Privacy policy

Last updated October 2024.

Maldaba Limited (registered number 05187518) (“us”, “our”, “we”, “Maldaba”) is the processor of your personal data collected through Maldaba platform, https://www.hearmenowchecks.com/ including apps on your smart phone (the “Platform”).  Maldaba is committed to protecting and respecting your privacy.

This privacy policy (the “Policy”) sets out the types of personal data we collect and use when you use the Platform and how we may use that data.

1 Introduction

This Privacy Policy explains who we are, why and how we process personal data collected through the use of the Platform and, if you are the subject of any of the personal data concerned, what rights you have and how to get in touch with us if you need to.

When you supply any personal data to us or we receive personal data about you from third parties (such as your GP), we have legal obligations towards you in the way we use that data. For ease of reading, we have divided this Policy into several sections:

1. Introduction
2. What information can we collect?
3. What lawful reasons do we have for processing personal data?
4. Special Category Data
5. How is your personal information collected?
6. How and why do we use and share your personal information? 
7. For how long do we keep your personal information?
8. Security
9. Your Rights
10. Contact Details

“You” may be a professional user of the Platform, working as a GP or in a GP practice. “You” may be a patient, or “You” may be a companion of a patient. You should keep your personal data accurate and current by ensuring that your GP and GP’s practice has up to date information about you.

It is important that you read this Policy together with any other privacy notice or fair processing notices that we may provide on the Platform at or around the time that we collect or process personal data about you (for example, fair processing notices that we may display to you at the time that you sign up to receive e-mail updates from us) so that you are fully aware of how and why we are using that data. 

This Policy supplements other notices on the Platform and is not intended to override or replace them.

By using the Platform, you agree to its terms (including as amended from time to time) and this Privacy Policy.  If, for any reason, you do not agree to the terms of this Policy, please stop using this Platform including the apps on your smartphone.

We reserve the right to revise or amend this Policy at any time to reflect changes to our business or changes in the law.  Where these changes are significant we will endeavour to let users of the Platform know. However, it is your responsibility to check this Policy before each use of the Platform – for ease of reference the top of this Policy indicates the date on which it was last updated.

Please note that the Platform collects and processes personal data of children under the age of 18 (each “Child” or “Children.”)

Please note that the Platform does not collect or process personal data of children under the age of 14.

Where we rely on performance of a contract as the lawful basis for processing Children’s data, we shall consider whether the Child is capable of understanding the obligations it is entering into. Where we rely on legitimate interest as the lawful basis for processing of Children’s data, we shall give due weight to the additional risks to Children of processing of their personal data.

2 What information can we collect?

What is personal data?

Where this Policy refers to ‘personal data’ it is referring to data about you from which you could be identified – such as your name, your date of birth, your contact details and even your IP address.

By law, all organisations who process your personal data in the UK are obliged to process your personal data in certain ways and to ensure that you are given an appropriate amount of information about how they use it. You also have various rights to seek information from those organisations about how they are using your data, and to prevent them from processing it unlawfully. For more information about these rights, please see the ‘Your Rights’ section of this Privacy Policy.

What types of data we collect from you when you use the Platform

The personal data we collect from you may include:

• Identity Data which includes your name, date of birth and gender.
• Contact Data which includes your e-mail address, home address and phone number.
• Technical Data which includes your IP address, your login data and browser type and version.
• Usage Data which includes information about how you use the Platform.
• For patients – Medical Data which includes data about your health and wellbeing and plans to improve your health and wellbeing.

3 What lawful reasons do we have for processing personal data?

We may rely on the following lawful reason when we collect and use personal data to operate our business and provide our services:

• Fulfilment of a contract: we require the personal data which is being provided by you because without it we cannot fulfil our contractual obligations to provide the system to manage patient Health Action Plans. The purpose of processing personal data is to provide a service which helps patients and GPs prepare, monitor and update Health Action Plans.

4 Special Category Data

We collect the following special categories of personal data about you:

• Medical Data – health and wellbeing data which may include your medical history.

When processing special categories of personal data, we are obliged to have an additional lawful bases for processing this data. In this case, the additional lawful basis is

• The management of health or social care systems pursuant to a contract with a health professional.

5 How is your personal information collected?

Direct interactions

When you use the Platform to make an appointment for an annual health check and/or complete a new Health Action Plan (HAP), update a HAP, contact us by email or by post, browse from page to page, we may collect, store and use the personal data that you disclose to us.

Automated technologies or interactions

Whichever type of user you are, we shall also collect information about you when you  visit and interact with the Platform through the use of technologies such as cookies.

The following are examples of information we may collect:

• information about your device, browser or operating system;
• your IP address;
• information about links that you click and pages you view on the Platform;
• length of visits to certain pages;
• subjects you viewed or searched for;
• page response times;
• records of download errors and/or broken links;
• page interaction information (such as details of your scrolling, clicks, and mouse-overs);
• methods used to browse away from the page; and
• the full Uniform Resource Locators (URL) clickstream to, through and from this Platform (including date and time).

We use the data described above for several different reasons. First we use it to ensure that the Platform works properly and that you are able to receive the full benefit of it. Secondly, we use the data to monitor online traffic and audience participation across the Platform. Thirdly, we use the data to gain insights about user preferences and interests. We undertake these activities because we have a legitimate interest in doing so.

For more information on this kind of technology, please see our Cookies Policy.

Updating your information

If you want to update the information we are processing about you, please contact your GP’s practice.

6 How and why do we use and share your personal information?

Lawful basis for processing your information

We will only use your personal data when the law allows us to.  Most commonly we will use your personal data in the following circumstances:

• Where you have asked us to do so, or consented to us doing so (although consent is not necessarily required for us to process your personal data);
• Where we need to do so in order to perform a contract we have entered into with you or another party;
• Where it is necessary for our legitimate interests (or those of a third party) and your fundamental rights do not override those interests; and
• Where we need to comply with a legal or regulatory obligation.

Here are some examples about how we may use the information we collect about you and the lawful basis we rely on to do so.

Activity	Examples of the types of personal data we may collect	Lawful basis for processing
To register you as a user and deliver services to you	Identity and contact information	Performance of a contract with the GP practice
To store content you have submitted to us on the Platform.	Identity.	Performance of a contract with the GP practice.
To manage our relationship with you including notifying you of any changes to the Platform or services provided on the Platform.	Identity, contact, profile and marketing communications information.	Performance of a contract with the GP practice If you are not a customer, we have a legitimate interest in doing so.
To administer and protect our business and this Platform (including troubleshooting, data analysis and system testing.)	Identity, contact and technical information.	We have a legitimate interest in doing so.
To use data analytics to improve the Platform, services, and experiences	Technical and usage information.	We have a legitimate interest in doing so.
To collect relevant health information, including medical history in order to assist in creating HAPs.	Special category data	We have a legitimate interest in doing so because the processing is needed in order to provide the management of health or social care systems pursuant to a contract with a health professional.

Communications

We may use your personal data to update you about the Platform.  

We will get your express opt-in consent before we share your personal data with any third party for marketing purposes.

Sharing your personal data

We may share the personal data we are processing it in the following ways:

• with selected third parties to which we sub-contract to provide various services and/or aspects of the Platform’s functionality (see “Service Providers” below); and

in the case of patients, with your GP, carers and/or social workers who are able to access the Platform to review the HAPs and make updates to them.

We may also disclose your personal data to third parties in the following events:

• if we were to sell or buy any business or assets, in which case we might disclose your personal data to the prospective seller or buyer of such business or assets as part of that transaction;
• if Maldaba or substantially all of its assets are acquired by a third party, in which case personal data held by us about our customers and contacts will be one of the transferred assets;
• if we are under a duty to disclose or share your personal data in order to comply with any legal obligation, or if we are asked to provide your details to a lawful authority in order to aid in the investigation of crime or disorder; and/or
• in order to enforce or apply the Platform’s terms of use or terms and conditions of sale; or to protect the rights, property, or safety of our company, our customers, or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction.

Service Providers (Data Processors)

Our service providers provide us with a variety of administrative, statistical, and technical services. We will only provide service providers with the minimum amount of personal data they need to fulfil the services we request, and we stipulate that they protect this data and do not use it for any other purpose. We take these relationships seriously and oblige all of our data processors to sign contracts with us that clearly set out their commitment to respecting individual rights, and their commitments to assisting us to help you exercise your rights as a data subject. We do not allow our third-party service providers to use your personal data for their own purposes. The following is a list of our major service providers:

• Hyve
• Google Analytics

Cookies

You can set your browser to refuse all or some browser cookies, or to alert you when Platforms set or access cookies. If you disable or refuse cookies, please note that some parts of the associated Platform may become inaccessible or not function properly. For more information about the cookies we use, please see our cookie policy

To find out more about cookies, visit www.allaboutcookies.org.

Change of purpose

We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.

If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

7 For how long do we keep your personal data?

We will hold your personal information on our systems only for as long as required to provide you with the services, including for the purposes of satisfying any healthcare regulations, legal, other regulatory, tax, accounting or reporting requirements.  We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation with respect to our relationship with you.

To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.

In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.

We may also collect, use and share aggregated data such as statistical or demographic data for any purpose. Aggregated data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity. For example, we may aggregate your usage data to calculate the percentage of users accessing a specific Platform feature.

8 Security

Maldaba takes the protection of your information very seriously. We have put in place technologically and organisationally appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. 

Where there is a password that enables you to access certain parts of the Platform including the apps, you are responsible for keeping this password confidential.  We ask you not to share a password with anyone. If you are concerned your password has been compromised, please contact the GP practice.

In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know.  They will only process your personal data on our instructions and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

9 Your rights

You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK regulator for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance hello@hearmenowchecks.com.  

As a data subject you have a number of rights in relation to your personal data. Below, we have described the various rights that you have, as well as how you can exercise them.

Maldaba will always process your personal data in a lawful, fair and transparent manner, in accordance with the UK GDPR. This Privacy Policy has been written to help you understand how and why we process your personal data, but if you require further information, we are happy to provide more detail. Please contact us at hello@hearmenowchecks.com.

Right of Access

You may, at any time, request access to the personal data that we hold which relates to you (you may have heard of this right being described as a “subject access request”).

Please note that this right entitles you to receive a copy of the personal data that we hold about you in order to enable you to check that it is correct and to ensure that we are processing that personal data lawfully. It is not a right that allows you to request personal data about other people, or a right to request specific documents from us that do not relate to your personal data.

You can exercise this right at any time by writing to us by contacting us and telling us that you are making a subject access request. You do not have to fill in a specific form to make this kind of request.

Your Right to Rectification and Erasure

You may, at any time, request that we correct personal data that we hold about you which you believe is incorrect or inaccurate. You may also ask us to erase personal data if you do not believe that we need to continue processing it including storing it (you may have heard of this right described as the “right to be forgotten”).

Please note that we may ask you to verify any new data that you provide to us and may take our own steps to check that the new data you have supplied us with is correct. Further, we are not always obliged to erase personal data when asked to do so; if for any reason we believe that we have a good legal reason to continue processing personal data that you ask us to erase we will tell you what that reason is at the time we respond to your request.

You can exercise this right at any time by contacting us and telling us that you are making a request to have your personal data rectified or erased and on what basis you are making that request. If you want us to replace inaccurate data with new data, you should tell us what that new data is. You do not have to fill in a specific form to make this kind of request.

Your Right to Restrict Processing

Where we process your personal data on the basis of a legitimate interest (see the sections of this Policy which explain how and why we use your information) you are entitled to ask us to stop processing it in that way if you feel that our continuing to do so impacts on your fundamental rights and freedoms or if you feel that those legitimate interests are not valid.

You may also ask us to stop processing your personal data (a) if you dispute the accuracy of that personal data and want us verify that data’s accuracy; (b) where it has been established that our use of the data is unlawful but you do not want us to erase it; (c) where we no longer need to process your personal data (and would otherwise dispose of it) but you wish for us to continue storing it in order to enable you to establish, exercise or defend legal claims.

In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms., We will tell you what that reason is, either at the time we first respond to your request or after we have had the opportunity to consider and investigate it.

You can exercise this right at any time by writing to us using the contact details set out here and telling us that you are making a request to have us stop processing the relevant aspect of your personal data and describing which of the above conditions you believe is relevant to that request. You do not have to fill in a specific form to make this kind of request.

Your Right to Portability

Where you wish to transfer certain personal data that we hold about you, which is processed by automated means, to a third party you may write to us and ask us to provide it to you in a commonly used machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.

Your Right to object to processing

You may object to processing of your personal data where we rely on legitimate interest for processing that personal data.  We will comply with your request unless we have a compelling overriding legitimate interest for processing or we need to continue processing your personal data to establish, exercise or defend a legal claim.

Your Right to stop receiving communications

Where we send you e-mail marketing communications (or other regulated electronic messages) you have the right to opt-out at any time. You can do this by using the ‘unsubscribe’ link that appears in the footer of each communication (or the equivalent mechanism in those communications).

Alternatively, if for any reason you cannot use those links, or if you would prefer to contact us directly – you can unsubscribe by writing to us at hello@hearmenowchecks.com and telling us which communications you would like us to stop sending you.

Your Right to object to automated decision making and profiling

You have the right to be informed about the existence of any automated decision making and profiling of your personal data, and where appropriate, be provided with meaningful information about the logic involved, as well as the significance and the envisaged consequences of such processing that affects you.

Withdraw consent, where consent is the lawful basis for processing

Notwithstanding that you have the right to withdraw consent at any time where we are relying on consent to process your personal data, we do not rely on sent to process your personal data.

Exercising your rights

When you write to us making a request to exercise your rights we are entitled to ask you to prove that you are who you say you are. We may ask you to provide copies of relevant ID documents to help us to verify your identity.

It will help us to process your request if you clearly state which right you wish to exercise and, where relevant, why it is that you are exercising it. The clearer and more specific you can be, the faster and more efficiently we can deal with your request. If you do not provide us with sufficient information then we may delay actioning your request until you have provided us with additional information (and where this is the case we will tell you).

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances.

We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

10 Contact Details

If you have any queries regarding this Privacy Policy, if you wish to exercise any of your rights set out above or if you think that the Privacy Policy has not been followed, please contact us by emailing at hello@hearmenowchecks.com

You may also lodge a complaint to the supervisory authority about the way we process your personal data.  We would however, appreciate the chance to address your concerns before you approach the supervisory authority, so please contact us in the first instance.