related to your operation and recovery journey and use of the Site/App. We will not, without your permission, use it to send you general marketing emails.

Information sharing

We may share your information, including information that you insert in to the App, with:

  • your nominated surgeon or healthcare professional responsible for your care for the purposes explained above so they can understand and evaluate your condition and recovery progress. In accordance with the terms of our contractual arrangements with surgeons and healthcare professionals, your surgeon/healthcare professional will be legally required only to share this information to the extent necessary to provide your treatment to you.

  • our commercial partners. Aggregated and anonymised data that does not personally identify you, but which shows general trends, for example the average age or average recovery after certain operations. We will never share your personal information with commercial partners without your explicit consent, which we would obtain separately. You will be informed clearly and in a transparent manner, what type of personal data will be shared;

  • registry providers, for tracking post-surgery progress for specific implants in cases where individual users have separately consented to this; and

  • if required or authorised by law or a legal process, such as to law enforcement bodies to assist in their functions and courts of law.

In the event that we undergo re-organisation or are sold to a third party, you agree that any personal information we hold about you may be transferred to that re-organised entity or third party.

We may disclose your personal information if required to do so by law or if we believe that such action is necessary to prevent fraud or cyber crime or to protect the Site/App or the rights, property or personal safety of any person.

We may disclose aggregate statistics about visitors to the Site and users of the App in order to describe our services to prospective partners, sponsors and other reputable third parties and for other lawful purposes, but these statistics will include no personally identifiable information.

External links

The Site/App may, from time to time, contain links to external sites. We are not responsible for the privacy policies or the content of such sites.

Security

We place great importance on the security of all personal information associated with our users. We have security measures in place to attempt to protect against the loss, misuse and alteration of personal information under our control. For example, our security and privacy policies are periodically reviewed and enhanced as necessary and only authorised personnel have access to personal information. Whilst we cannot ensure or guarantee that loss, misuse or alteration of information will never occur, we use all reasonable efforts to prevent it.

You should bear in mind that submission of information over the internet is never entirely secure. We cannot guarantee the security of information you submit via the Site/App whilst it is in transit over the internet and any such submission is at your own risk.

Data Storage, Security and Transfers

We store all your personal health data on secure servers.

Where you have chosen a password that enables you to access certain parts of our App, you are responsible for keeping this password confidential. We ask you not to share the password with anyone.

Your personal information which we collect is transferred to and stored on secure third party servers located in the United Kingdom. Such storage is necessary in order to process the information.

We encrypt data transmitted to and from the App. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access. We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this Privacy Policy.

By using our Site/App, you consent to the transfer of your personal information to the United Kingdom for storage purposes. If you are using the Site or App outside of the United Kingdom, please be advised that United Kingdom law may not offer the same privacy protections as the law in your jurisdiction.

Retention

We retain personal data for as long as necessary to provide our products and fulfill the transactions you have requested, or for other essential purposes such as complying with our legal obligations, and enforcing our agreements. Because these needs can vary for different data types in the context of different products, actual retention periods can vary significantly.

The general rule we apply for data retention is that we will store your personal data for eight years from the last time you use the App. We will always inform you if the applicable data retention period deviates from the general rule.

We may also retain aggregate information beyond this time for research purposes and to help us develop and improve our services. You cannot be identified from aggregate information retained or used for these purposes.

Your rights

The information we provide in this section is a brief summary of your rights under the GDPR and you should still read the relevant laws and guidance from the regulatory authorities for a full explanation of these rights.

  • Wherever we process data based on your consent, you can withdraw that consent at any time by emailing support@myrecovery.ai;

  • Understand and request a copy of information we hold about you. Recordings of your appointments with us and other medical notes can be accessed via the App. For other information, you can make a request by email;

  • Ask us to rectify or erase information we hold about you, subject to limitations relating to our obligation to store medical records for prescribed periods of time;

  • Ask us to restrict our processing of your personal data or object to our processing;

  • To the extent that the legal basis for our processing of your personal information is consent, you have the right to withdraw that consent at any time. Withdrawal will not affect the lawfulness of processing before the withdrawal;

  • If you have given additional consent for your data to be shared to a third party, including academic institutions, medical device companies and pharmaceutical companies, you have the right to withdraw this consent at anytime;

  • Ask for your data to be provided on a portable basis; and

  • Prevent the use of your personal information for direct marketing purposes.

You may also contact the Information Commissioner’s Office (the data protection regulator in the UK): Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF, telephone: 0303 123 1113 (local rate).

Cookies & other technologies

When you interact with the Site/App, we try to make that experience simple and meaningful. When you visit the Site or access or use the App, a web server sends a cookie or other similar technology to your computer or mobile device (as the case may be). Cookies are small pieces of information which are issued to your computer or mobile device (as the case may be) when you visit a website or access or use a mobile App and which store and sometimes track information. A number of cookies we use last only for the duration of your web or App session and expire when you close your browser or exit the App. Other cookies are used to remember you when you return to the Site/App and will last for longer.

The cookies and/or other similar technologies we use collect information, such as the type of internet browser or mobile device you use, any website from which you have come to the Site/App, your IP address and/or the operating system of your computer or mobile device.

We use cookies to remember that you have visited us before. This means we can identify the number of unique visitors we receive. This allows us to:

  • make sure we have enough capacity for the number of users that we get;

  • customise elements of the promotional layout and/or content of the pages of the Site/App; and

  • collect anonymous statistical information about how you use the Site/App (including how long you spend on the Site/App) and where you have come to the Site/App from, so that we can improve the Site and learn which parts of the Site and which functions of the App are most popular with users.

Some of the cookies used by the Site/App are set by us, and some are set by third parties who are delivering services on our behalf, for example Mixpanel and Fabric.

Most web and mobile device browsers automatically accept cookies but, if you prefer, you can change your browser to prevent that or to notify you each time a cookie is set. You can also learn more about cookies by visiting the All About Cookies website which includes additional useful information on cookies and how to block cookies using different types of browser or mobile device.

Please note, however, that by blocking or deleting cookies used on the Site/App, you may not be able to take full advantage of the Site/App.

Changes to this Privacy Policy and Further Information

We may revise this Privacy Policy from time to time. The most current version of the policy will govern our use of your information and will always be at myrecovery.ai/privacy. If we make a change to this policy that, in our sole discretion, is material, we will notify you via an App notification or email to the email address associated with your account. By continuing to access or use our services after those changes become effective, you agree to be bound by the revised Privacy Policy.

Please submit any questions, concerns or comments you have about this Privacy Policy or any requests concerning your personal data by email to support@myrecovery.ai or write to us at:

Unit 3, Spectrum House, 32-34 Gordon House Road, London NW5 1LP