HexTransforma

Hex Remote Monitoring App: PRIVACY NOTICE

Last updated October 16, 2020

Thank you for choosing to be part of our community at HexTransforma Healthcare Ltd. ("Company", "we", " us", "our"). We are committed to protecting your personal information and your right to privacy.

When you use our mobile application, as the case may be (the "App") and more generally, use any of our services (the "Services", which include the App), we appreciate that you are trusting us with your personal information. We take your privacy very seriously. In this privacy notice, we seek to explain to you in the clearest way possible what information we collect, how we use it, and what rights you have in relation to it. We hope you take some time to read through it carefully, as it is important. If there are any terms in this privacy notice that you do not agree with, please discontinue use of our Services immediately.

This privacy notice applies to all information collected through our Services (which, as described above, includes our App), as well as, any related services, sales, marketing or events.

Please read this privacy notice carefully as it will help you understand what we do with the information that we collect.

1. WHAT PERSONAL DATA DO WE COLLECT?

Your personal data is received from and sent to the National Health Service (NHS). Your health record data is input manually by medical clinicians, stored and then a risk dashboard is presented to medical professionals. The following personal data is collected:

NHS Number; First Name; Last Name; Postcode; Date of Birth; Telephone Number; Email; Address; Height; Weight; Gender at Birth; Ethnicity; Underlying Health Conditions; Pulse; Oxygen saturation (Sp02); Temperature; Covid Symptom Checklist

Your health personal data will be automatically processed in order to help medical clinicians make decisions on your access to medical treatment.

Your personal data will be obtained from you and from your electronic health records.

Your blood oxygen saturation level (SP02) will be tracked.

Your health data will be evaluated or scored using a risk rating.

2. WILL YOUR INFORMATION BE SHARED WITH ANYONE?

Your personal data will be disclosed to clinicians for the purpose of monitoring your Covid-related medical treatment.

We may process or share your data that we hold based on the following legal basis:

• Consent: We may process your data if you have given us specific consent to use your personal information for a specific purpose.
• Explicit Consent: For special category personal data, such as data relating to health or ethnicity, we may process your data if you have given us explicit consent to use your personal data for a specific purpose.
• Legitimate Interests: We may process your data when it is reasonably necessary to achieve our legitimate business interests.
• Performance of a Contract: Where we have entered into a contract with you, we may process your personal information to fulfill the terms of our contract.
• Legal Obligations: We may disclose your information where we are legally required to do so in order to comply with applicable law, governmental requests, a judicial proceeding, court order, or legal process, such as in response to a court order or a subpoena (including in response to public authorities to meet national security or law enforcement requirements).
• Vital Interests: We may disclose your information where we believe it is necessary to investigate, prevent, or take action regarding potential violations of our policies, suspected fraud, situations involving potential threats to the safety of any person and illegal activities, or as evidence in litigation in which we are involved.

More specifically, we may need to process your data or share your personal information in the following situations:

• Business Transfers. We may share or transfer your information in connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business to another company.

3. IS YOUR INFORMATION TRANSFERRED INTERNATIONALLY?

HexTransforma Healthcare operates on a global scale and as a result, your personal data may be stored and processed by us or our partners in multiple countries. This is to enable us to deliver our services to you.

Your personal data will not be transferred to countries outside the EEA (European Economic Area).

4. HOW LONG DO WE KEEP YOUR INFORMATION? We only retain your data for as long as required by law. For further information on how long personal data is likely to be kept before being removed from our systems and databases, please contact us using the details provided.

When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymize such information, or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.

5. DO WE COLLECT INFORMATION FROM MINORS?

We do not knowingly solicit data from or market to children under 18 years of age. By using the App, you represent that you are at least 18 or that you are the parent or guardian of such a minor and consent to such minor dependent’s use of the App. If we learn that personal information from users less than 18 years of age has been collected, we will deactivate the account and take reasonable measures to promptly delete such data from our records. If you become aware of any data we may have collected from children under age 18, please contact us at privacy@southwood.tech.

6. WHAT ARE YOUR PRIVACY RIGHTS?

If you are a resident in the European Economic Area and you believe we are unlawfully processing your personal information, you also have the right to complain to your local data protection supervisory authority. You can find their contact details here:
http://ec.europa.eu/justice/data-protection/bodies/authorities/index_en.htm

If you are a resident in Switzerland, the contact details for the data protection authorities are available here: https://www.edoeb.admin.ch/edoeb/en/home.html

7. CONTROLS FOR DO-NOT-TRACK FEATURES

Most web browsers and some mobile operating systems and mobile applications include a Do-Not-Track ("DNT") feature or setting you can activate to signal your privacy preference not to have data about your online browsing activities monitored and collected. At this stage no uniform technology standard for recognizing and implementing DNT signals has been finalized. As such, we do not currently respond to DNT browser signals or any other mechanism that automatically communicates your choice not to be tracked online. If a standard for online tracking is adopted that we must follow in the future, we will inform you about that practice in a revised version of this privacy notice.

8. DO WE MAKE UPDATES TO THIS NOTICE?

We may update this privacy notice from time to time. The updated version will be indicated by an updated "Revised" date and the updated version will be effective as soon as it is accessible. If we make material changes to this privacy notice, we may notify you either by prominently posting a notice of such changes or by directly sending you a notification. We encourage you to review this privacy notice frequently to be informed of how we are protecting your information.

9. HOW CAN YOU CONTACT US ABOUT THIS NOTICE?

Who is responsible for the processing of your personal data?
HexTransforma Healthcare of Platf9rm, Floor 5 & 6, Tower Point, 44 North Rd, Brighton BN1 1YR is the Data Controller and responsible for the processing of your data.

Who can you contact in case you have questions or requests?
HexTransforma Healthcare has appointed a Data Protection Officer (DPO) who is available to handle any questions or queries you may have relating to the processing of your data, this Policy and associated Privacy Notices.

The DPO can be contacted at privacy@southwood.tech

10. HOW CAN YOU REVIEW, UPDATE, OR DELETE THE DATA WE COLLECT FROM YOU?

Based on the applicable laws of your country, you may have the right to request access to the personal information we collect from you, change that information, or delete it in some circumstances. To request to review, update, or delete your personal information, please submit a request form by clicking here . We will respond to your request within 30 days.