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Last updated: 30th October 2024

 

1. OUR PRIVACY POLICY

The Hormona Services are owned and operated by Wlness Science LTD, located at The Old
Rectory, Church Street, Weybridge, Surrey, England. KT13 8DE (12944590), and our
subsidiary Wlness Science Sweden AB, located at Birger Jarlsgatan 57 C 113 56 Stockholm
(559440-1019), hereinafter referred to as ‘Hormona’, ‘we’, ‘our’.

We, at Hormona, believe that our technology and data offer a unique opportunity to empower women to take control of their hormonal health. The Hormona app provides you with the tools to track both your cycle and hormone related symptoms to understand their relation to hormonal fluctuations.

We strive to be the first global hormonal player to help women with hormonal issues worldwide, and we can’t do that without you, our users. We acknowledge the responsibility that comes with obtaining your personal and health data on the Hormona App, and ensure to always achieve high standards of privacy and security in compliance with EU GDPR, HIPAA and in accordance with applicable law.

Keeping your data safe, being clear and transparent, and ensuring you fully understand how we store, process and manage your data is of the utmost importance to us.

 

1.1 Consent

Please read our Privacy Policy carefully to understand how we handle your data, before using the Hormona App. This Privacy Policy does not cover the practices of companies we don’t own or control, or people we don’t manage.

In accordance with Article 9(a) of GDPR, The processing of health data to provide our service to you is based on you providing consent to the Privacy Policy for Hormona to process the health data you choose to share with the Hormona App.

By accepting this privacy policy you consent to the information outlined here within being collected and processed. You can manage your consent preferences in the app anytime following onboarding, for collecting and processing data that is non-essential to delivering and improving our Services.

If you have any questions or concerns, you may contact us by email on hello@hormona.io.

Please note, when you correspond with us, you explicitly provide consent for the processing of your personal data, in order to deal with the correspondence.

 

1.2 Our Recommendations for Protecting your Data

The biggest threat to the security and privacy of your data is by someone gaining access to any of the device(s) in which you avail of our Services, without your consent. The personal and health data you enter into the Hormona App is private, and we want to make sure it stays that way.

Here are some recommendations of how to protect your data:

  • Protect your Hormona account: Make sure you create a unique password for your Hormona Account. We have made sure your password must have eight (8) characters with at least one(1) letter and one(1) number. You will be automatically logged out of your account if you have not used the app for more than two (2) weeks.
  • Protect your Device: Activate passcode, TouchID or FaceID authentication on your device(s). This will automatically secure your Hormona Data and prevent any person from using your device without your permission. Set up a feature to allow you to erase all the data from your device if it’s been lost or stolen. For iOS, ‘Find my Iphone’ must be activated, then ‘Erase your device’ enabled. For Android, ‘Find my Device’ must be set up, and if needed, the connected web interface is used to lock or wipe your phone remotely.

 

1.3 Change(s) to our Privacy Policy

We may make change(s) to this Privacy Policy from time to time to reflect changes in the law, our data collection and data use practices, the features of Hormona services, or advances in technology.

It is your responsibility to check the Privacy Policy periodically for changes referring to the updated date at the top of the page, in order to know if it has been revised since your last visit. Any change(s) to this Privacy Policy that we consider to require your consent, will be notified to you.

 

1.4 Primary Language of our Privacy Policy

Whilst our Services are available in English and Swedish. Please note that the English version of this Privacy Policy is the original version. We have a dedicated process internally to provide and proofread translations of all our communications, including this Privacy Policy as accurately as possible. The English version of this document prevails over all other versions.

 

1.5 Definitions

‘Anonymous Data’ means information which does not relate to an identified or identifiable natural person. Personal data rendered anonymous in such a manner that the data subject is not or no longer identifiable.

‘Cookies’ mean small files of information generated by a web server, and sent to a web browser. Collective term for cookies and similar technology such as pixel tags, web beacons, clear GIFs and JavaScript.

‘Health Information’ means any personal information relating to your physical or mental health.

‘Personal Information’ means any information that identifies or relates to you (health information) and also includes information referred to as ‘Personally Identifiable Information’ or ‘Personal Data’ under applicable Privacy and/or Data Protection Laws.

‘Process’ means any operation(s) performed on personal information such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination, otherwise make available, align or combine, restrict, erase or destruct.

‘Pseudonymised’ means the processing of personal data in such a manner that the personal data can no longer be attributed to a specific person without the use of additional information.

‘Services’ means the services which have been made available through the website, and our app, along with any such other related goods, equipment, services and information made available to you from us.

‘SSL’ means secure sockets layer, which is a protocol that secures link exchanges between servers and browsers.

 

2. TYPES OF DATA WE COLLECT & PROCESS

 

2.1 Legal Basis for Processing

We will only process your Personal Information if we have lawful basis under EU GDPR for doing so, such as:

  • Consent: Except for the specific situations explained below, we process your Personal Information, and Health Information, provided by you, with your consent. You may withdraw your consent at any time and we will stop processing your Personal Information in this way.
  • Contractual Necessity: In order to be able to perform our contract with you in providing our services, we need to collect Personal Information and Health Information we have indicated as required.
  • Compliance with a legal obligation: We will sometimes have to process Personal Information in order to comply with a legal obligation imposed on us. Where those obligations are imposed by UK law, that law will provide us with a lawful ground for processing.
  • Legitimate Interest: We process the following categories of Personal Information when we believe it is in our legitimate interest to do so and we do not believe that your rights of freedoms will be unduly interfered with by our processing:
    • Device data is justified by our legitimate interest in maintaining a reliable and secure system, free from errors and external security threats.
    • Cookies, for the reasons set out in our Cookie Policy.

In short, Hormona are allowed to process all health information you choose to input into the Hormona App, because you have provided us the consent to do so.

 

2.2 Personal Information

When you create an account, we require information to manage your account. Such information includes your name, date of birth, email address and telephone number. We need this information in order to provide our service to you, therefore, you will not be able to create an account without providing this information.

We require your date of birth in order to comply with applicable laws and standards, and also to provide our services. This information ensures that we protect the privacy and security of all users, particularly those under the age of sixteen (16) years old. Also, it is essential that we know your age group to provide you the best possible insight into your hormone health.

You can provide a different name, such as a nickname and/or a made-up name which you would like to be known as in the Hormona Community. However, your email address and telephone number shall be used for two-factor authentication to access the Hormona App, so must be correct.

When you create an account, we may also use your email address to send you emails for the following purposes:

  • Providing you with information about our products or services.
  • Keeping in touch with you about the Hormona App, its performance as well as new versions and/or similar Apps we may develop.
  • Inviting you to participate in user feedback sessions to help improve our service.

Our legal basis for the above, is our legitimate interest in improving and promoting our Services. For more information, see the User Research and Mailing Lists sections below.

Hormona Plus (+) subscribers can choose to provide their partner’s Email Address which is used solely for sending weekly updates about your upcoming symptoms, and cycle phase along with educational information.

You have the option to amend/update all personal information in the Hormona App, in ‘Profile Settings’.

Please note, we do not retain your data in an identifiable format for longer than is required to provide our services.

 

2.3 Health Information

We require health information to provide the Services to you. Such information includes menstrual cycle data, hormone data and symptom logs. We require this data to provide our services including app functionality, personalised advice, recommendations, trends, as well as symptom and cycle predictions.

You can choose to provide further health information in your profile such as height, weight, pre-existing conditions and contraceptive use, to further personalise your profile and experience. You have the option to amend/update additional health information in the Hormona App, in ‘Profile Settings’.

 

2.4 Usage Information

If you use our Services, we will also collect information about you. Some of this information is direct (IP address, the type of browser used, make of smartphone, and the contents of cookies) as set in our Cookie Policy. We also use third party analytics providers such as Google Analytics, who collect similar information, and supply us with the analysis derived from it.

We process this data in order to:

  • Locate errors in our systems, and/or problems that our system may be facing with other systems (such as compatibility with a web browser).
  • Improve the functioning of our Service.
  • Prevent fraud or other criminal activity.

This information is automatically provided to us, and due to the nature of both browser and App software, it is inevitable that we process it. However, there are ways you can prevent us from receiving this information. For example, by changing the information your browser supplies to us.

 

2.5 Payment Information

Payment information is necessary in order for payments to be processed by a third-party payment processor. Such information includes the amount of payment, payment card type, payment card number and your billing address.

When you subscribe to Hormona Plus (+) all your payment information is securely processed by the Apple App Store or Google PlayStore. Hormona does not collect or process your payment information at any time.

 

2.6 Correspondence Information

Where you directly correspond with us (such as by sending an email to hello@hormona.io) we will process information about you concerning that communication, including the content of that email and our responses.

We are required to keep that information for as long as necessary to deal with that correspondence. For example, if you make a complaint, we shall retain that information for as long as needed to deal with the complaint, and then for a further five (5) years following close-out of the complaint.

 

3. ANONYMISING PERSONAL & HEALTH INFORMATION

We may create Aggregated, Pseudonymised or Anonymized Data from the Personal and Health Information we collect, by removing information that makes the data personally identifiable to a particular user.

We use your Health Information to improve our models of the interaction of hormones and health. The models we create have no individual information about you, being the aggregation of data from many individuals within the Hormona community.

We may use Anonymous Data and share it with third parties for our lawful business purposes, including to analyse, build and improve our Services, and promote our business.

We retain Anonymous Data indefinitely.

 

4. HOW & WHY WE PROCESS YOUR DATA

 

4.1 Providing our Services

Data processing is essential to provide our Services. Whenever you use our services, some personal and health information is collected, stored and analysed using both internal and third party tools.

We process health information when you track your health data in the app, to provide our core service as a hormone health tracking app. Device data is processed when you use the Hormona App or website, in order to understand how you interact with our services and to technically improve performance.

When you set up your Hormona account, we process account information to enable login, and to communicate with you on service-related topics. Communications may include information about your account, essential app updates, or insights and recommendations based on the health information you have provided. These communications shall be via email, or in-app notifications.

By accepting the Privacy Policy, you agree to your personal and health information to be processed so that Hormona can provide our hormone health tracking services.

 

4.2 Essential Third Party Providers of our Services

In order to provide our Services, we use the following third party services and integrations.

  • Aiven: Hormona uses Aiven, an open-source data platform to host our backend server.
  • BigQuery: Hormona uses BigQuery, a webservice in Google Cloud Platform, to analyse Health Information data. All data is stored on Google Cloud Platform.
  • Google Cloud Platform: Hormona uses Google Cloud Services as our hosting provider to store our data on secure servers. We only utilise Google Cloud data centres in the European Union. All data stored on Google Cloud is pseudonymised.
  • MixedPanel: Hormona uses services operated by MixedPanel, a company based in the United States, to monitor and analyse in-app activity to measure engagement with features in the app so we know what you love, and what could use our attention for improvement. All data stored in MixedPanel is Pseudonymised and contained in Google cloud data centres in the European Union.
  • Twilio: Hormona uses Twilio, a web service hosted on AWS, to send SMS verification for two-factor authentication to log into our App.

When first creating your account, there are several options to sign-up. In addition to signing up with your email address, its possible to use Services provided by Apple or Google:

  • Signing in with Apple: Allows you to create and sign into your Hormona Account using your Apple credentials, authorising us to collect your email address. If you sign up using Apple, Hormona will exchange certain information with Apple such as device data, IP-address, and information you provided to Apple when creating an account with Apple Inc. This may include a transfer of your Personal Information to Apple servers located outside the European Union. It is your choice if and to what extent you use the “Sign in with Apple” service and what information you provide to Apple. No health data will be exchanged with Apple for the purpose of using the “Sign in with Apple” service.
  • Signing in with Google: Allows you to create and sign into your Hormona Account using your Google credentials, authorising us to collect your email address. If you sign up using Google, Hormona will exchange with Google the types of data you provided to Google when creating an account with them (such as name, email address). This may include a transfer of your personal data to Google servers located outside the European Union. It is your choice if and to what extent you use the “Sign in with Google” service and what information you provide to Google. No health data will be exchanged with Google for the purpose of using the ‘Sign in with Google’ service.

By accepting the Privacy Policy, and creating an account you agree to our use of third party services outlined above in order to provide our Services, and meet the conditions laid out in our Terms and Conditions, in accordance with EU GDPR Article 6(b).

 

4.3 Providing Customer Service

When you contact us at hello@hormona.io with questions regarding our Services, you authorise Hormona access to process your personal and health Information depending on the nature of your query, in order to adequately answer your query.

By contacting us at our email address with a query, you provide consent for Hormona to process your personal and health information that may be contained within, to deal with the correspondence, in accordance with EU GDPR Article 6(a).

 

4.4 To Analyse, Build & Improve our Services

In order to build valuable features in our App, we process health information you have provided, to better understand which features are most useful to you. By doing this, we can better understand how our community uses the app, to individualise your experience.

Analysing how the Hormona Community use and interact with the app, allows us to understand which features are loved and valued. These insights are hugely important to drive feature development and indeed improvement to make sure we are delivering a service that meets your needs. This could mean improving the accuracy of predictions, building new algorithms to offer more insights, creating content based on topics submitted to our community, or based on the recipes most loved.

By accepting the Privacy Policy, you agree to your information being processed so that Hormona can analyse performance for improvement of our Services, in accordance with EU GDPR Article 6(b).

 

4.5 To Personalise your Experience by Making Recommendations

In order to individualise your experience we process certain usage data to understand how you interact with the app, including the health information you have provided. Collecting this data allows us to send you recommendations via email and push notifications (if enabled).

We do this with your Pseudonymised Data, and aggregate it with similar users Pseudonymised Data in order to provide information that’s more tailored to you. This includes sending you updates on new features, based on what you have logged, or suggesting interesting products/services from partnerships.

By accepting the Privacy Policy, you provide your consent for Hormona to process your account, usage and health information, so that we can provide personal recommendations for products and services based on the interactions, and information you have provided in the app, in accordance with EU GDPR Article 6(a). You can opt out of receiving recommendations for this purpose at any time in ‘Menu > Terms & Conditions> Privacy Preferences > Withdraw Consent’.

 

4.6 To Advance Hormonal Health Research

To help advance hormonal health research, we may share relevant Anonymised and/or Pseudonymised Data with trusted research partners.

The data you choose to provide Hormona is incredibly powerful, which collectively with the entire Hormona community is essential to advance women’s health, as currently, women are still widely underrepresented in health research. With your help, we are on a mission to improve gender research bias, and to do that, we may need help from trusted partners to advance research exponentially.

Where we share this Anonymous Data, it is directly relevant to the research question, and follows strict protocols to ensure your data remains anonymous to the researchers.

By accepting the Privacy Policy, you explicitly provide your consent for Hormona to your health information being Anonymised/Pseudononmyised, processed and shared with trusted partners to advance Hormonal Health Research, in accordance with EU GDPR Article 6(a). You can opt out of receiving recommendations for this purpose at any time in ‘Menu > Terms & Conditions> Privacy Preferences > Withdraw Consent’.

 

4.7 User Research

As a member of the Hormona Community, users may be invited, via email, to share some feedback by submitting surveys, attending interviews or contributing to focus groups. Interaction and feedback from the Hormona Community is key for us developing Services/Products you love. We may use surveys and run interviews to gain insights on certain health topics, the performance of our Services, or the value of features. Any information provided by you in a survey and/or interview is processed to provide and improve our services.

Hormona uses ‘Google Forms’, a survey tool provider offered by Google. By completing the survey and returning to us, and/or agreeing and attending an interview, you provide your consent for Hormona to collect and process any personal and health information contained within, in accordance with EU GDPR Article 6(a). We do not retain your personal data in an identifiable format for longer than is required for the purpose it was collected.

 

5. TRACKING, ADVERTISING & NOTIFYING

 

5.1 General Tracking 

Our Services use Cookies to enable our servers to recognise your web browser, tell us how and when you visit our website, analyse trends, and learn about our user-base to operate and improve our Services. Cookies are small pieces of data, usually test files, placed on your computer, tablet, phone or similar device when you use the device to access our Services.

This helps us to identify whether you’ve already downloaded Hormona, subscribed to Hormona Plus(+) and find out which advertisements you have interacted with (if any).

We may also supplement the information we collect from you with information received from third parties, including third parties that have placed their own Cookies on your device(s).

Please note, because of our use of Cookies, the Service does not support ‘Do Not Track’ requests sent from a browser at this time. For more information about our use of cookies, please see our Cookie Policy.

 

5.2 Third Party App Integrations

In order to track customer interaction with our Services, we utilise the following third party services and integrations.

  • CustomerIO: Hormona uses services operated by Customer.io, a company based in the United States, to help us facilitate communication with you via in-app push notifications and emails. Such communication may include information about your account, essential app updates, or insights and recommendations based on the health data you have provided. All data stored in CustomerIO is Pseudonymised and contained in Google cloud data centres in the European Union.
  • Sentry: Hormona uses services operated by Sentry, a company based in the United States, to track errors and monitor performance to identify and fix bugs, to make the app more stable and reliable. All data is stored using Google Cloud data centres in the European Union.
  • RevenueCat: Hormona uses services operated by RevenueCat, an open source to allow our users to opt-in to subscriptions on iOS and Android within the app.

 

5.3 Google Analytics

Our website uses Google Analytics, a web analysis service operated by Google. Google Analytics uses Cookies stored on your computer to allow for analysis of your visits to websites and interactions with them in order to personalise your experience and improve our services.

Find out more about Google Analytics Cookies here.

Google analyses this information to offer reports to Hormona on website usage and online usage of associated services. Under the terms of Google’s analytics service, Google may also transfer this information to third parties, either when this is required by law or when third parties are contracted by Google to process this data. Google must not allow your IP address to be linked to any other personal data.

We also advertise our Services using Google Ads, and utilise Google Analytics to track our advertisements.

By opting in via the cookie banner, you consent to data being used and processed by Google as described above. You can withdraw consent for this use of your data in this way at any time in your browser settings. Please note that this withdrawal only applies to future activities.

 

5.4 AppsFlyer

We have instructed AppsFlyer to aggregate the anonymised information we provide it, in order to group our users, providing us reports and insights to optimise promotional campaigns and target audiences for advertisement.

Appsflyer obtains the anonymised data from Hormona, and analyses it to aggregate data into user profiles and groups. Appsflyer passes on this analysis to third party integrations, such as Meta and Google to find people similar on social media and browsing platforms. Tracking in this way can be managed within settings on your device, and is not controlled by our App.

 

5.5 Notifications

By enabling notifications, you provide consent for us to provide Customer.IO with your unique Hormona-ID and email address, and pseudonymised Health Information including the current cycle phase you are in, in order to do so.

In-app notifications can be enabled/disabled in your devices settings under ‘Notifications’.

By accepting the Privacy Policy, you provide your consent for Hormona to process your email address and health information, to allow Customer.IO to provide personalised notifications in accordance with EU GDPR Article 6(a). You can opt out of receiving recommendations for this purpose at any time in ‘Menu > Terms & Conditions> Privacy Preferences > Withdraw Consent’.

 

5.6 Mailing Lists

You can subscribe to our mailing lists to get the latest updates on Hormona and/or our Services without creating a Hormona account, via our website. We will use the Personal Information, such as the email address you provide us with in order to do so.

By signing up to mailing lists and entering your details, you provide consent for us to process your Personal Information for that reason.

If you do not wish to receive these emails from us, you can opt out anytime by clicking ‘unsubscribe’ at the bottom of our email, and/or by requesting to unsubscribe by emailing hello@hormona.io. If you unsubscribe, we are required to keep some information on file to ensure we respect your preferences in the future.

 

6. STORING INFORMATION WE COLLECT

All information we collect in the Hormona App is stored securely in the backend of our App in our internal Hormona Database in the European Union.

All access information is encrypted and stored on your phone’s secure storage (If you use an iPhone this is called Keychain, if you use an Android this is called Keystore), to ensure that they are accessible only by you. Where you select to register for an account using Google or Apple the password is not shared with us. However, where you manually register your email and create a password all information is provided to us over SSL and is stored encrypted in our database.

Internally, the entire Hormona team uses a secure password sharing system to maintain the security of our systems, including our databases. Only very limited, trusted team members have access to the database.

All information in our database is identified by your unique Hormona User-ID. This ID is a meaningless sequence of numbers to anyone else but us. We do not process any identifiable information from our database, we clone our database into Google Cloud Platform, and process Pseudonymised Information there.

We use two-factor authentication to access all third party providers and integrations to ensure even your Pseudonymised Information remains secure. We also ensure all third-party services and integrations we use are in compliance with EU GDPR and store Pseudonymised Information in databases located in the European Union.

 

7. SHARING YOUR PERSONAL DATA

We do not share Personal Data with anyone else other than:

  • Contractors providing services we use for processing Personal Data under a professional duty of confidence, including:
    • Hosting, Technology, and communication providers.
    • Security and Fraud Prevention Consultants.
    • Analytics Providers for promotion of our services.
    • Support and Customer Service Venders.
    • Payment Processors.
    • Our Professional Advisors, such as if we need to consult an attorney for legal advice.
  • Others who carry out research into health, including academic research organisations (Universities), and commercial organisations (Pharmaceutical and LifeScience companies) for product development. When we collaborate with others in this way, we will always provide anonymous data to replace your personal details.

All of your Personal Data that we collect may be transferred to a third party if we undergo a merger, acquisition, bankruptcy or other transaction in which that third party assumes control of our business (in whole or in part). Should one of these events occur, we will make reasonable efforts to notify you before your information becomes subject to different privacy and security policies and practices.

 

8. HORMONA USERS UNDER THE AGE OF 16

When creating your Hormona account, you are required to provide your date of birth. Where a date of birth is entered that is below the age of sixteen (16) years old, we ask for confirmation that your parent/legal guardian has provided their consent that you can use our Services.

If you are a parent/legal guardian who has learnt that your child/ a child you are responsible for, is using the Hormona App without your permission, or you have a query about data privacy at Hormona, please get in contact with us via email at hello@hormona.io

We do not knowingly collect personal information from children under the age of thirteen (13) years old. Where we discover a user that is below that age, Hormona reserves the right to delete the account and wipe all relevant information about the account and user from our Servers.

 

9. YOUR DATA PROTECTION RIGHTS

Your privacy, and most importantly privacy of your data is a basic human right, a right we at Hormona truly respect.

Our Services are designed to collect only the information necessary to provide our Services. We only collect and process your data for the purposes outlined here within. Internally, the entire Hormona team uses a secure password sharing system to maintain the security of our databases. Only very limited, trusted team members have access to your Personal Information. We do not retain your personal information in an identifiable format for longer than is necessary. We do not process any identifiable information from our database, we clone our database into Google Cloud Platform, and process Pseudonymised Information there.

We use two-factor authentication to access all third party providers and integrations to ensure even your Pseudonymised Information remains secure.

As a user of our Services, you may exercise your rights under EU GDPR to:

  • Manage and/or Correct your Personal Information and Health Information in the app settings.
  • Request your Personal Information processed by Hormona. Upon your request, such information will be provided to you electronically. Please request at hello@hormona.io to be provided with your data within ten (10) working days.
  • Gain access to your information by requesting a copy of your data in a format that is readable by other companies or organisations.
  • Withdraw your consent from ongoing processing at any time by deleting your account, changing your privacy preferences, disabling notifications, and/or unsubscribing to mailing lists.
  • Request complete deletion of your data, including past data obtained, and sent to third-party providers and integrations by reaching out to hello@hormona.io. Your data will be deleted within one (1) month of the request being received.
  • Lodge a complaint with the relevant supervising authority where you believe Hormona is processing your Personal Information in violation of applicable data protection regulations.

 

If you have any questions, or if something in this privacy policy isn’t clear, please feel free to reach out to us at hello@hormona.io.

 

 

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