1. Definitions

• Expand Health Ltd ("Expand"): The company providing the mobile application. Company Number: 14728574. Address: 77 East Road Studio Shoreditch Bsl, London, N1 6AH.

• App: The mobile application developed and operated by Expand, which allows End-Users to connect with their Clinician, receive personalized health programs, integrate wearable devices, analyze biomarkers, and schedule appointments.

• Clinician: Your health coach, practitioner, or clinic with whom you are connected through the App.

• End-User: The individual who downloads and uses the App.

2. Introduction

Welcome to Expand. This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you use our mobile application (the "App"). Our App allows End-Users to connect with their Clinician, receive personalized health programs, integrate wearable devices, analyze biomarkers, and schedule appointments.

3. Information We Collect

When you register an account on the App or use the Expand services, we collect information about you, which directly or indirectly identifies you, as well as other personal information about you. You consent to us processing your personal information as set out in this policy.

We will only collect personal information for a purpose consistent with the purpose for which it is required. We may collect the following types of information:

a. Personal Information:

• Health Information: Customized health plans, biomarker data from blood tests, and other health-related information provided by your Clinician.

• Device Information: Details about the wearable devices you connect to the App and the health metrics they provide.

• Contact Information: Name, email address, phone number, and other contact details you provide to us.

b. Usage Data:

• App Usage: Information about how you use the App, including your interactions with the App and the features you use.

• Device Data: Information about your mobile device, such as device and network information, device model, operating system, and unique device identifiers.

c. Appointment Data:

• Scheduling Information: Details of appointments booked with your Clinician through the App.

4. How We Use Your Information

We will only process your information in a manner that is adequate, relevant and not excessive in the context of the purpose for which it is processed. That purpose will be compatible with that for which it was collected, unless you have consented to an alternative purpose in writing, or we are permitted to use the information in terms of national legislation of general application.

We will not, without your express consent, use your information for any purpose other than as set out below. 

We use the collected information to:

• Provide and maintain our services and access to the App, including personalized health programs and biomarker analysis.

• Sync and integrate data from wearable devices to enhance your health tracking and monitoring.

• Facilitate the scheduling of appointments with your Clinician.

• Improve the functionality and user experience of the App.

• Secure our systems, prevent fraud and help us protect the security of user accounts.

• Track your use of the App through the use of cookies and compile de-identified statistics relating to use of or feedback on the performance of the App.

• Communicate with you regarding your health programs, appointments, and other relevant updates.

• Train and update our artificial intelligence model, a failure or disruption in the Services provided by third-party upstream service providers.

We may use information collected to compile profiles for statistical purposes. No information contained in the profiles or statistics will be able to be linked to any specific End-User.

5. How We Share Your Information

We do not sell, trade, or otherwise transfer your personal information to outside parties except with your prior express consent and as described below:

• With Your Clinician: Your health information and program details are shared with your designated Clinician to provide personalized care.

• With Service Providers: We may share information with third-party service providers who assist us in operating the App and providing services, such as data storage or hosting and appointment scheduling.

• For Legal Reasons: We may disclose your information if required by law or in response to legal processes.

6. Destruction of Personal Information

We will delete all personal information, insofar as it relates to you when we receive a written instruction from you to do so unless we are obliged by law or under our obligations to you to retain such information.

We will destroy or delete any personal information that is no longer needed by us for the purpose it was initially collected, or subsequently processed.

We may retain information from deleted accounts to comply with the law, prevent fraud, resolve disputes, troubleshoot problems and enforce any of our terms. Any information we retain will be handled in accordance with this Privacy Policy.

7. Data Security

We implement appropriate, reasonable security, technical and organizational measures to protect your information from unauthorized access, misuse, disclosure, alteration, and destruction. We are committed to ensuring the security and confidentiality of your data through compliance with relevant regulations:

• GDPR Compliance: We adhere to the General Data Protection Regulation (GDPR) for End-Users in the European Union, ensuring that your personal data is handled with the utmost care and in accordance with your rights under GDPR.

• HIPAA Compliance: For End-Users in the United States, we comply with the Health Insurance Portability and Accountability Act (HIPAA), ensuring that your health information is protected and used only for authorized purposes.

If we share your personal information with third parties, we will ensure that the level of protection given to your personal information is at least as good as that provided for under the regulations listed above, either by means of a binding contract with the third party, or by using a third party located in a country with privacy laws of similar or stronger effect.

Despite our rigorous security measures, you understand that no data transmission over the Internet or electronic storage can be guaranteed to be completely secure and we cannot absolutely ensure or warrant the security of any information you transmit to us. We continually review and enhance our security practices to safeguard your information but transmitting personal information is done at your own risk.

8. Your Rights

Depending on your location, you may have certain rights regarding your personal information, including:

• Access: Request access to the personal information we hold about you.

• Correction: Request corrections to inaccurate or incomplete information.

• Deletion: Request deletion of your personal information, subject to legal and contractual obligations.

•  Restrict or Object: Restrict, object to or withdraw your consent to processing of your personal information, subject to legal and contractual obligations.

9. Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our practices or legal requirements. We will notify you of any significant changes by posting the updated policy in the App or through other appropriate means.

Continued use of the App or our services subsequent to any amendments having been made constitutes your acceptance of the Privacy Policy as amended.

10. Contact Us

If you have any questions or concerns about this Privacy Policy or our data practices, please contact us at:

Expand Health Ltd
77 East Road Studio Shoreditch Bsl
London, N1 6AH

Email: support@expand.health