Adynn Ltd, trading under the name Inflow, (“we”) are committed to protecting and respecting your privacy.
1. Purpose of this Policy
2. Which data we hold and how we get it
We may collect and process information provided by filling in forms on the Website or App, including information provided during completion of surveys and other online tools, posting of comments in the Community or requesting further services, and when you report a problem with our System. If you contact us, we may also keep a record of that correspondence. Inflow also collects and processes data with the health tracking technology which provide you as part of the System.
Throughout your use of the System we may collect information such as: personal data (including but not limited to first and last names, gender, date of birth or age, address, email, phone number); lifestyle or health data (referred as “special category data”); other health profile information and details of your visits to the System and the resources that you access (including, but not limited to, traffic data, location data, weblogs, other communication data, and the resources that you access).
Your personal data and health data (referred as “special category data” and includes symptoms, occupation, and medication) may also be collected.
We collect as well technical information and analytics from you concerning your use of the System, including but not limited to pages visited, links clicked, non-sensitive text entered, mouse movements, system and operating system type and version, browser or app version, time zone setting and usage of our iPhone and Android apps.
The information described in this Policy that is collected through either the System is known as “personal data”.
But don’t worry, we are required by law to maintain the privacy of your personal data and lifestyle or health data and to provide you with this notice of our legal duties and privacy practices with respect to them. When we use or disclose your personal data, we are required to abide by the terms of this Policy (or other Policy in effect at the time of the use or disclosure).
3. IP addresses and cookies
We may collect information about your device, including where available your IP address, operating system, browser type and screen size for use in system administration, to tailor your experience of the System, provide you with customer support and to report aggregate information internally.
For the same reason, we may obtain information about your usage of the System by using a cookie file which is stored on the hard drive of your device. Cookies help us to give you a smooth user experience, improve the System and deliver a better and more personalized service. They enable us: To recognize you when you return to our site. To maintain data you have entered e.g. during completion of a survey. To speed up your searches. To estimate our audience size and usage pattern. To store information about your preferences, and so allow us to customize our site according to your individual interests.
Both Inflow and third-party vendors, including Google, may use first-party cookies (such as the Google Analytics cookie) to inform, optimize, and serve ads based on your past visits to the Website on sites across the Internet (also known as ‘remarketing’). If you would like to opt out of this you can do so via your Google Ads Preferences Manager.
4. What we use your data for
Inflow is dedicated to maintaining the privacy and integrity of your personal data. As such, we have policies and procedures and other safeguards to help protect your personal data from improper use and disclosure.
We collect and use your personal data to deliver our contract to you. We may collect and use your health data only if you have given us your specific consent.
We may use and disclose your personal and special category data for our internal operations, which include administration, planning and various activities that assess and improve the quality and cost effectiveness of the service that we deliver to you. Examples are using information about you to improve quality of the service, satisfaction surveys, de-identifying personal data, customer services and internal training. We may use and disclose your personal data to contact you as a reminder to interact with, or complete tasks relating to your use of the System.
We use also automated decision-making to allocate you to a group of users before starting the use of our service.
We follow a Minimum Necessary Access Policy, so any required disclosure of your identifiable information is minimized. The following categories describe different ways that we use your personal data within Inflow and disclose your personal data to persons and entities outside of Inflow. We have not listed every use or disclosure within the categories below, but all permitted uses and disclosures will fall within one of the following categories. In addition, there are some uses and disclosures that may require your specific authorization.
How much personal data is used or disclosed without your written permission will vary depending, for example, on the intended purpose of the use or disclosure.
Disclosure at your request: We may disclose information relating to your use of the System when requested by you. This disclosure at your request may require written authorization by you.
Payment: We do not store your credit/debit card details; they are processed directly by a third-party processor (Stripe or Braintree) that will store all payment information and transaction details. We will only retain details of transactions on secure servers and we will not retain your credit or debit card information.
Operations: We may use and disclose your personal data for our internal operations, which include administration, planning and various activities that assess and improve the quality and cost effectiveness of the service that we deliver to you. Examples are using information about you to improve quality of the service, satisfaction surveys, de-identifying personal data, customer services and internal training.
Reminders and notifications: We may use and disclose your personal data to contact you as a reminder to interact with, or complete tasks relating to your use of the System.
Third party service providers:
We may share anonymised information with third-party service providers who assist us in our marketing and advertising activities or in the improvement of Inflow app or website. These are third party services that allow Inflow to collect information from you concerning your use of the System, including but not limited to pages visited, links clicked, non-sensitive text entered, mouse movements, and usage of our iPhone and Android apps. These services are used to help Inflow enhance or improve the user experience on this website and to perform any other function that Inflow believe in good faith is required to protect and ensure the proper functionality and security of this website.
Third party medical professionals: with additional permission that we will separately explain to you and request your consent for, we may disclose your personal data to a third-party medical professional nominated by you: e.g. your GP or local NHS service. This may be in the form of a discharge letter or an electronic disclosure to an electronic patient record.
Threat to health or safety: We may use and disclose your personal data when necessary to prevent a serious threat to your health and safety or the health and safety of the public or another person. Any disclosure, however, would only be to someone able to help prevent the threat.
As required by law: Certain laws permit or require certain uses and disclosures of personal data for example, for public health activities, health oversight activities and law enforcement. In these instances, Inflow will only use or disclose your personal data to the extent the law requires.
For research and publicity purposes: We may use personal data for internal and external research and publicity purposes. This may include publishing aggregate, anonymous information about our users in the context of providing public information and conducting academic research.
Transfer of business assets: If Inflow or substantially all of its assets are acquired by a third party, personal data held by it about its customers will be one of the transferred assets.
Except as described above, we will never share your personal information with any other party without your consent.
5. Where we store your personal data
All information and data you provide to us is stored on secure servers with trusted 3rd party suppliers, Squarespace and Amazon Web Services (‘AWS’) within the European Economic Area (‘EEA’). AWS complies with EU Data Protection Directive (‘Directive 95/46/EC’), which sets out several data protection requirements, which apply when personal data is being processed. AWS are industry leaders in the provision of hosting services and take security very seriously – you can find out more about their security policies and processes in their Security Whitepaper.
All passwords are stored in encrypted form and all traffic is transmitted securely via SSL by default. However, it may be possible that your anonymised data is transferred to, and stored at, a destination outside the EEA – such as Google Analytics. By submitting your personal data, you agree to this transfer, storing or processing.
Unfortunately, despite these measures, the transmission of information via the internet is never completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to the System, and any transmission is at your own risk. Once we have received your personal data, we will use strict procedures to try to prevent unauthorized access in accordance with our Company data protection policy and code of practice, and responsibilities as a registered Data Controller in the UK.
6. Your rights regarding your personal data
You have certain rights with respect to your personal data. If we do not agree to a request by you with respect to your personal data, please consult the Inflow Privacy and Security Officer whose contact information is below.
We comply with the below:
Restrictions: You have the right to request in writing that we do not disclose certain information about you. To request a restriction, please contact the Privacy and Security Officer whose contact information is below.
Confidential Communications: You have the right to request in writing that we restrict the way in which we communicate information regarding your health and health care services, such as ceasing to send email or SMS messages to notify or remind you about aspects of the System or your progress through the Inflow program. We will make every effort to accommodate your request.
Access: You have the right to inspect and copy your personal data maintained by us. Normally, we will provide you with access within one month of your request. To request your data:
You can email us along with electronic copies of your identification documents to: firstname.lastname@example.org
We will endeavour to respond promptly and in any event within one month.
Deletion: You have the right to ask that we delete all information that the System has collected on you via email to the Inflow privacy and Security whose contact information is below.
Amendment: You have the right to request that we amend your written personal data. For instance, you can request that we correct an incorrect date of birth in your records. We will amend your personal data within one month of your request and will notify you when we have amended your personal data. We can deny your request in certain circumstances, such as when we believe that your personal data is accurate and complete.
Accounting: You have the right to request an accounting from us of certain disclosures made by us. We will provide you with your accounting within one month of your request. In addition, we will notify you as required by law if there has been a breach of the security of your personal data.
Data Portability: You have the right to obtain and reuse your personal data from Inflow for your own purposes across different services. This can be freely downloaded in .csv format within the settings page of your Inflow account.
Objection: You have the right to object to processing based on legitimate interests or the performance of a task in the public interest, to direct marketing, and to processing for the purposes of scientific research & statistics. To request an objection, please contact the Privacy and Security Officer whose contact information is below.
Automated Decision Making & Profiling: You have the right not to be subject to a decision based on automated processing and it produces a legal effect or a similarly significant effect on you. To request an opt-out of automated decision making & profiling, please contact the Privacy and Security Officer whose contact information is below.
7. Data Retention
As per the ICO’s ‘Principle 5’, we retain personal data no longer than is necessary for the purpose we obtained it for. With the context that your personal data may be used for research purposes (as covered in section 3), Inflow will retain any information held on an individual for up to 10 years after that individual has ceased use of the System. At that point, the individual’s information will be deleted. As covered in section 5, you may request that we delete your data at any time.
8. Data Breach
We have implemented appropriate technical and organizational security measures designed to protect the security of any personal information we process. However, please also remember that we cannot guarantee that the internet itself is 100% secure. Although we will do our best to protect your personal information, transmission of personal information to and from our Services is at your own risk. You should only access the services within a secure environment.
9. Concerns or complaints
If you believe that any of your rights with respect to your personal data has been violated by us, our employees or agents, please communicate with the Inflow Privacy and Security Officer at: email@example.com
10. Amending this Policy
We reserve the right to revise this Policy and to make the revised Policy effective for all personal information that we created or received prior to the effective date of the revised Policy. If you are a registered user, we will notify you of changes by the email address we have for you on file.
Questions relating to revisions to this Policy may be addressed to the Privacy and Security Officer whose contact information is above. This Policy will be promptly revised if there is a material change to a policy described herein.
Effective Date: This Policy is effective as of May 27th 2020.