Babylon Privacy Policy

Babylon’s mission is to put an accessible and affordable health service in the hands of every person on earth. We are passionate about high-quality and convenient health services. We are also passionate about privacy. We strive to comply with applicable privacy laws, and to be market leaders when it comes to health services and privacy.

At Babylon, we respect your privacy and appreciate the trust you have placed in us. This Privacy Policy (Policy) explains how we use your personal data when you visit our Website (Website). We want to help you understand how we work with your data, so that you can make informed choices and be in control of your information. We invite you to spend a few moments understanding this Policy. It is important that you read this Policy carefully because any time you use our Website, you consent, on your own behalf and/or on behalf of someone else, to the practices we describe in this Policy.

We may update this Policy from time to time, and if we make any material changes, Babylon will update the Effective Date noted above and post a notice regarding the updated Policy on our Website. By continuing to use our Website after the changes have been made, and we have notified you of them, the way we use your personal data will be subject to the terms of the updated Policy.

This policy covers:

1. Who we are;
2. What personal data we hold and how we get it;
3. What we use your personal data for;
4. Sharing your personal data;
5. Retention;
6. Data Security and transfers;
7. Your rights; and
8. Contact us.

If you have any further questions about how we process your information, please don’t hesitate to get in touch by contacting our Data Protection Officer:

Address: Data Protection Officer, Babylon Health, 60 Sloane Avenue, London, SW3 3DD

Email: DPO@babylonhealth.com

1. Who are we

Our health-related information is delivered in collaboration with commercial partners. Our commercial partners may provide the interface that users access, and we take care of the backend, such as the flow of questions, engine and generation of results, to suit the needs of individual markets.

When this policy talks about ‘Babylon’, ‘us’ or ‘we’, it means Babylon Partners Limited (i.e. our headquarter located at 60 Sloane Avenue, London, SW3 3DD, United Kingdom), and Babylon Singapore Pte. Limited (our Asia-Pacific head office located at The Great Room, 1 George Street, #10-01, Singapore 049145).

2. What personal data we hold and how we get it

We may collect the following categories of personal data:

a. Personal details

When you interact with our Website, you may complete forms and provide us with basic information about yourself, such as your name, gender, date of birth, mobile phone number, address and email address. You are responsible for the accuracy of the information that you provide to us.

b. Technical information and analytics

When you use our Website, we may automatically collect the following information where this is permitted by your internet browser when you use our Website:

• technical information, including the address used to connect your mobile device to the internet, your login information, system and operating system platform type and version, device model, application version, time zone setting, language and location preferences, wireless carrier and your location (based on IP address); and
• information about your visit, including services you viewed or used, Babylon App response times and updates, and interaction information (e.g. button presses, time spent interacting with content, etc.).

We work with partners who provide us with analytics for our services. This includes helping us understand how users interact with our Website and measuring performance of our Website. Cookies and similar technologies may be used to collect this information, such as your interaction with our services. Our Cookie Policy. You can prevent the setting of cookies by adjusting the setting on your mobile device.

c. Information obtained from third party services

Provided we are acting in accordance with data protection laws, we may also use information from other sources, such as our commercial partners. This information can, for example, help us to improve and measure the effectiveness of our services.

3. What we use your personal data for

The purposes for which we use your personal data and the legal grounds on which we do so are as follows:

a. Provide, customize and improve our Website

We use the information (always having removed personal identifiers, such as your name, address and contact details) we collect about you from our Website to improve and develop new products, services, features, and functionality as they become available on our Website, and to understand and analyse the usage trends and preferences of our users. We also use your information to personalise our Website, such as remembering information about you so that you will not have to re-enter it next time you use the Website, and monitor and analyse usage and the effectiveness of our Website. Strict confidentiality and data security provisions apply at all times. This consent relates to information that can identify you.

b. Comply with applicable law and enforce our legal rights

Based on our legitimate interest in managing and planning our business, we may analyse data about your use of our Website to troubleshoot bugs within our Website, forecast demand of our Website to understand other trends in use, including which features users use the most and find most helpful, and what features users require from us. This does not involve making any decisions about you that would have a significant legal effect on you - it is only about improving our Website so that we can deliver better services to you. Strict confidentiality and data security provisions will apply at all times.

We may also process the information we collect about you or from you to enforce our terms and other legal rights, including intellectual property rights, to comply with or address applicable laws, regulations, compliance purposes or legal processes, and to comply with industry standards and our policies.

4. Sharing your personal data with others

We will never share your personal data with any other party without your consent, except under circumstances as described below:

• We may share your personal data with our commercial partners. This is to help us deliver our Website to you;
• We may share with our commercial partners aggregated and anonymised data that does not personally identify you, but to show general trends, for example, the number of users of our Website;
• We may share your personal data with companies we have hired to provide services on our behalf, including those who act as data processors on our behalf, acting strictly under contract in accordance with relevant data protection regulations and laws. Those data processors are bound by strict confidentiality and data security provisions, and they can only use your data in the ways specified by us; and
• We may preserve or disclose information about you to comply with a law, regulation, legal process, or governmental request; to assert legal rights or defend against legal claims; or to prevent, detect, or investigate illegal activity, fraud, abuse, violation of our terms, or threats to the security of our services or the physical safety of any person.

5. Retention periods

We retain your records in accordance with best practice guidance.. The below is a summary of our retention policy, but we may retain records that do not identify you for legitimate business purposes such as managing or planning our business, or record for other periods as required by law or regulation.

6. Data storage, security and transfers

We do not store your personal data on your mobile device. We store all your personal data on secure servers.

We encrypt data transmitted to and from our software. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorized access. We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this Policy.

Your data may be processed or stored in destinations outside of the country within which you access our Website, but always in accordance with data protection law, including mechanisms to lawfully transfer data across borders, and subject to strict safeguards.

7. Your rights

Whenever we rely on your consent to process your personal data, you have the right to withdraw your consent at any time.

You also may have specific rights under PDPA and/or other relevant privacy laws, including:

• wherever we process data based on your consent, withdraw that consent at any time;
• understand and request a copy of information we hold about you, which is subjected to our retention periods; or
• ask us to rectify what we hold about you, which is subjected to our retention periods.

8. Contact us

If you have any questions or comments about this Policy, please contact us at dpo@babylonhealth.com.