Privacy Policy

Privacy Policy
This Privacy Policy outlines the practices of MyCouchDoctor, located at 128 City Road, London,
EC1V2NX, United Kingdom, concerning the collection, use, and disclosure of your information when
you use our website https://mycouchdoctor.com (the “Service”). By accessing or using the Service,
you consent to the collection, use, and disclosure of your information in accordance with this Privacy
Policy.
We are always available to discuss how we handle and safeguard your information. If you have any
questions, want to update your information, change your user preferences, register a concern, opt
out of marketing, or anything else, feel free to reach us at info@mycouchdoctor.com.
About Us
As part of our service, we provide a Platform application to qualified medical practitioners (including
their relevant medical clinics). The Platform facilitates the delivery of healthcare services.
In this policy:
 "we", "our" or "us" refers to Value Digital Health Ltd company, and our related bodies
corporate identified below at section 14.
 "our services" means the provision of the Platform to you as a Patient and related services
that we provide.
 "you" refers to you, the reader of this policy.
 "your information" means your personal information that you may share with us
 "privacy laws" means all privacy and data protection laws that apply to us when we handle
your information, including applicable health information laws
What Information Do We Collect?
We collect and hold various categories of information, including personal information, health
information, payment information, device information, and general information to help us improve our
services.
The collection of extensive data sets, including device information, is crucial for enhancing user
experience, optimizing service functionality, and ensuring robust security measures. We process
such information based on legitimate interests—improving our services and maintaining
security—and where applicable, through explicit consent, which is transparently obtained at the point
of data collection. If you choose not to provide the requested information, it may impact our ability to
deliver these services to you fully.
Additionally, we may collect other types of information from you to further tailor and secure our
offerings, adhering to all requirements under all relevant regulations, ensuring transparency and
giving you control over your personal data.
Here are the main categories of information we collect:
Your General Personal Information
This includes identifiable information or opinion about you, such as your name, address, age or date
of birth, gender, contact number, and email address. For Practitioners, we may also collect
information relating to your qualifications, registrations, training, and educational background.

Payment and Claim Information
We may collect information from you to offer services or make claims on your behalf. This may
include credit card information, bank account details, and Medicare card and claim details.
Your Health Information
This includes any health information that Practitioners provide when accessing or using our website,
Platform, or other services. We may collect health information from you for the purposes of
facilitating the delivery of healthcare services by you. We may also collect health information of
Patients from Practitioners, including where a Practitioner has treated a Patient arising out of, or in
connection with the Platform. This may include information that a Practitioner provides directly to us,
or otherwise makes available to us. The types of health information may include your medical
history, clinical notes, test results, disease status, and prescribed medications (among others).
Device Information
This includes your device ID, device type, geo-location information, computer and connection
information, statistics on page views, traffic to and from the sites, ad data, IP address, and standard
web log information.
Additional Information You Provide
This includes information you provide to us through customer surveys, directly through our website,
or indirectly through your use of our website or Platform or online presence or through other
websites or accounts from which you permit us to collect information.
Information Collected for Our Own Business Improvement
We may de-identify your general personal information and use it in aggregate form to conduct
analysis on how our website, Platform, and other services are being used to help us improve our
services and provide benefits back to our users. When we refer to ‘de-identified’ information, we
mean information that has undergone a process of removing all personal identifiers that can
reasonably identify you so that there is no reasonable likelihood of re-identification occurring. When
we use this information for the purposes of business improvement, it is always in de-identified form.
De-identified Health Information
We may de-identify your health information and use it to provide the Platform functionality and to
improve the Platform and other services.
Information Collected by Cookies
We may collect de-identified information via cookies on our website, such as your browser type,
operating systems, and other websites visited. We may also collect some personal information when
using cookies, such as where a cookie is linked to your account. There are more details about
cookies in section 9.
Information Collected for Recruitment Purposes
When you apply for a job or position with us we may collect certain information from you (including
your name, contact details, working history, and relevant records checks) from any recruitment
consultant, your previous employers, and others who may be able to provide information to us to
assist in our decision on whether or not to make you an offer of employment or engage you under a
contract.

How Do We Collect Your Information?
We collect your personal information when you engage with us or from third parties. Here are some
of the main ways:
Registration
When you register on our website or Platform.
Communication
Where you communicate with us through correspondence, questionnaires, chats, email, or when you
share information with us from other services or websites. Communications may occur through the
Platform.
Interaction
When you interact with our sites, Platform, services, content and advertising, or use our Platform or
services.
We may also collect information about you from our related companies, third-party service providers,
and other organizations that we partner with. For example:
 When you apply for a job or position with us, we may collect information about you from any
recruitment consultant, your previous employers, referees, CV checking agencies, or others
who may be able to provide information to assist us with our decision.
 Where you are a Practitioner, we may collect information about your qualifications,
registrations, training, and education background from third-party sources, for purposes
which include verifying your status as a qualified medical practitioner.
How Do We Use Your Information?
We use your personal information to enable us to deliver and improve our products and services.
We adhere to privacy by design principles by integrating data protection from the outset of designing
our systems and business practices. Our measures include robust encryption, stringent access
controls, and continuous threat monitoring. Privacy impact assessments are conducted regularly to
ensure potential risks are identified and mitigated, ensuring data protection is a foundational aspect
of our operations.
We implement rigorous de-identification techniques to ensure personal and health data are
pseudonymized, stripping identifiable markers to prevent re-identification by unauthorized actors.
These processes are reinforced by stringent security protocols, including multi-layered encryption
and access controls, to safeguard the integrity and confidentiality of the de-identified data.
If we use personal information already collected in a manner different from that stated within this
Privacy Policy, we will notify users via an updated information notice. This notice will inform you of
the new use of the data and provide you with choices regarding its use.
Here are the main ways we use your information:
Access
To enable you to access and use our website, Platform, and other services.

Improvement
Design, provide, improve and manage our website, Platform, and other services, business and your
experience, such as to perform analytics and marketing.
Health Care Services
To facilitate the delivery of healthcare services to Patients. For example, information relating to
Patients’ medical history, complaints or symptoms may be collected and used by the Platform so that
Practitioners can make treatment decisions.
De-identified Information for Platform Functions and Improvement
We may de-identify and/or aggregate your personal information, including your health information,
for the purposes of using that de-identified information to provide certain functionality and develop
and improve the Platform.
Support
Send you service, support and administrative messages, reminders, technical notices, updates,
security alerts, and information requested by you.
Contact
Contact you when we need to tell you something important about the website, Platform and other
services, or your information.
Marketing
Send you marketing and promotional messages and other information that may be of interest to you.
Law
Comply with laws, and assist government or law enforcement agencies where we are required and
authorized to do so.
Employment
Consider your employment application.
Other Purposes When De-identified and/or Aggregated
We may also de-identify and/or aggregate your personal information for other purposes that may not
be set out in this Privacy Policy including improving our services and accuracy of our Heidi.
Unless permitted or required by law, we won’t use your health information without your consent.
How Do We Use Your Personal Information for Marketing, and How Do You Opt Out?
You can opt-out at any time from our marketing communications.
We may send you direct marketing communications and information about our services or products.
This may take the form of emails or other forms of communication. We’ll always conduct our
marketing practices in accordance with privacy laws and other applicable laws.

If we do send you marketing messages using your information, you’ll be able to opt out at any time –
either by using the unsubscribe facility in the relevant message or by contacting us (it’s easy – see
section 1).
We may also market our services to you generally – including via social media, advertising through
our website, and other digital or non-digital platforms. We’ll always do this in accordance with our
legal requirements.
Without your consent, we will not:
 Use any of your health information to send you marketing communications.
 Disclose any of your information to a third party in order for them to market to you.
Do We Store or Share Information Outside of Your Country?
For Australian, UK, US, EU, and Canadian users, your personal information is stored in your local
jurisdiction.
We understand the importance of data security and privacy and we’re committed to safeguarding
your information. We have implemented data localization solutions for customers located in
Australia, UK, US, the EU, and Canada. Please note that some functionalities of our Platform
depend on third-party services, whose servers may be located outside of your jurisdiction. This
however does not include sensitive or identifiable health information. Whenever these third-party
services are utilized, we ensure that data processing agreements are entered into. These
agreements enforce compliance with data protection standards and legal requirements,
safeguarding your personal information from unauthorized use or disclosure. This contractual
measure helps maintain the integrity and confidentiality of your data while enabling us to provide
enhanced functionality through external services.
Who Do We Share Your Information With?
We may share your personal information with our other partners and for other reasons we tell you
about in this policy, on our website, on our Platform, or where we otherwise communicate this to you.
We may share your personal information with:
 Our employees and related companies.
 Third-party suppliers and service providers (including providers for the operation of our
Platform, websites, and/or our business).
 Professional advisers, dealers, and agents.
 Payment systems operators (e.g., merchants receiving card payments).
 Anyone to whom our assets or businesses (or any part of them) are transferred.
 Specific third parties authorized by you to receive information held by us, and other parties
involved in the delivery of healthcare services.
 Other persons, including government agencies, regulatory bodies, and law enforcement
agencies, or as required, authorized, or permitted by law.
Using Our Website and Platform
We use cookies on our website to track your website usage and remember your preferences.

Our website includes pages that use cookies which are small files that store information on your
computer, mobile phone, or other device. We may use them to recognize you across devices and
browsing sessions.
You can configure your internet browser to accept all cookies, reject all cookies, or notify you when a
cookie is sent. If you refuse the use of cookies in this way you may not be able to access the full
functionality of our website. Please refer to your internet browser’s instructions or help screens to
learn more about these functions.
We may also use third-party analytics tools to help us gather and analyze information relating to your
use of our website and Platform.
How Do We Protect Your Information?
We take a number of measures to keep your information safe.
We generally hold personal information in our electronic databases. Our website and Platform and
our working environment are built with integrated physical, electronic, and managerial processes
designed to safeguard your information and protect it from misuse, interference loss, and
unauthorized access, modification, or disclosure. Here are some of the key things we do to protect
your information:
Staff Training
We put our staff through training about how to keep your information safe and secure at all times.
De-identification Tools
We use a range of tools designed to de-identify your information before it is used or disclosed for
certain purposes, as described in this policy.
Secure Storage and Handling
We use a combination of techniques and measures to maintain the security of our website and
Platform and to protect your account and your information.
Destroying or De-identifying Your Information
We only keep your information for as long as we need it or are lawfully required to keep it.
What Are Your Rights in Relation to Your Information?
You have rights in relation to your personal information. You can contact us to exercise any of your
rights in relation to your information.
Here are the things you can ask us to do in relation to your information at any time while you use our
website, Platform, or other services:
Access
You can request a copy of your information.
Correct

You can ask us to correct or update your information.
Complain
You can express your concerns or complaints to us about your privacy or the way we are handling
your information. We take your concerns seriously and will seek to fix any problem as soon as
possible.
When you contact us regarding a request for access, correction, erasure, or to make a complaint, or
if you wish to object to processing, withdraw consent, or request data portability, please include your
name and contact details (such as email address and phone number) and clearly describe your
request. We are committed to addressing your inquiries promptly and will acknowledge receipt of
your correspondence swiftly. We aim to formally respond to all requests within 30 days. If we are
unable to fulfill your request due to legal or other reasons, we will explain why. Verification of your
identity may be required to protect your information and ensure it is not disclosed improperly.
If you are not satisfied with how we handle your query or manage your information, including our
response to your requests, you have the right to lodge a complaint with your relevant Information
Commissioner’s Office. Additionally, for detailed information on how to exercise your rights under the
UKGDPR, including requests for data portability, please refer to our GDPR Compliance Policy. This
policy provides comprehensive guidelines on how you can manage your data, including how to
withdraw consent effectively.
Employees
We collect the following types of information from our employees:
Your General Personal Information
This includes identifiable information or opinion about you, such as your name, address, age or date
of birth, contact number, email address, and image.
Educational and Social Information
This includes details of your education, references from your institutions of study, and information
relating to your interests and extra-curricular activities. It also includes lifestyle information and social
circumstances, for example ‘life events’ such as marriage, divorce, bereavement, or adoption or birth
of children.
Sensitive Information
This includes information concerning your health and medical conditions, certain criminal convictions
and offenses, racial or ethnic origin, religious or philosophical beliefs, sexual orientation.
Financial Information
This includes your bank account number, tax identifier and status (including residence status), and
credit checks (where required).
Work-Related Information
This includes details of your work history, professional activities and interests, involvement with and
membership of industry bodies and professional associations, and any personal information
captured in the work product(s) you create while employed by us.

If you are a current or former employee and you have any questions in relation to our handling of
your personal information, please contact us at info@mycouchdoctor.com.
Changes to This Policy
If we need to change this policy in a way that affects the way we handle your information, if you use
our Platform, you’ll receive an alert from us. We will also publish the changes to it on our website.
We encourage you to check our website periodically to ensure that you are aware of our current
Privacy Policy.
Related Companies
Value Digital Health LTD is the owner of MyCouchDoctor and is located at 128 City Road, London,
UK. You can contact us via email at info@mycouchdoctor.com. If you have any questions regarding
privacy or security, please contact us via email at info@mycouchdoctor.com.
We may disclose your personal information to our related companies, including as set out in this
policy. If we do disclose your personal information to our related companies they may use your
information in accordance with this policy. If you access the services of our related companies, you
should also consider their privacy policy as it may be different from this policy.
Find Out More
You can find out more about the various privacy laws and other rules, regulations, and standards
we’ve mentioned in this policy by visiting the website of the Office of the Australian Information
Commissioner, Office of the Information Commissioner Canada, UK Information Commissioners
Office, or relevant the U.S. Department of Health & Human Services Office for Civil Rights or
equivalent state-based Information Commissioner.
Reviewed on December 2024