Daye Health Platform (DHP)

PRIVACY NOTICE

Version 2.0

Effective Date: December 1, 2023

We at Daye are conscious that when using the Daye Health Platform (“DHP”) available through Daye’s website located at www.yourdaye.com, our customers entrust their most intimate health-related concerns to us. This is why when developing and offering DHP , we prioritise transparency to our customers and security of their information. The DHP Privacy Notice aims to inform you how Daye handles and protects your personal information if you use the different services and products offered through DHP as detailed in our erms and Conditions.

It is important that you read this document together with our Website Privacy Policy available at this link which contains more general information about how we process data about visitors of Daye’s website. To use DHP, Daye customers are required to create a dedicated account on Daye’s Website (“DHP Account” or “Account”). Before using DHP and creating a DHP Account please read this Privacy Notice carefully. By accessing or using DHP or any products and services offered through DHP, you acknowledge that you’ve read this Privacy Notice and you agree with its content. If you do not agree to this Privacy Notice, please do not use DHP.

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Important information and who we are

We are Anne’s Day Ltd., a company established in the UK under company number 11044785 (just “Daye”, “we” or “us”). Daye is made up of different legal entities across the globe so when we mention Daye in this document, we are referring to the relevant company in the Daye Company Group which provides the DHP services and products to you and is therefore responsible for the processing of your personal information.

For the purposes of data protection laws, we are the controller and responsible for the processing of your personal data when you use DHP. If you have any questions about this privacy notice or our data protection practices with regard to DHP please contact us at hello@yourdaye.com.

The data we collect about you and how we use it

When you use DHP, incl. any products or services offered on DHP, we will collect, use, store transfer and process different kinds of personal information about you as described above:

Data category	What it is	How we will use it
Order ID	A randomly generated unique identifier for each Kit orderedon DHP	To process and execute your orders for DHP products and services
Order details (may include special categories of data)	Shipping address, contact details, DHP or third-party products or services purchased, etc.	To deliver our products and services and to comply with our contractual obligations to you.
Account ID	A randomly generated unique identifier assigned to every customer who has successfully registered on the DHP.	To identify you as an individual DHP customer and to allow you to log into your DHP account.To obtain your Medical ID once you log in the DHP (see next row for what a Medical ID is).
Medical ID	A randomly generated unique identifier assigned to every DHP customer for the purposes of managing our medical database. This identifier is linked to your Account ID via a separate database, and only you as an authenticated customer are able to obtain your Medical ID. This is a privacy-enhancing technique called pseudonymization which safeguards our customers’ identity and privacy when they use DHP.	To link the pseudonymised medical records in our medical database with individual customers without using direct identifiers. The medical ID will only be accessible to you, after you’ve authenticated yourself within the DHP. No other accounts, even Daye admins, will have access to this data.
Kit activation code	The Kit activation code is a unique identifier assigned to the Kit you’ve ordered. This is a randomly generated number that allows Daye to attribute a Kit to a particular customer and to generate a barcode image which is printed as a label included in your Kit.	To link a particular physical Kit and sample to a customer and to allow you to obtain your lab test results when ready.To allow the lab to submit the test results in Daye’s lab frontend system without knowledge of the customer’s identity.
Microbiome Screening Results (includes special categories of data)	These are the results provided by the lab after analysis of the microbiome in the sample you’ve sent to us after using your Kit. The results are provided to us by the lab without any knowledge of your identity.	Those results will be recorded by Daye in our patient medical database and will be retrievable to you as a holder of the activation code through the DHP.
STI Screening Results (includes special categories of data)	These are the results provided by the lab after analysis of any sexually transmitted viruses or bacteria in the sample you’ve sent to us after using your Kit. The results are provided to us by the lab without any knowledge of your identity.	Those results will be recorded by Daye in our patient medical database and will be stored there for 10 years as legally required from Daye. They will be kept in strict confidentiality and will be made available only to Daye employees and agents who have a “need-to-know” to the extent this is necessary for the purpose of treatment of the STI or prevention of the spread thereof.
Questionnaires and surveys you’ve filled on the DHP (may include special categories of data)	Any information contained in responses to questionnaires and surveys that we’ve provided to you and that you’ve filled on the DHP, for example - the questionnaire you have to fill when activating your Kit or questionnaires part of the Daye Period Pain Clinic.	To gain extra knowledge of our customers, their health status and their customer experience in order to provide you with more accurate healthcare recommendations tailored to your lifestyle, to provide you with the services you’ve requested and to also improve the quality of our services.
Correspondence between you and Daye (may include special categories of data)	This may include any written (e.g. email or physical mail) correspondence between you and Daye, incl. attachments thereof, and phone call recordings.	To provide service support to our customers.To deliver our products and services and to comply with our contractual obligations to you;

We may collect the information above in different ways, including:

Directly from you, for example – when you fill in questionnaires or when you participate in surveys.
By generating it ourselves, e.g. our systems generate randomly your Medical ID, your Kit Activation Code, etc. when you place a purchase.
By receiving it from third parties, for example - when laboratories we work with share your Microbiome or STI Screening Results with us.

Lawful bases for processing your personal data

We will process the personal data categories described in Section 1 above when at least one or more of the conditions below are met:

This is required to meet our contractual legal obligations to you or to exercise our rights;
You’ve consented to this;
It is within our legitimate business interests to do that when this will not cause disproportionate harms to your privacy and data protection rights, e.g. to send you direct marketing messages; to detect, prevent, investigate and report crime; to improve our existing and to develop new products and services; to conduct gynae health research.
When we are required by law to do so; or
When this is necessary to protect your or someone else’s life.

We may also process medical information about you which is afforded a higher level of protection under data protection laws. We will do that only if:

You’ve given us explicit consent to do so;
This is necessary for the establishment, exercise or defence of legal claims by Daye;
This is necessary for reasons of substantial public interest, incl. In the area of public health;
This is necessary for the purposes of preventive medicine;
This is necessary for archiving purposes in the public interest, scientific, historical research or statistical purposes; and
When this is necessary to protect your or someone else’s life.

How we share your personal data

We will share your personal data with other entities part of the Daye Company Group insofar this is necessary for the delivery of the DHP products and services or for the management of our business.

We will also share your Kit activation code/barcode with the laboratories we work with for the purpose of analysing your sample. Remember - we won’t share any directly identifiable attributes (such as names and addresses) with the laboratory.

We will share your personal data with other service providers or partners of our choice insofar this is necessary for the provision of DHP products and services or where we have a lawful basis for that, e.g. - our hosting service provider – Google, the provider of our electronic patient medical record services - Cliniko, healthcare specialists, pharmacies we work with such as Cedarwood and Phlo, accountants, etc. We will make sure that all those third parties are bound by confidentiality undertakings and will not use your information in a way different than as described in this document.

If your STI Screening Results are positive, we or the laboratories we work with may also share anonymised STI Screening Results with the UK healthcare public authorities for statistical purposes andt to comply with relevant legal obligations for reporting such diseases. If your STI Screening Results are positive, we may also notify your intimate partners and share your personal data, if you explicitly consent to that.

Please note that we may anonymise your data and we may share it with other third parties in a format in which your data is no longer attributable to you as an individual. For more information, please see “Research” section of the Terms and Conditions.

International transfers

We will transfer, store and process your personal data in the UK and the European Economic Area (EEA) but we may also transfer it to countries outside the UK and the EEA.

When we do that, we will ensure compliance with the applicable rules on transfers of personal data to third countries. Particularly, when your personal data is stored or otherwise processed in a country that is not considered to offer an adequate level of protection to your personal data compared to UK standards, we will make sure the recipient of the data in that third country is bound by the standard contractual clauses as approved by UK Parliament and by any other supplementary safeguards necessary to ensure your personal information continues to enjoy the same level of protection as if still in the UK.

Your legal rights

Under certain circumstances, data protection laws grant you rights in relation to the information Daye holds about you as detailed in our Website Privacy Policy available here.

Please note that if you’d like to receive a copy of your health information or test results, Daye allows you to download a file with all that information through the DHP so you can then send it to your own doctor or print it for your own archives.

Further details

If you are looking for more information on how we process your personal data including what your rights are, what are the data retention periods and lawful processing bases we rely on, etc. please consult our Website Privacy Policy available here.