We take data protection seriously
We process personal data, and have therefore adopted this privacy protection policy, which tells you how we process your data.
To ensure the best possible protection of your personal data, we regularly assess the risk that our data processing might affect your ability to have control over your data.
Processing of your personal data
You must be old enough to consent and agree to the processing of your personal data
If you are a minor, you are not allowed to use the Liva Platform without the consent of your parent(s) or guardian(s). Liva takes all reasonable and practical measures to ensure that it does not process the personal data of minors without parental or guardian consent. However, to the extent that this does occur, and Liva verifies that it has processed or is processing personal data of a minor without parental or guardian consent, Liva will as soon as possible cease the processing of this personal data and return and/or delete the same
We ensure fair and transparent data processing
Liva Healthcare ensures that the data processing takes place in accordance with the law. When we ask you to make your personal data available to us, we inform you of what data we process about you and for what purpose. You will receive information about this at the time of collection of your personal data.
If we collect data about you from another party, such as a supplier, government authority or business partner, we notify you within 10 days of obtaining your personal data. We also inform you of the reason for collecting the data, and the legal basis that allows us to obtain your personal data.
We use this type of data about you
We use data about you to make our service better and ensure quality in our products and services as well as in our contact with you. The data we collect can include:
- Contact information which includes your name, e-mail address and telephone number
- National Identification number
- Sensitive data regarding your health and medical condition
- Data on interests and habits relevant to your lifestyle
In some cases, we need to compare your data with data we receive from third parties. If the compilation can reveal your identity and information of a private or sensitive nature, we will obtain your consent to the processing. Before we compile data, we assess whether there is a risk that the treatment will have a negative effect on your privacy. If so, we will inform you of the treatment and its purpose and ask for your consent to continue treatment.
We collect and store your personal data for specific purposes
We collect and store your data for specific purposes and other legitimate business purposes. This happens when we need to:
- Fulfill your request to use the Liva Platform
- Provide health coaching services to you in the Liva Platform
- Improve our products and services
- Administer your relationship with us
- Conduct research
We may need to use your personal data for a purpose other than that for which they were collected for, eg. for research purposes. In other cases, we investigate whether the original purpose of collecting your data is compatible with the new purpose.
When your information in Liva is passed on for research, it does so at an overall aggregated (collected) and pseudonymised (purified for personal data) level. The researchers can therefore not identify you via the data we make available.
We only process relevant personal data
We only process data about you that is relevant and sufficient for the purposes defined above. The purposes are crucial to the type of data about you that is relevant to us. The same applies to the scope of the personal data we use.
Before we process your personal data, we investigate whether it is possible for us to minimize the amount of data we process about you. We are also investigating whether some of the data types we collect can be used in anonymized or pseudonymized form. We can do so if it does not adversely affect our obligations or the service we offer you.
We only process necessary personal data
We collect, process and store only the personal data necessary to fulfil our stated purpose. In addition, it may be determined by law what type of data is required to be collected and stored for our business operations. The type and extent of personal data we process may also be necessary to fulfil a contract or other legal obligation. We want to make sure that we only process personal data that is necessary for each of our specific purposes. Therefore, it is embedded in our IT systems that only the data types that are needed are collected.
Correct and up-to-date information
We check that the personal data we process about you is not incorrect or misleading. As our service depends on your data being accurate and up to date, we ask you to inform us of relevant changes to your data. You can use the contact information below to let us know of your changes. To ensure the quality of your data, we have adopted internal rules and established procedures for checking and updating your personal data.
We delete your personal data when it is no longer required
We only store your data for as long as is necessary to achieve the purposes mentioned in this Privacy Policy or for as long as is determined by applicable legislation. We delete your personal data when they are no longer needed for the purpose that formed the basis of our collection, processing and storage of your data, or when a legal record keeping duty has expired.
We obtain your consent before processing your personal data
We obtain your consent before processing your personal data for the purposes described above unless we have another legal basis for obtaining it. We will inform you of such a basis and of our legitimate interest in processing your personal data. Your consent is voluntary and you can withdraw it at any time by contacting us. If we need to use your personal data for a purpose other than originally stated, we will inform you of the new purpose and ask for your consent before we begin data processing. If we have another legal basis for the new treatment, we will inform you of this.
We do not share your personal data without your consent
If we share your personal data with partners and third parties, e.g. for research or reporting purposes, we will inform you about what the data will be used for and with whom it will be shared. No personal data will be share unless you have given your consent. You can object to this type of disclosure at any time. If you use the Liva Platform through a Danish municipality, we will not in all cases obtain consent in connection with your data being used for research, it will depend on which legal basis in legislation applies. We do not obtain your consent if we are legally obliged to disclose your personal data, eg as part of reporting to an authority. We do not pass on your personal data to third countries without informing you and obtaining your consent.
Third-party sub-processors and data providers
Liva works with certain third parties to provide specific functionality related to or within the Liva Platform, as well as to provide employee recruitment services.
The following is a list of sub-processors processing personal data on Liva’s behalf, or from whom Liva may receive data from about you:
- Amazon Web Services Europe (“AWS Europe”) which provides data hosting for the Liva Platform and all User data processed inside the Liva Platform. AWS Europe is located in the EU and processes data in the EU. The User data that is hosted with AWS Europe consists of general personal info (such as name, email and telephone number) and sensitive personal data concerning a User’s health, medical condition(s) and relevant lifestyle data. AWS Europe’s privacy policy can be found here.
- Calendly which provides appointment booking services. Calendly is located in the US and processes data in the US. Calendly collects the name, email address and telephone number of Users who have consented to the use of Calendly to book their first appointment with their health coach. Calendly’s privacy policy can be found here.
- Google which shares with Liva relevant health data that is collected in a User’s Google Fit mobile application. Google is based in the US and processes their user’s data in the US. Google will only share a User’s Google Fit data with Liva where the User has given their consent for the sharing of specific data with Liva. The data that Liva can receive from Google Fit can include your weight and daily step counts, and any other data that you indicate can be shared with Liva. Google’s privacy policy can be found here.
- Apple which shares with Liva relevant health data that is collected in a User’s Apple Health mobile application. Apple is based in the US and processes their user’s data in the US. Apple will only share a User’s Apple Health data with Liva where the User has given their consent for the sharing of specific data with Liva. The data that Liva can receive from Apple Health can include your weight and daily step counts, and any other data that you indicate can be shared with Liva. Apple’s privacy policy can be found here.
- Teamtailor which provides employee recruitment services to Liva. Teamtailor is located in the EU and processes data in the EU and the US. Teamtailor collects an employment candidate’s device information, full name, contact information, demographics and information concerning employment suitability and ability. Teamtailor’s privacy policy can be found here.
- Webflow which provides website hosting services for Liva in respect of the livahealthcare.com website. Webflow is situated in the US and may process your data in the US and EU. Webflow may process personal data such as your full name, e-mail address, telephone number and any other information you voluntarily provide when engaging with our websites. Webflow may collect and process certain data that is required as part of their hosting services. Webflow’s privacy policy can be found here.
- IPinfo which provides geolocation services for Liva in respect of the livahealthcare.com website. IPinfo uses your IP address to determine your generalised location so that you are directed to the correct Liva website relevant to you. IPinfo only receives your IP address. IPinfo’s privacy policy can be found here.
Security
We protect your personal data and have internal information security rules
We have adopted internal rules on information security, which contain instructions and measures that protect your personal data against being destroyed, lost or altered, against unauthorized publication, and against unauthorized access or knowledge of unauthorized persons. We have established procedures for granting access rights to those of our employees who process sensitive personal data and data that reveals information about personal interests and habits. We control their actual access through logging and monitoring. To avoid data loss, we regularly back up our data sets. We also protect the confidentiality and authenticity of your data by encrypting data during storage and transport. We will notify you of any security breaches that result in a high risk to you as soon as possible.
Use of cookies
Cookies, purpose and relevance
We use two different types of cookies on Liva's website: necessary cookies and analytical third-party cookies.
Necessary cookies are used to provide the functionality on our website that is necessary for the user, and Liva does not need the user's consent to use these cookies.
Third-party cookies are used by external applications or software to perform specific functions, and these can only be used if the user gives his consent. In connection with this, Liva uses the following:
- Google Analytics, a web traffic analytics service provided by Google Inc. (“Google”). Google Analytics' cookies help Liva analyse how users use Liva's website. Google Analytics uses cookies to track individual users and also anonymously collects standard internet log information and information about visitor behaviour (such as IP address and geographical location, pages visited, time spent on the pages). This information about your use of the website is sent to Google and is used to evaluate the use of the website and compile statistical reports on the activity of the website for the use of backup technology. We may also use Google Analytics to deliver ads about products and services tailored to your needs (including non-affiliated companies). These advertisements may appear on other websites. This process helps us manage and track the effectiveness of our marketing. The following Google Analytics advertising features may be used:
- Remarketing with Google Analytics
- Exposure reporting on the Google Display Network
- Google Analytics reporting on demographics and interests
- Integrated services that require Google Analytics to collect data for advertising purposes, including the collection of data through advertising cookies and identifiers
You can find information on how to completely opt out of Google Analytics here. - MailerLite is an email marketing service used to manage our email marketing subscriber list and to send emails to our subscribers. MailerLite will install a cookie that will only track and determine if visitors have seen the pop-up sign-up window or not, and when the pop-up window should reappear based on behavioural settings. MailerLite will not install additional cookies. MailerLite's Privacy Policy is available here. You can unsubscribe from the newsletter by clicking on the unsubscribe link at the end of each newsletter.
- YouTube is an application that allows you to play videos on Liva's website. When you click on a YouTube video on Liva's website, YouTube will install a cookie that collects data about a user's visit to the website, such as which videos have been viewed. YouTube collects data that may include a visitor's IP address, technical information about the user's device, the website visited, and searches of the YouTube website. YouTube's Privacy Policy is available here.
Your rights
You have the right to access your personal data
You have the right to be informed at any time what data we process about you, where they come from and what we use them for. You can also be informed how long we store your personal data and who receives data about you, to the extent that we pass on data in Denmark and abroad. If you request it, you can gain insight into the data we process about you. However, access may be limited for the protection of other persons' privacy, trade secrets and intellectual property rights.
You are entitled to have inaccurate personal data corrected or deleted
If you believe that the personal data we process about you is inaccurate, you have the right to have it corrected. You must contact us and inform us of the inaccuracies and how they can be corrected. In some cases, we will have an obligation to delete your personal data. This applies, for example, if you withdraw your consent. If you believe that your data is no longer necessary for the purpose for which we collected it, you may request that it be deleted. You can also contact us if you believe that your personal data is being processed in violation of the law or other legal obligations. When you contact us with a request to have your personal data corrected or deleted, we will investigate whether the conditions are met, and if so, implement changes or deletion as soon as possible.
You have the right to object to our processing of your personal data.
You have the right to object to our processing of your personal data. If your objection is justified, we will make sure to stop the processing of your personal data.
You have the right to have your personal data transferred to another service provider
You have the right to receive the personal data you have made available to us and those that we have collected about you from third parties based on your consent. If we process data about you as part of a contract to which you are a party, you can also have your data sent to you. You also have the right to transfer your personal data to another service provider. If you wish to exercise your right to data portability, you will receive your personal data from us in a commonly used format.
You have the right to restrict the processing of your personal data
You have the right to request that we restrict the processing of your personal data under certain conditions. Should you request that we restrict the processing of all or some of your personal data, this may result in us being unable to continue rendering services to you since those services may require the processing of personal data that is subject to your request for restriction.
You have the right not to be subject to a decision based on automatic processing
You have the right to object to the processing of your personal data in a such manner that it results in automated decisions being taken about you, including profiling, and which produces legal effects concerning you or which similarly affects you.
Complaints
If you experience incorrect or unlawful data processing with Liva Healthcare, you may contact us using the contact details above. In Denmark you always have the right to submit a complaint til Datatilsynet. You can send your complaint by letter or via their webpage. Read about the complaints options here.
In the U.K. you always have the right to submit a complaint to the UK Information Commissioners Office (ICO) if you are not satisfied with our data processing or with the result of your complaint to us. You may contact ICO though their webpage.
Exercising your rights
We will strive to accommodate any request from you to exercise your data subject rights. We will give you an answer to your inquiry as soon as possible.
Should you have any questions regarding the data we process and the way we do so, or to exercise your rights as a data subject, you can contact us at the contact information appearing below.
Contact information
Liva Healthcare A/S – Denmark
Address: Danneskiold-Samsøes Allé 41, 1434 Copenhagen K, Denmark
CVR no.: 38 73 73 68
Telephone: +45 7020 8822
Email: kundesupport@livahealth.com
Website: livahealthcare.com
Liva Healthcare UK Ltd. – United Kingdom
Address: 125 Kingsway, London, WC2B 6NHH
Company Reg: 10717560
Telephone no .: +44 203 858 0767
Email: help@livahealth.com
Website: livahealthcare.com
Changes to this privacy policy and/or the categories of data we process
We may amend this privacy policy from time to time and you are invited to review it frequently, and we suggest at least every time that you submit personal information to us.
To the extent that there are any changes to the types of personal data that we process about you or the way we process your personal data which requires your consent, we will obtain your consent prior to processing your personal data.
Version
September 2024