Daye Health Platform (DHP)

PRIVACY NOTICE

Version 1.0

Effective Date: 11th August, 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 services via the DHP, including our vaginal microbiome screening service (“VMS”)(“Services”), we prioritise transparency to our customers and security of their personal information. The DHP Privacy Notice aims to inform you how Daye handles and protects your personal information if you use the services and products offered through DHP.

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 and Daye customers in general. 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 clicking “I accept” prior to accessing or using the DHP, you acknowledge that you’ve read this Privacy Notice and you agree with its content. If you do not agree to the terms of this Privacy Notice, do not use the DHP.

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Important information and Who We Are

We are Anne’s Day Inc., with an address at 2140 S.Dupont Highway, Camden, Delaware, 19934 (just “Daye”, “we” or “us”).

For the purposes of data protection laws, we are the controller and responsible for your personal information 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

Types of Data We Collect: When you use DHP, including any products or services offered on DHP, we will collect, use, store and transfer different kinds of personal information about you. The main types of information we collect include:

Data category	What it is	How we will use it
Order ID	A randomly generated unique identifier for each test kit order placed on DHP	To process and deliver your orders
Order details	Shipping address, contact details, goods or services purchased, etc.	To process and deliver your orders
Account ID	A randomly generated unique identifier assigned to every customer who has successfully registered on the DHP.	To identify you as a 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 customer for the purposes of 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 medical records in our medical database with 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 physical test kit you’ve ordered. This is a randomly generated number that allows Daye to attribute a test 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 test 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.
Screening Test Results	These are the results provided by the lab after analysis of the sample we’ve sent to them. The results are provided to us by the lab without any knowledge of your identity.	Test results will be recorded by Daye in our medical database and will be retrievable only by you as a holder of the activation code through the DHP.
Questionnaires and surveys	Your responses to questionnaires and surveys that we’ve provided to you and that you’ve filled, for example - the questionnaire you have to fill when activating your Kit	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.

In addition to the above, we may collect other types of personally identifiable information (“Personal Information”) and other non-identifiable information from you when you register for the DHP, respond to communication such as e-mail, or otherwise use the DHP in any manner. For example:

We may collect and use IP addresses and session identifiers to analyze trends, to administer the Services, to track user activities, to infer user interests, and to otherwise gather information about individual users and market segments.
If necessary to provide you the Services, we may collect protected health information (“PHI”), as defined by the Health Insurance Portability and Accountability Act of 1996 (“HIPAA”). Any use or disclosure of PHI will be in accordance with applicable laws, including HIPAA.
Like many web sites and certain mobile apps, we use and may allow third party service providers to use “cookies” and/or other tracking technologies to enhance your experience and gather information about visitors and visits to our website and the DHP, including how you use the Services (“Usage Data”). Please refer to the Cookie Policy for information about cookies and how we use them.
We may also collect transactional information, customer services information, or any other legally permissible information.

Your information may be supplemented with additional information from other companies such as publicly available information, information about households and other information that we may append or match to your information.

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

Directly from you, for example – when you share your health information or when you participate in surveys.
By generating it ourselves, e.g. our systems generate randomly your Medical ID, your Kit Activation Code, etc.
By receiving it from third parties, for example - laboratories we work with sharing your Screening Test Results with us.

How We Use the Data We Collect: We may use the Personal Information and other data we collect from you when you register on the DHP, purchase Services, respond to a survey or marketing communication, access or view the Services or use certain other DHP features in the following ways:

To provide any legitimate service or product.
To personalize your use of the Services and to allow us to deliver the type of content and product offerings in which you are most interested (including to present offers to you on behalf of third-party businesses and advertisers).
To allow us to better respond to your customer service requests.
To contact you when necessary or requested.
To quickly process your transactions.
To verify and validate your identity.
To administer a promotion, survey or other Service feature.
To the extent you have not opted out of receiving marketing communications, to send you information about Daye and our products or services, or to provide you with information about third-party businesses, products and services, including by letter, email, text, telephone or other forms of communication.
To show you advertisements, including interest-based or online behavioral advertising.
To troubleshoot concerns with the DHP, or any Services, as requested, and respond to your inquiries.
To enforce the Terms and Conditions, and to detect and protect against error, fraud and other unauthorized or illegal activities.
To operate and improve the Services available through the DHP and Daye website, including but not limited to using your Personal Information for data analytics and product improvement efforts.
To fulfill your requests for tools, software, functionality, features and other products, and services;
To conduct research about your use of our products and services and offer you other products, features or services that may be of interest.

How we share your personal information

We will share your personal information with other entities part of the Daye Company Group insofar this is necessary for the delivery of the DHP 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 information with other service providers of our choice insofar this is necessary for the provision of DHP products or services or where we have a lawful basis for that, e.g. - our hosting service provider – Google, healthcare specialists, pharmacies, accountants, etc. We will make sure that all those third parties are bound by confidentiality obligations and to the extent applicable, written agreements to protect the confidentiality and integrity of the Personal Data, and will not use your information in a way different than as described in this document.

Please note that we may de-identify your personal information 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 erms and Conditions.

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 information 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.

Please note that, because we offer our services on a global basis we have chosen to use the European Union (GDPR) model, often considered as the strictest model for user transparency, as the format for our Privacy Policy. Consequently, based on the privacy and data protection laws that apply to you based on the location from which you access our VMS, you may not necessarily understand the meaning of some of the terms used in our Privacy Policy and, consequently, in this privacy notice, we refer you to our Glossary of terms at the end of our Privacy Policy to help you make better sense of both our Privacy Policy and this document.