LVNDR’s Privacy Notice
LVNDR’s Privacy Notice

LVNDR’s Privacy Notice

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Last updated on 28/04/2023

LVNDR Health is an LGBTQ+ community-led platform offering sexual healthcare and wellbeing services designed and enabled by LGBTQ+ clinicians to deliver remote care through an app. This currently includes at-home PrEP test monitoring, remote consultation with LGBTQ+ clinicians, and PrEP delivery.

LVNDR Health is the trading name of Troglo Ltd.

📮 Our contact details

Email: hey@lvndr.com

Address: 241 Southwark Bridge Road

❓ What is this notice all about?

We want to be completely transparent about how we collect and use your personal data and this privacy notice exists to tell you exactly how we do this.

This notice applies wherever we decide why and how we process personal data (and therefore act as a Data Controller under data protection law). It covers the personal data we process when you use our services.

Our privacy notice tells you the journey of your personal data from the moment it enters our systems up until it's time for us to say "goodbye 👋", as well as the various stops it makes along the way.

👇 The different ways we process personal data

When you join our app
🗂️ What personal data do we collect, why do we collect it, and what legal basis do we rely on?
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Personal data is anything that can identify an individual, either on its own or through combining it with other factors that could eventually identify an individual.

When you first join our app, we'll need some information about you, such as your name, email address, and Google or Apple ID if you choose to sign up that way, and we rely on Article 6(1)(f) of the GDPR - Legitimate Interests when doing so.

When you start PrEP with us, in order to ensure you the best clinical outcomes, we will need to process a your date of birth, gender, sex assigned at birth, pronouns, address, phone number, medical information including but not limited to HIV status and mental health information, demographic information, such as ethnicity and sexuality and risk factor information, such as immigration status and insecure housing. To do this we rely on Article 6(1)(b) of the GDPR - Contract or Article 6(1)(e) of the GDPR - Public Task, and Article 6(1)(f) of the GDPR - Legitimate Interests. For your special category data, we use Article 9(2)(h) of the GDPR - Health and Social Care the Schedule 1(1)(2) of the DPA 2018 - Health or social care purposes. Where needed, this information will be shared with our clinicians, our laboratory partners and our pharmacy partners in order to deliver your clinical outcomes.

If we have concerns that you may be a danger to yourself or others, we may share this information with the relevant authorities. To do this we would use Article 6(1)(d) of the GDPR - Vital Interests.

🗺️ Where do we store it?

To provide our services we share your information with our suppliers and cloud services. You can find more information about what sorts of places we send it and where they are below.

Application hosting providers - based in the USA, China and the EEA.

Data storage providers - based in the USA.

Internal communication providers - based in the USA.

Meeting scheduling providers - based in the USA.

Video-telephony providers - based in the USA.

Analytics providers - based in the USA.

Our Laboratory and Pharmacy Partners - LVNDR is working with a lab that is UKAS and CQC regulated and a pharmacy partner that is CQC and GPhC regulated both based in the UK.

⏲️ How long do we keep it for?

Due to the nature of the information we hold, we keep the mentioned information about you for 5 years, in line with our legal obligations as a healthcare service.

When you sign up for our emails
🗂️ What personal data do we collect, why do we collect it, and what legal basis do we rely on?
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Personal data is anything that can identify an individual, either on its own or through combining it with other factors that could eventually identify an individual.

When you sign up for our email newsletter or our pilot programme, we'll need some information about you, such as your name, email address and we rely on Article 6(1)(a) Consent

🗺️ Where do we store it?

We use Mailchimp to host our newsletter. They are based in the USA and you can find out more about them here.

⏲️ How long do we keep it for?

We keep the personal data mentioned until you unsubscribe from our newsletter.

When you visit our website

Our website uses cookies and other similar technologies of which you should be aware.

🗂️ What cookies do we collect, why do we collect them, and what legal basis do we rely on?
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Cookies are text files placed on your hard drive by a web page server when you visit a website and are saved in your browser's history. They allow the website to recognise your device and store some information about your preferences or past actions. Cookies cannot be used to run programs or deliver viruses to your computer; they are uniquely assigned to you and can only be read by a web server in the domain that issued the cookie.

When you use our website, the cookies can be stored on your device are either first party cookies, which are placed and read by us directly while you are using our website or third party cookies, which are set by other third parties we have partnered with.

Below is a list of the cookies we use and the purposes for which they are used:

Non-essential cookies
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These cookies are additional to the the performance of our Website and help us improve the service we provide to you.
Analytical cookies

These are third party cookies that enable us to monitor and analyse how visitors use our website and generate statistics based on them.

These cookies can be set by Google Analytics. Google Analytics is a web analysis service provided by Google Inc. (“Google”) which uses the Data collected to track and examine the use of our Website, prepare reports on its activities and share them with other Google services. Google may use the Data collected to contextualise and personalise the ads of its own advertising network.

Personal Data processed: Cookies and Usage Data.

Place of processing: United States – Privacy Policy.

You can choose not to store Non-essential cookies on your computer when you visit our website, or you can adjust your browser settings to prevent cookies from being saved on your computer. You can find information about how to manage Cookies in the most commonly used browsers at the following addresses:

📜 What are your rights?

Your personal data is yours and you have rights in relation to it granted by the UK GDPR, which include:

📮 The right to be informed

You have the right to be informed about the collection and use of your personal data, the purposes for processing, retention periods for that personal data and who it will be shared with. We have set this information out in this privacy notice.

🗝️ The right of access

You have the right to ask us for copies of the data we hold about you. If you ask us, we’ll confirm whether we’re processing your personal information and, if so, provide you with a copy of that personal information (along with certain other details).

The right to object

You have the right to ask us to stop processing your personal information in some circumstances, such as when we are relying on our own (or someone else’s) legitimate interests to process your personal information, when we are processing your personal information for direct marketing or when we are processing your personal information for research.

📝 The right to rectification

You have the right to ask us to rectify the personal information you think is inaccurate or to complete information you think is incomplete. When you ask us to rectify your information, if we’ve shared your personal information with others, we’ll let them know about the rectification where possible.

🧽 The right to erasure

You have the right to ask us to erase your personal information, in some circumstances, such as where we no longer need it or you withdraw your consent (where applicable).

🚫 The right to restrict processing

You have the right to ask us to restrict the processing of your personal information for a period of time in some circumstances, such as where you contest the accuracy of that personal information or object to us processing it. This right is separate from the right to object and will only stop us from using your personal information further, not from processing it. If we’ve shared your personal information with others, we’ll let them know about the restriction where possible.

✈️ The right to data portability

You have the right to ask that we transfer the personal information you gave us to another organisation, or to someone else, in some circumstances.

You don't have to pay anything in order to exercise your rights. Please contact us by sending an email to support@lvndr.com if you wish to make a request under your rights; we have a calendar month to get back to you with a response.

💔 How you can complain

If you have any concerns about our use of your personal information, please let us know by:

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Emailing us at support@lvndr.com, or
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Writing to us at 241 Southwark Bridge Road, London, England SE1 6FP

If you are not satisfied with our response or you are unhappy with how we have used your data, you can complain to the Information Commissioner's Office (ICO). You can find the ICO contact details below:

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ICO Address: Information Commissioner's Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF, Helpline number: 0303 123 1113.
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