Background
Tiny Medical Apps Limited understands that your privacy is important to you and that you care about how your personal data is used. We respect and value the privacy of all of our users and will only collect and use personal data in ways that are described here, and in a way that is consistent with our obligations and your rights under the law. We are also committed to collecting and retaining only the minimum amount of personal data needed to provide the elements of our service in which users are actively engaged, in line with the GDPR principle of ‘data minimisation’.
- Information About Us
- What does this notice cover?
- What Is Personal Data?
- What Are My Rights?
- What Personal & Sensitive Data Do You Collect and How?
- How Do You Use My Personal Data?
- How Long Will You Keep My Personal Data?
- How and Where Do You Store or Transfer My Personal Data?
- Do You Share My Personal Data?
- How Can I Access My Personal Data?
- How May Parents Access, Change or Delete Information About Their Children?
- How Do I Contact You?
- NHS Login
- Changes to this Privacy Notice
1. Information About Us
Company Name: Tiny Medical Apps Limited.
Registered in England Company number: 10051596
Address: Canterbury House, 1 Royal St, Lambeth, London SE1 7LL
VAT registration: GB296395447
ICO Registration: ZA282635
Data Protection Officer: Matt Bourne
Clinical Safety Officer: Beverley Scott
Email address: [email protected]
Telephone number: 0207 859 4169
2. What Does This Notice Cover?
This Privacy Information explains how we use your personal data: how it is collected, how it is held, and how it is processed. It also explains your rights under the law relating to your personal data.
3. What Is Personal Data?
Personal data is defined by the General Data Protection Regulation (EU Regulation 2016/679) (the “GDPR”) and the Data Protection Act 2018 (collectively, “the Data Protection Legislation”) as ‘any information relating to an identifiable person who can be directly or indirectly identified in particular by reference to an identifier’.
Personal data is, in simpler terms, any information about you that enables you to be identified. Personal data covers obvious information such as your name and contact details, but it also covers less obvious information such as identification numbers, electronic location data, and other online identifiers.
The personal data that we use is set out in Part 5, below.
4. What Are My Rights?
Under the Data Protection Legislation, you have the following rights, which we will always work to uphold:
- The right to be informed about our collection and use of your personal data. This Privacy Notice should tell you everything you need to know, but you can always contact us to find out more or to ask any questions using the details in Part 11.
- The right to access the personal data we hold about you. Part 10 will tell you how to do this.
- The right to have your personal data rectified if any of your personal data held by us is inaccurate or incomplete. Please contact us using the details in Part 11 to find out more.
- The right to be forgotten, i.e. the right to ask us to delete or otherwise dispose of any of your personal data that we hold. Please contact us using the details in Part 12 to find out more.
- The right to restrict (i.e. prevent) the processing of your personal data.
- The right to object to us using your personal data for a particular purpose or purposes.
- The right to withdraw consent. This means that, if we are relying on your consent as the legal basis for using your personal data, you are free to withdraw that consent at any time.
- The right to data portability. This means that, if you have provided personal data to us directly, we are using it with your consent or for the performance of a contract, and that data is processed using automated means, you can ask us for a copy of that personal data to re-use with another service or business in many cases.
- Rights relating to automated decision-making and profiling. We do not use your personal data in this way.
For more information about our use of your personal data or exercising your rights as outlined above, please contact us using the details provided in Part 12.
It is important that your personal data is kept accurate and up-to-date. If any of the personal data we hold about you changes, please keep us informed as long as we have that data.
Further information about your rights can also be obtained from the Information Commissioner’s Office or your local Citizens Advice Bureau.
If you have any cause for complaint about our use of your personal data, you have the right to lodge a complaint with the Information Commissioner’s Office. We would welcome the opportunity to resolve your concerns ourselves, however, so please contact us first, using the details in Part 12.
5. What Personal & Sensitive Data Do You Collect and How?
Depending upon your use of our App, we may collect and hold some or all of the personal and non-personal data set out in the table below, using the methods also set out in the table.
| Data Collected | How we Collect the Data | Required? |
| Special Category Data | ||
| Health: including physical health conditions (asthma, allergy), clinical management as it relates to specific health conditions (asthma/allergy care plan, asthma/allergy triggers, Adrenaline Pen), scores and measures relevant to specific illnesses used to monitor progress (symptoms, peak flows, adverse health outcomes). Name and contact details for people to contact in an emergency.
Ethnicity |
Self-entered on onboarding, within account & profile settings, symptoms and measures within health tracker and uploading of care plan within care plan section. | Only health conditions (e.g. Asthma, Allergies are required in order to provide the service).
Ethnicity is not required but useful to ensure we are reaching the whole target population. |
| Personal Data | ||
| Data from Social Login including Name, email address & avatar | Registration and Login: Social Media | Yes (if account creation) |
| Data from NHS Login accounts including Name, NHS Number, email address & mobile telephone number | Registration and Login: NHS Login | Yes (if account creation) |
| Profile information: preferences | Settings: Entered during onboarding and within settings | No |
| Device ID | A unique ID for each device is provided by the platform (IOS/Android) | Yes |
| Location data
Location based features: Weather, Pollution & Pollen alerts, medication reminders |
Requires in-app permissions. Native feature of both platforms. | No |
| Emergency contacts name & telephone number | Self-entered within the Emergency plan section of the app. | No |
| Non-Personal Data | ||
| Profile information: Behaviours
Analytic activity within: app: Use of app features, including time and frequency |
Using cookie-less analytics from Google Analytics (GA4) | No |
| Audit Information
Monitoring access when data within the app is viewed or edited |
Events on the device pushed to database via REST API | Yes |
| Crash reporting data including operating system, device type, app version, state of device and error information. | Data captured if the app experiences crashes or exceptions. Using Sentry. No PID shared. | No |
6. How Do You Use My Personal Data?
Under the Data Protection Legislation, we must always have a lawful basis for using personal data. The following table describes how we may use your personal data, and our lawful bases for doing so:
| What we Do | What Data we Use | our Lawful Basis |
| Supplying our products and services to you. | Data from Social Media accounts, provided Email and Password, Data from NHS Login accounts and Analytic information including Device ID and IP Address | Consent: Verifying your identity and keeping all data held within the app secure |
| Profile information & behaviours, Audit Information and Crash reporting data | Consent: help maintain and improvement of the app. | |
| Personalising and tailoring our products and services for you. | Profile information, behaviours & preferences and Location Data | Consent: Personalising the app and enabling functionality of app features |
| Communicating with you. | Data from Social Media accounts , Data from NHS Login accounts | Consent: Product improvement and feedback, public health information |
With your permission and/or where permitted by law, we may also use your personal data for marketing purposes, which may include contacting you by email or text message with information, news, and offers on our products. You will not be sent any unlawful marketing or spam. We will always work to fully protect your rights and comply with our obligations under the Data Protection Legislation and the Privacy and Electronic Communications (EC Directive) Regulations 2003, and you will always have the opportunity to opt-out.
We will not share your personal data with third parties for marketing purposes.
We will only use your personal data for the purpose(s) for which it was originally collected unless we reasonably believe that another purpose is compatible with that or those original purpose(s) and need to use your personal data for that purpose. If we do use your personal data in this way and you wish us to explain how the new purpose is compatible with the original, please contact us using the details in Part 12.
If we need to use your personal data for a purpose that is unrelated to, or incompatible with, the purpose(s) for which it was originally collected, we will inform you and explain the legal basis which allows us to do so.
In some circumstances, where permitted or required by law, we may process your personal data without your knowledge or consent. This will only be done within the bounds of the Data Protection Legislation and your legal rights.
7. How Long Will You Keep My Personal Data?
We will not keep your personal data for any longer than is necessary in light of the reason(s) for which it was first collected. Your personal data will therefore be kept for the following periods:
| Type of Data | How Long we Keep It |
| Sensitive and personal data including all medical information, name, email, NHS number, telephone number, profile and analytic data | 18months + 3days from last successful login.
(+1 month for backups to be cycled) |
| Non-Personal data including profile information. audit and crash reporting data | 18months + 3days from last successful login.
(+1 month for backups to be cycled) |
8. How and Where Do You Store or Transfer My Personal Data?
We will only store your personal data within the UK. Your data is stored encrypted (AES-256) within a secure cloud datastore. Data in transit is encrypted using HTTPS (TLS 1.2) and on your device sensitive data is encrypted using the devices passcode or biometrics (AES-256).
9. Do You Share My Personal Data?
We do not share your data in ways not described in this policy. In order to deliver our platform we use a limited number of 3rd party data processors. These 3rd party processors are themselves compliant with GDPR.
| 3rd Party Processor | Required Or Optional | Data Shared | Purpose | GDPR Compliance |
| Google Cloud Platform | Required | All platform data is hosted within a secure cloud database. All data is encrypted at rest. | To provide a stable and secure architecture to our platform. | https://cloud.google.com/security |
| Google Analytics | Optional | Non-identifiable activity within our platform. | Analytics to improve the platform. | https://support.google.com/analytics/answer/9019185?hl=en |
| Intercom | Optional | Name and Email | For Support | https://www.intercom.com/security |
| Gleap | Optional | Name and Email | For Bug Tracking | https://gleap.io/docs/Privacy/ |
| Encharge | Optional | Name and Email | For Marketing Emails | https://encharge.io/privacy-policy/ |
Where your personal data is shared with a third party, as described above, we will take steps to ensure that your personal data is handled safely, securely, and in accordance with your rights, our obligations, and the third party’s obligations under the law, as described above in Part 8.
If we sell, transfer, or merge parts of our business or assets, your personal data may be transferred to a third party. Any new owner of our business may continue to use your personal data in the same way(s) that we have used it, as specified in this Privacy Policy.
In some limited circumstances, we may be legally required to share certain personal data, which might include yours, if we are involved in legal proceedings or complying with legal obligations, a court order, or the instructions of a government authority.
Non Identifiable Data Sharing
We may share aggregated (non-identifiable) data with Health & Research Organisations to help evaluate the value of this service.
| Recipient | Activity Carried Out | Sector | Location |
| NHS Bodies including: ICS’s, PCN’s, Hospital Trusts, NHS England, NHS Digital | Sharing of anonymised data such as usage statistics and outcome measures such patient activation & quality of life measures. | Health Care | England |
10. How Can I Access My Personal Data?
If you want to know what personal data we have about you, you can ask us for details of that personal data and for a copy of it (where any such personal data is held). This is known as a “subject access request”.
All subject access requests should be made in writing and sent to the email or postal addresses shown in Part 12.
There is not normally any charge for a subject access request. If your request is ‘manifestly unfounded or excessive’ (for example, if you make repetitive requests) a fee may be charged to cover our administrative costs in responding.
We will respond to your subject access request within two weeks and, in any case, not more than one month of receiving it. Normally, we aim to provide a complete response, including a copy of your personal data within that time. In some cases, however, particularly if your request is more complex, more time may be required up to a maximum of three months from the date we receive your request. You will be kept fully informed of our progress.
11. How May Parents Access, Change or Delete Information About Their Children?
If you are a parent, and we need your consent to certain processing of your Children’s personal information, if you:
- wish us to cease further collection of personal information from your Children;
- believe your Children are participating in an activity on the App that uses their personal information without the parental consent required by law;
- wish us to make no further use of, or delete, the personal information we have collected online from your Children; and/or
- no longer wish for your Children to participate as registered users of the App,
we will delete your Child’s Profile, and any contact information we may hold, on request using the contact details in part 12.
For your Child’s protection, we may need to verify your identity before implementing any request. We will try to comply with your request as soon as reasonably practicable.
12. How Do I Contact You?
To contact us about anything to do with your personal data and data protection, including to make a subject access request or to ask us anything about this privacy policy, please use the following details:
Address: Canterbury House, 1 Royal St, Lambeth, London SE1 7LL
Email address: [email protected]
Telephone number: 0207 859 4169.
13. NHS Login
Please note that if you access our service using your NHS login details, the identity verification services are managed by NHS Digital. NHS Digital is the controller for any personal information you provide to NHS Digital to get an NHS login account and verify your identity, and uses that personal information solely for that single purpose. For this personal information, our role is a “processor” only and we must act under the instructions provided by NHS Digital (as the “controller”) when verifying your identity. To see NHS Digital’s Privacy Notice and Terms and Conditions, please use these links: https://access.login.nhs.uk/terms-and-conditions /https://access.login.nhs.uk/privacy. This restriction does not apply to the personal information you provide to us separately.
14. Changes to this Privacy Notice
We may change this Privacy Notice from time to time. This may be necessary, for example, if the law changes, or if we change our business in a way that affects personal data protection.
Any changes will be made available at http://digitalhealthpassport.co
This Privacy Notice is Version v1.8- 21/03/2023
