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Privacy Policy and Data Processing Agreement

Overview

This document explains how we collect, process, and store your health data, including blood test results and associated personal information, to ensure transparency and compliance with applicable laws in Australia, the United Kingdom (UK), the European Union (EU), and the United States (US).

1. Data Collection and Storage

Data Processing Details

File Types and Upload:

  • We accept blood test results in PDF, JPG, and PNG formats
  • You can upload historical test results to build a comprehensive health timeline
  • Files are securely encrypted upon upload

Data Analysis

  • We use artificial intelligence to extract data from your blood test results
  • Analyze patterns and trends
  • Provide general information about your test results
  • Generate visualizations of your historical data
  • Our AI provides general advice and information based on publicly available medical knowledge
  • This analysis is automated and not reviewed by healthcare professionals

Important Disclaimers

  • Our service is for informational purposes only
  • Analysis and advice are generated by AI and are not verified by medical professionals
  • This is not a substitute for professional medical advice, diagnosis, or treatment
  • Always consult qualified healthcare professionals for interpretation of your test results
  • Never disregard professional medical advice or delay seeking it because of information provided by our service

2. User Authentication and Consent

To use our services, you must:

  • Create an account with a valid email address
  • Verify your email by clicking the verification link
  • Explicitly consent to storage and processing of your health data
  • Accept processing of your data in the United States
  • Accept our Privacy Policy and Terms of Service
  • Self-declare that you are 18 years or older

3. Data Protection Measures

We employ robust security measures to protect your data:

  • End-to-end encryption for all data transmissions
  • Secure storage using advanced encryption protocols
  • Strict access controls and multi-factor authentication
  • Regular security audits and monitoring
  • Secure deletion of data upon account termination

Full compliance with:

  • APP 8 and APP 11 for overseas disclosure and data security
  • UK GDPR requirements for special category data
  • EU GDPR data protection principles, including data minimization and purpose limitation
  • HIPAA requirements for protecting PHI

4. User Rights and Access

You have the following rights:

  • Access: View your stored personal and health information
  • Correction: Request corrections to your data
  • Withdrawal: Withdraw consent and request data deletion
  • Copy: Receive a copy of your stored data
  • Complaints: Lodge complaints about data handling
  • Breach Notification: Be notified of any data breaches affecting your personal information

These rights are granted under:

  • Australian Privacy Act 1988
  • UK GDPR
  • EU GDPR
  • HIPAA

5. Account Requirements

  • Self-declaration of being 18 years or older
  • A valid, verified email address
  • Enforced strong password requirements
  • Optional two-factor authentication for enhanced security

6. Children's Data

Our services are not intended for individuals under 18 years of age:

We do not knowingly collect or process data from individuals under 18. If discovered:

  • Data processing will immediately cease
  • All collected data will be deleted
  • Relevant authorities will be notified where required

7. Third-Party Access and Processing

We may share your data with:

  • Service Providers: To assist in delivering our services
  • Data processing will immediately cease
  • Legal Authorities: When required by law
  • Emergency Services: In cases of imminent harm

All third parties are bound by:

  • Strict confidentiality agreements
  • Data processing agreements
  • igorous security requirements

We ensure compliance with:

  • APP 8 for overseas disclosure
  • UK GDPR and EU GDPR for data processing agreements
  • HIPAA for third-party business associate agreements (BAAs)

8. Cookies and Tracking

We use cookies for:

  • Essential Functions: To enable account functionality
  • Session Security: To maintain session integrity
  • Legal Authorities: When required by law
  • Analytics: With your explicit consent

Cookie preferences can be managed via your browser settings.

9. Data Processing Location

Your data will be processed in the United States and stored securely in compliance with:

  • APP 8 for cross-border data transfers
  • UK GDPR and EU GDPR for international data transfers
  • HIPAA for secure data processing and storage

10.International Data Transfers

We ensure that any international data transfer:

  • Complies with cross-border data transfer regulations
  • Is safeguarded by appropriate measures, including Standard Contractual Clauses (SCCs)
  • Is necessary for delivering our services
  • Is disclosed to you before the transfer

11.Technical Security Details

Our security measures include:

  • Regular security assessments and vulnerability testing
  • Employee access controls and training
  • Incident response protocols
  • Data backup and recovery systems
  • Continuous system monitoring and logging

Compliance with:

  • ISO 27001 standards for information security management
  • NIST Cybersecurity Framework for risk management

12. Limitations and Disclaimers

  • Our service provides AI-based analysis only and is not a substitute for medical advice
  • Users should consult qualified healthcare professionals for medical interpretation
  • We do not sell or share your data with third parties
  • We comply with lawful requests from authorities when required

13. Data Retention

  • Data is retained while your account is active
  • Automatic deletion occurs 30 days after account termination
  • Backup copies are retained for a maximum of 90 days
  • Usage logs are retained for up to 12 months

14. Data Breach Response

In the event of a data breach:

  • Affected users will be notified within 72 hours
  • Details of the breach will be provided
  • Steps taken to mitigate risks will be outlined
  • Guidance on recommended actions will be shared

We comply with:

  • APP 11 for security and data breach response
  • UK GDPR and EU GDPR breach notification requirements
  • HIPAA breach notification rules

15. Contact Information

Smarterblood

Email:

  • support@smarterblood.org

Changes to This Policy

We reserve the right to update this policy. Significant changes will be communicated via email, and continued use of the service will require acknowledgment of the updated policy.

Last Updated: April 10, 2025Version: 1.4