Welcome to LumiraDx Care Solutions UK Ltd’s privacy policy. LumiraDx Care Solutions UK Ltd (“We“) are committed to protecting and respecting your privacy.

This privacy policy (together with, where applicable, our Terms and Conditions of trading and End User Licence Agreement) applies only to:

• • your use of our website lumiradxcaresolutions.com (“our Site”);
  • your use of:
    • our software, such as our online software component known as INRstar and/or any other software (including software applications) owned by LumiraDx Care Solutions UK Ltd (“Software”);
    • third party software licenced to LumiraDx Care Solutions UK Ltd;
    • devices (such as patient self-care devices and/or any other devices, components or goods); and
    • our services,
      (“Products and Services”); and

• your purchase (or, in the case of devices, hire) of Products and Services,

and sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us. Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it. This privacy policy also tells you about your privacy rights and how the law protects you.

Our Site and Software is not intended for children and we do not knowingly collect data relating to children.

Your acceptance of this privacy policy is deemed to occur upon your first use of our Site and/or Software or place an order with us. If you do not accept and agree with this privacy policy, you must stop using our Site and/or Software immediately.

PERSONAL DATA

You may be asked to provide personal data whilst you are in contact with us. Personal data is information that can be used to identify or contact you. You do not have to provide the personal data that we request, however, if you choose not to, we may not be able to provide you with the services that you have requested.If we combine personal data with non-personal data, the combined information will be treated as personal data for as long as it remains combined. Personal data does not include data where the identity has been removed (anonymous data).

CONTROLLER

For the purpose of the General Data Protection Regulations ((EU) 2016/679) and any national implementing laws, regulations and secondary legislation and the Data Protection Act 1998 (“Data Protection Legislation”) the data controller of your personal data is LumiraDx Care Solutions UK Ltd a company registered in England and Wales with company registration number 03473597 whose registered office is at Lowin House, Tregolls Road, Truro, Cornwall TR1 2NA. Our Data Protection Registration Number is Z2996445.

This privacy policy does not apply to clinical or other associated data relating to patients, collected in the course of treating patients, which is inputted by you (or us on your behalf) onto the Software for the purpose of using the Software, Products and Services (“Patient Data”). For the purposes of Data Protection Legislation, LumiraDx Care Solutions UK Ltd is the data processor of Patient Data which is processed in accordance with our Terms and Conditions of trading.

INFORMATION WE MAY COLLECT FROM YOU AND HOW WE USE IT

We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:

• Identity Data includes your name, username, password, postal address, email address, telephone number and address associated with your order, your professional registration number and your employment status. The identity data may be processed for the purpose of setting up your user account within the Software, processing and delivering your order for Products, for the installation and servicing of Products, managing our relationship with you (including notifying you about changes to our privacy policy and to our Products and Services, to provide you with feedback as to your use of our Software and how to improve performance, for support, maintenance and patient safety (including the investigation of faults) and to provide training), enabling you to complete a survey, administer and protect our business, Site and Software (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data).  The legal basis for this processing is the performance of a contract and/or taking steps, at your request, to enter into such a contract and our legitimate interests (namely to keep our records updated, to study how our Site, Software and Products are used, for the running of our business, provision of administration and IT services, network security).

• Contact Data includes your name, email address, telephone number and postal address associated with your account or order. The contact data may be processed for the purpose of contacting your directly in relation to the Software, Services or Products, processing and delivering your order for our Products, for the installation and servicing of Products, managing our relationship with you (including notifying you about changes to our privacy policy and to our Products and Services, to provide you with feedback as to your use of our Software and how to improve performance, for support, maintenance and patient safety (including the investigation of faults) and to provide training), enabling you to complete a survey, administer and protect our business, Site and Software (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data). The legal basis for this processing is the performance of a contract and/or taking steps, at your request, to enter into such a contract and our legitimate interests (namely to keep our records updated, to study how our Site and Software is used, for the running of our business, provision of administration and IT services, network security).

• Financial Data includes bank account, direct debit and payment card details (type, number, name on card, expiry date and CCV code). The financial data may be processed for the purposes of processing and delivering your order for our Products and Services (namely managing payments and charges and collecting monies). The legal basis for this processing is the performance of a contract and our legitimate interests (namely to recover debts due).

• Transaction Data includes details about any Products, Services and Software you have ordered from us. The transaction data may be processed for the purpose of processing and delivering your order. The legal basis for this processing is the performance of a contract and our legitimate interests (namely our interest in the proper administration of our Site, Software and business).

• Technical Data includes internet protocol (IP) address, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the computer, smartphone, mobile telephone or other electronic device you use to access our Site and Software. The technical data may be processed for the purpose of administering and protecting our business, Site and Software (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data), to ensure that content from our Site and Software is presented in the most effective manner for you and for your computer, smartphone, mobile telephone or other electronic device to improve the performance and features of our Software, to maintain our Software and ensure you are using the correct version of our Software, to keep our Site and Software safe and secure. The legal basis for this processing is our legitimate interests (namely to grow our business and protect our Site and Software).

• Profile Data includes your email, username and password, details of orders made for our Products and Services, your interests, preferences, feedback and survey responses. The profile data may be processed for the purpose of managing our relationship with you (including notifying you about changes to our privacy policy and to our Products and Services and asking you to leave a review), enabling you to complete a survey, to make suggestions and recommendations to you about other Products and Services that may be of interest to you. The legal basis for this processing is the performance of a contract and our legitimate interests (namely to keep our records updated, to study how our Software is used and to grow our business and to inform our marketing strategy).

• Usage Data includes information about how you use our Site and Software (including the pages you look at and how you use them). This usage data may be processed for the purposes of support, maintenance and patient safety (including the investigation of faults), to maintain and protect our Software and ensure you are using the correct version of our Software, to improve the performance and features of our Products and Services, to provide you with feedback as to your use of our Software and how to improve performance, to provide training, enabling you to complete a survey, to deliver relevant website contents and use data analytics to improve our Site, marketing, customer relationships and experiences and to make suggestions and recommendations to you about Products and Services that may be of interest to you. The legal basis for this processing is the performance of a contract and our legitimate interests (namely to study how our Site and Software is used and to grow our business and to keep our Site and Software updated and relevant).

• Installation and Service history Data includes records relating to the installation of our Software at your home or business and information relating to the servicing of that Software Installation and Service history Data may be processed for the purposesof improving the performance and features of our Products and Services, to maintain and protect our Software and ensure you are using the correct version of our Software. The legal basis for this processing is the performance of a contract and our legitimate interests (namely to keep our Software updated and relevant and improve the performance of our Software).

• Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences. The marketing and communications data may be processed for the purposes of sending you the relevant notifications. The legal basis for this processing is our legitimate interests and consent.

In addition to the specific purposes for which we may process your personal data set above, we may also process any of your personal data where such processing is necessary for compliance with a legal obligation and to ensure regulatory compliance to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.

We also collect, use and share anonymised Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy policy.

We may also provide you with information about offers and services that are similar to those that you have already received or we feel may interest you. If you:

• have already concluded a contract with us, (e.g. if you have purchased Software, Products and Services from us) we will only contact you by electronic means (e-mail, text or Software notifications) with information about offers and services similar to those which were the subject of a previous contract. If you do not want to be on our mailing list, you can opt out at any time by contacting us or unsubscribing by using the links provided in our electronic communications and at the point of providing your details.

• are a potential new customer (e.g. enquiring about Software, Products or Services), we will contact you by electronic means only if you have provided your explicit consent to this. If you are happy for us to use your personal data in this way, please tick the relevant box situated on the website page/form on which we collect your details. Again, if you do not want us to use your data in this way, you can opt out at any time by contacting us or unsubscribing by using the links provided in our electronic communications.

HOW IS YOUR PERSONAL DATA COLLECTED

We use different methods to collect data from and about you including through:

• Direct interactions. You may give us your Identity, Contact, Financial Data and Marketing and Communication Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
  • order Products and Services from us (which will generate the Transactional Data);
  • create a user account in our Software;
  • request the installation and servicing of Software you have ordered form us (which will generate the Installation and Service history Data);
  • request marketing to be sent to you;
  • enter a survey;
  • reporting a problem with our Site or Software;
  • leave a review or complete a contact form for customer service queries; or
  • give us some feedback.
• Automated technologies or interactions. As you interact with our Site or Software we may automatically collect Technical and Usage Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies. When you interact with our Software we may also automatically collect Profile Data.

• Third parties or publicly available sources. We may receive personal data about you from various third parties which include:
  • Identity and Contact Data from companies within our group (the “LumiraDx Group”);
  • Identity and Contact Data from approved third party software providers;
  • Contact, Financial and Transaction Data from providers of technical, payment and delivery services.
  • Marketing and Communication Data from advertising networks;
  • Technical Data from analytics providers such as Google based outside the EU; and
  • Identity and Contact Data from publicly available sources, such as social media accounts, Companies House and the Electoral Register.

WHERE WE STORE YOUR PERSONAL DATA

Some of the third parties which we work closely with are based outside of the European Economic Area (“EEA”) so their processing of your personal data will involve a transfer of data outside of the EEA.

Whenever we transfer your personal data out of the EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

• we will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission;
• where we use certain service providers, we may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe;
• where we use providers based in the US, we may transfer data to them if they are part of the Privacy Shield which requires them to provide similar protection to personal data shared between the Europe and the US.

Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.

Where we have given you (or where you have chosen) a password which enables you to access certain parts of our Site or Software, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.

Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our Site; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access.

COOKIES

Our Site uses cookies to distinguish you from other users of our Site. This helps us to provide you with a good experience when you browse our Site and also allows us to improve our Site.

Cookies are small data files which are stored on the hard drive of your computer. Cookies contain certain personal information about you, which help us to deliver a better and more personalised service.

You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of our Site may become inaccessible or not function properly.

We use the following cookies on our Site: