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Privacy policy

Introduction

    1. Vala is committed to protecting and respecting the privacy of its users and members. The purpose of this policy is to explain how we collect information from you, what we do with it and what controls you have over that process. Please read this policy carefully and contact us if you have any questions about it.

    2. Any terms used in this policy shall have the same meaning as those used in our Terms and Conditions.

    3. Further information on how Vala Health complies with the General Data Protection Regulation.

    4. If you do not agree with the terms of this privacy policy, you should not use our Website or the Vala App.

  2. Website

    1. www.valahealth.com (the “Website”) is operated by iPrimary Care Limited, a company registered in England and Wales under number 08826625 (“Vala”, “we”, “us”, “our”). For the purposes of the Data Protection Act 1998, we are the data controller.

    2. By using the Website, you consent to the collection and use of information in accordance with this privacy policy.

    3. We reserve the right to change this privacy policy from time to time. Any changes we make to our privacy policy in the future will be notified to you the next time you log-in via our Website. The updated privacy policy will apply to any transaction or use and it is your responsibility to ensure that you understand and agree to the then-current privacy policy before you make any further use of the Service.

    4. This privacy policy was last updated on 31 October 2019.

  3. Information which we may collect

    1. We may collect and process the following information about you:

      1. information (such as your name, email address, postal address and telephone number) that you provide when you complete forms on the Website, register as a Member, make any Appointment, upload or submit any material via the Website or request any information;

      2. data or information provided in or as a result of Sessions, which may include sensitive information about you including your health, medical records, test results, physical and mental performance, characteristics, any ailments, diseases or disabilities, your race, gender, age and other sensitive information;

      3. your name, address, e-mail address and phone number, financial and credit card information;

      4. your password and log-in details for your account with Vala;

      5. details of any Appointments or other transactions made by you through the Website;

      6. communications you send to us, for example to report a problem or to submit queries, concerns or comments regarding the Website or its content;

      7. information from surveys that we may, from time to time, run on the Website for research purposes, if you choose to respond to them; and

      8. details of your visits to the Website, the resources you access and any data you download.

    2. You are under no obligation to provide any such information. However, if you should choose to withhold requested information, we may not be able to provide you with certain services.

    3. If you use our services, you consent to us and our Affiliates' and licensees' transmission, collection, maintenance, processing and use of your location data and queries to provide and improve location-based products and services. You may withdraw this consent at any time by turning off the location services settings on your device.

  4. How we use your information

    1. We will use the information you provide:

      1. to enable us to provide you with the services and information offered through the Website and which you request;

      2. to provide such information to our Affiliates, partners, and suppliers where reasonable or necessary in connection with your use of the Services including provision of your information to Vala Team Members, dispensing chemists, partner diagnostic/testing providers, and suppliers or subcontractors used in relation to our Website;

      3. to review and enhance the quality of our services and products, including monitoring compliance with clinical care standards;

      4. to make disclosures as required by or in compliance with reasonable requests by regulatory bodies including the General Medical Council or the Care Quality Commission, or as otherwise required by law or regulation;

      5. subject to your prior consent or request, to provide to your insurance provider who may contribute to the cost of the services provided to you;

      6. to administer your account with us;

      7. to where you request it, provide to your other healthcare providers such as your GP

      8. to process your payments for Sessions and other services;

      9. to audit the downloading of data from the Website;

      10. to improve the layout and/or content of the pages of the Website and customise them for our Members;

      11. to identify visitors to the Website;

      12. to carry out research on our Members’ demographics;

      13. to send you information we think you may find useful or which you have requested from us, including information about our products and services or those of carefully selected third parties, provided you have indicated that you do not object to being contacted for these purposes; and

      14. to allow, with your consent, carefully selected third parties to send you information directly which you may find useful regarding their products and services.

    2. You may instruct us not to contact you with marketing information regarding our products and services or those of third parties or to share your details with third parties so that they can send you information regarding their products and services, either at the point such information is collected on the Website (by checking or un-checking (as directed) the relevant box) or by following the unsubscribe instructions on any communications sent to you. You can also exercise the right at any time by contacting us at iPrimaryCare Limited, Blue Star House, 234-244 Stockwell Road, London SW9 9SP or by email to support@valahealth.com.

  5. Additional information

    When you visit the Website, we may automatically collect technical information, including, but not limited to, the address used to connect your mobile phone or other device to the Internet, your login information, system and operating system type and version, time zone setting, operating system and platform, your location and information about your visit, including the pages you viewed, website response times and interaction information. You cannot be identified from this information and it is only used to assist us in providing an effective service on the Website and to collect broad demographic information for aggregate use.

  6. Cookies

    1. The Website also uses cookies or similar technology to collect information about your access to the Website.

    2. Cookies are pieces of information that include a unique reference code that a website transfers to your device to store and sometimes track information about you. A number of cookies we use last only for the duration of your web session and expire when you close your browser. Other cookies are used to remember you when you return to the Website and will last for longer.

    3. We use cookies to:

      1. remember that you have used the Website before (this means we can identify the number of unique visitors we receive and allows us to make sure that we have enough capacity for the number of visitors we expect);

      2. allow you to navigate the Website more quickly and easily;

      3. recognise when a visitor to the Website is a registered Member;

      4. remember your login session so you can move from one page to another within the Website;

      5. store your preferences;

      6. customise elements of the layout and/or content of the pages of the Website for you; and

      7. collect statistical information about how you use the Website so that we can improve the Website.

    4. All cookies used on our Website are set by us.

    5. Most computer and some mobile web 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 www.allaboutcookies.org which includes additional useful information on cookies and how to block cookies using different types of browser. Please note however, that by blocking or deleting cookies you may not be able to take full advantage of the Website.

  7. Information sharing

    1. We may share basic identification data (such as your name, postal address, email address and phone number) with the dispensing pharmacies used by us, taking all reasonable steps to protect your personal information, for the purposes of the pharmacy verifying your identification on collection of your prescription.

    2. We may disclose aggregate statistics about visitrs to the Website in order to describe our services to prospective partners, investors, advertisers and other reputable third parties and for other lawful purposes, but these statistics will include no personally identifiable information.

    3. If we carry out anyreorganisation 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.

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

  8. Patient data

    1. All information collected and supplied to Vala will be treated as confidential.

    2. We do not store your personal health data on your mobile device. We store all your personal health data – including your primary care information, secondary care information, medication information and diagnostic information – on secure servers located in the EU. Where you have chosen a password that enables you to access certain parts of our Website, you are responsible for keeping this password confidential. We ask you not to share the password with anyone.

    3. Vala maintains records of the notes made by Vala Team Members during Consultations as well as audio and video recordings of the Consultation for clinical governance purposes, in accordance with data processing requirements. These records and any personally identifiable information you give to us will be treated as strictly confidential and will not be disclosed without your express permission except under special circumstances, for example, in comply order to comply with a legal obligation.

    4. We may encourage you to inform your GP of any health concerns you may have but we will not share information with your GP without your express permission unless there is an overriding public interest in disclosing the information without your consent. This is in accordance with the General Medical Council’s guidance, which may change from time to time.

    5. Vala monitors the use of its Website for statistical purposes only and to improve the quality of the Service.

    6. We encrypt data transmitted to and from the Website. However, secure transmission of information via the internet cannot be guaranteed due to security threats outside our control and you acknowledge that transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access. You are responsible for ensuring that any computer or telephone you use to access your online patient record is suitably protected from potential interception.

    7. In order to provide you with the best quality care, information will be shared among Vala Team Members as well as members of Vala's administrative or other staff who support the provision of care. If you object to particular information being shared among Vala Team Members or the wider healthcare team you must let us know. We are obliged to make disclosures if failure to do so would expose others to a risk of death or serious harm. In addition, we may be unable to continue to provide you with treatment or arrange for referral where you object to the disclosure of information.

  9. External links

    The Website may contain links to other independent third-party websites ("Other Site"). Other Sites are not under our control, and we are not responsible for and do not endorse their content or their privacy policies (if any). You will need to make your own independent judgement regarding your interaction with any Other Sites, including the purchase and use of any products or services accessible through them.

  10. Payment processing

    We do not store any credit or debit card information. Payments are processed via a third party payment provider that is fully compliant with Level 1 Payment Card Industry (PCI) data security standards. All payment transactions are encrypted using SSL technology.

  11. Security

    1. We place great importance on the security of all personally identifiable information associated with our Members. We have security measures in place to attempt to protect against the loss, misuse and alteration of personal information under our control. For example, 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.

    2. 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 Website whilst it is in transit over the internet and any such submission is at your own risk.

    3. It is advisable to close your browser when you have finished your user session to help ensure others do not access your personal information if you use a shared computer or a computer in a public place.

  12. Storage of your information

    Information that you submit via the Website is sent to and stored on secure servers located in the EU. This is necessary in order to enable us to process the information.

  13. Your rights

    You have a legal right under the Data Protection Act 1998 to a copy of all the personal information about you held by us. On request, we will provide you with a copy of this information subject to a fee not exceeding £10. You also have a right to correct any errors in that information. As mentioned above, you have a right to prevent the use of your personal information for direct marketing purposes.

  14. Appropriate use of automation

     

    At Vala, we believe that RPA, NLP, Ai and other forms of automation should only be used to augment the role of the clinician, rather than replace them. We are committed to only introducing data-driven features that make the team more efficient in the delivery of care to our members. Therefore we will never use automated services to deliver primary care.

    We may, in some use-cases, apply automation powered by RPA, NLP or Ai to give our team recommendations of answers to basic questions and medical issues. We will also use NLP to assist in administrative tasks related to appointments with our team.

    Member data will never be used without explicit permission, to train models for algorithm powered tools.

    Any automation we introduce into any part of the Vala platform will receive substantial independent validation to prove member safety and efficacy.

     

  15. Contacting us

    Please submit any questions, concerns or comments you have about this privacy policy or any requests concerning your personal data by email to support@valahealth.com, or in writing to us at iPrimaryCare, Blue Star House, 234-244 Stockwell Road, London SW9 9SP.

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