Environmental, Social & Governance / Privacy Notice

Privacy Notice

Last updated: August 14, 2024

Global Privacy Policy

This privacy policy governs the collection, storage, use of personal information collected by us, OPEN Health Communications LLP (“OPEN Health”). It provides details about the personal information that we collect from you, how we use your personal information, and your rights regarding the personal information that we hold about you. Please read this privacy policy carefully – by using our services, you confirm that you have read, understood, and agree to this privacy policy in its entirety. Note: Specific sections for China(Personal Information Protection Law Specific Processing) and California(Disclosures under the California Consumer Privacy Act of 2018) can be found below.

Who is OPEN Health?

OPEN Health Communications LLP (whose registered address is at C/O Corporation Service Company (UK) Limited, 5 Churchill Place, 10th Floor, London, E14 5HU, United Kingdom and registered number OC360224) together with its subsidiary entities (details available here) operate in the healthcare and digital sector providing communications, market access, consultancy, public relations, meetings and events, medical education, data analytics, and health economic modelling services.

Data Controller

OPEN Health is made up of different legal entities, details of which can be found here: https://www.openhealthgroup.com/statutory-details. This privacy policy is issued on behalf of the OPEN Health Group, so when we mention “OPEN Health” “we,” “us,” or “our” in this privacy policy, we are referring to the relevant company in the OPEN Health Group responsible for processing your data. OPEN Health Communications LLP is the controller and responsible for this website.

Data Processor

OPEN Health also conducts data processing activities on behalf of its clients who will be the data controller for such activities. Where OPEN Health is a data processor, we may only process personal data in accordance with the controller’s documented instructions as set out in a data processing agreement or contractual arrangements. We may only transfer personal data out of the EEA and appoint sub-processors as permitted by the data processing agreement. OPEN Health is also given data sets for the purposes of research in a pseudonymised format which means the data subject will not be identifiable to OPEN Health because we have no access to the code that will re-identify the data.

Children

This website does not target and is not intended for children under the age of thirteen (13). OPEN Health does not knowingly solicit information from children under the age of thirteen (13). If you become aware that a child under the age of thirteen (13) has made use of our website or services, please make use aware by reporting to us using the contact details in the section below.

Contact us

If you have any questions about this privacy policy, including any requests to exercise your legal rights, please email us at dataprivacy@openhealthgroup.com. Please note that this email address is not intended or designed for any other communications.

United Kingdom address:
20 Old Bailey, 5th floor,
London, EC4M 7AN,United Kingdom

Europe address:
Marten Meesweg 107
Rotterdam, NL 3068 AV
Netherlands

United States address:
25 Recreation Park Drive, Suite 200
Hingham, MA 02043

China address:
上海市黄浦区西藏南路 569 号 Spaces 252 室 Spaces Base Fuxing
Room 252 569 South Xi Zang Road, Huangpu District Shanghai
China 20021

India address:
Zenia Building Hiranandani Circle
Hiranandani Business Park
Thane, Maharashtra 400607
India

You have the right to make a complaint at any time

You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO; the UK regulator for data protection issues; www.ico.org.uk) if you are based in the UK. If you are based in Europe, you have the right to make a complaint at any time to the Dutch DPA, who we have nominated as our lead data-protection authority (https://autoriteitpersoonsgegevens.nl). We would, however, appreciate the chance to deal with your concerns before you approach the ICO or the Dutch DPA, so please contact us directly at dataprivacy@openhealthgroup.com in the first instance.

External links

This website may include links to external websites, plug-ins, and applications. Clicking on those links or enabling those connections may allow other parties to collect or share data about you. We do not control these external websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy policy of every website you visit.

Changes to this Privacy Notice

We keep our privacy notice under regular review. This version was last updated on August 22, 2022.

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.

How is your personal data collected?

We use different methods to collect data from and about you, which may not always be collected directly from you, including through:

Direct interactions. You may give us your identity data, contact data, and financial data by filling in forms or by corresponding with us by post, telephone, email, or otherwise. This includes personal data you provide when you do any of the following:

Meet us at an event
Take part in research either online, through video conferencing, by phone, or face to face
Subscribe to publications and/or other marketing material
Take part in a campaign where you share your personal data and experiences
Approach and/or contract with us to perform services
Share your knowledge and expertise with us
Give us feedback
Contact us online in a networking or social media forum
Make an enquiry to our website
Send us your CV or biography
Contact us to request our services

Automated technologies or interactions. As you interact with our website, we may automatically collect technical data about your equipment, browsing actions, and patterns. This may also include your internet protocol (IP) address. We collect such personal data by using cookies, server logs, and other similar technologies. Please see our Cookie Policy for further details.

Third parties or publicly available sources. We may receive personal data about you indirectly, from various third parties and publicly available sources including those below:

Analytics providers
Registers of information – e.g. Specialist Information, Getty Images, Shutterstock, iStock
Search information providers such as Google, Chrome
Social media sites
Identity and contact data from publicly availably sources such as Companies House and the Electoral Register, British Medical Association, Association of the British Pharmaceutical Industry, Health Research Authority, National Institute for Health Research, and similar international organisations, if applicable
Medical journals and conference organisers
Partner institutions and our clients
Healthcare provider organisations
Agents and recruitment consultants
Suppliers
Third-party data collection specialists – e.g. BrandWatch
Contego Solutions Limited (trading as “Northrow”), a third party that provides us with compliance services
Technical data from the following:
- Our website hosting provider may collect your IP address; however, this information is anonymised so OPEN Health does not receive such data in a way that it can be personally identifiable and is therefore not personal data
- We generate log files about browsing patterns; this is statistical data which does not identify you as an individual
- This website uses Google Analytics, a web analytics service provided by Google, Inc. (“Google”); Google Analytics uses cookies to analyse how visitors use the website

Major Incidents and Health Emergencies. In circumstances where there is a virus or similar health and safety threat, to ensure the health and safety of all visitors, employees, or contractors, we may test your temperature by scanning individuals attending our offices with a thermal camera. No individual data will be retained or stored, but in line with our health and safety policy, if your temperature test indicates a higher-than-standard temperature, we may as a precaution ask you to leave or to retest for the protection of yourself and others in the interest of public health.

Healthcare Provider Organisations. As part of research studies conducted by OPEN Health on behalf of clients we collect from or are given pseudonymised patient data by Healthcare Provider Organisations for example hospitals, study sites, general practices. In these cases the data is not collected directly from the patient (Data Subject). OPEN Health does not hold the re-identification criteria or “key” to this personal data. Therefore OPEN Health is unable to confirm to any data subject whether they hold their personal data or from which Healthcare Provider Organisation from which it came.

Therefore, without the ability to re-identify the data subject OPEN Health is unable to provide a data protection notice directly to any of the data subjects held in these pseudonymised patient records and, as required by GDPR Article 14 OPEN Health shall take appropriate measures to protect the data subject’s rights and freedoms in respect to the data it holds. In these cases the original data protection notice issued to the data subject by the data controller will apply.

How we use your personal data

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

Where we need to perform a contract we are about to enter into or have entered into with you
Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests
Where we need to comply with a legal or regulatory obligation
Where it is in the public interest to do so

With your explicit consent (which you may withdraw at any time)

The personal data we may collect about you

Personal data means data which relate to a living individual who can be identified from those data, or from those data and other information which is in our possession, or is likely to come into our possession, and includes any expression of opinion about an individual and any indication of our intentions or the intentions of any other person in respect of the individual.

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

Identity data include first name, maiden name, last name, username or similar identifier, marital status, emergency contacts, title, date of birth, profession, and gender
Contact data include billing address, delivery address, email address, and telephone numbers
Educational and biographical data include information about your work history, job title, specialisms, qualifications, professional licence numbers for accredited bodies, progression, achievements, and extra-curricular activities
Financial data include bank account and payment card details
Transaction data include details about payments to and from you
Technical data include IP address, login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access our websites
Profile data include your interests, preferences, feedback, and any survey responses
Marketing and communications data include your preferences in receiving marketing and or newsletters from us and any communication preferences collected
Research data include any personal and or special categories of personal data including health data, genetic or biometric data, and data that relate to your sexual orientation or sex life that you have shared with us as a participant in a research study or survey or as part of our agreement with you; such data may exist in a pseudonymised form with a code and we may not know which individual the code relates to
Pseudonymised Data such as patient records not collected directly from a patient via a Healthcare Provider Organisation such as a hospital or doctor’s general practice. There is no way for Open Health to re-identify this data as the re-identification criteria or “key” always remains with the Healthcare Provider Organisation in these circumstances.
Aggregated data are statistical or demographic data for any purpose and may be derived from your personal data but are not considered personal data by law, as these data do not directly or indirectly reveal your identity
Subscription data include data collected from data agencies to whom you subscribe (e.g. Specialist Information)
Special categories of personal data include details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, health, and genetic and biometric data
Usage data include information about how you use our website.

If you fail to provide personal data

Where we need to collect personal data by law, or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (e.g. to provide you with goods or services). In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.

Purpose for which we will use your personal data

We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are, where appropriate.

Note that we may process your Personal Data for more than one lawful ground, depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the details below.

Legitimate interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law).

Performance of contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.

Comply with a legal or regulatory obligation means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.

Your relationship with Open Health	Purpose / Activity	Type of data	Lawful basis for processing including basis of legitimate interest	Who do we share it with?	How long will we keep it?
You are a specialist and/or medical expert including healthcare professionals, healthcare advisors and opinion leaders in the healthcare sector (as well as devices and diagnostic), and research investigators	To create and manage our relationship with you, including researching your credentials as a specialist in your area of expertise and making payments to you	Identity Contact Financial Educational and biographical Subscription	Performance of contractual obligations owed to you and to our clients Necessary for our legitimate business interests to (i) understand key healthcare specialists with whom we may wish to partner on behalf of our clients and (ii) understand and demonstrate expert knowledge of key healthcare issues to advance healthcare research and development with our clients Performance of (i) our legal and regulatory requirements and (ii) contractual obligations (e.g. making logistical arrangements for you or on your behalf and making honoraria payments to you on behalf of our clients)	Our clients Our banking partners Regulators including the ABPI, REC/IRB, HRA, EFPIA or EACCME Travel agencies and event management organisations	For 7 years following the end of our relationship with you unless we agree a different timeframe under contract with our client(s)
You are a site, partner or data collector working on behalf of a client or organisation	To create and manage our relationship with you including: Communicating with you to provide relevant access to data-collection systems and subsequent deactivation of access upon project completion Communicating with you regarding information you are inputting into our data-collection systems To identify who made changes to data held within data-collection systems	Identity Contact Usage	Performance of contractual obligations owed to you and to our clients Necessary to meet our legal obligation (to keep our records updated and gather feedback on performance)	Our clients OPEN Health Group companies	For 8 years following the research project end
You are a client or potential client (or an employee of the same)	To create and manage our relationship with you including: Communicating with you regarding services we are delivering on your behalf Notifying you about changes to our terms or privacy policy Requesting feedback from you on our performance Recommending goods or services that may be of interest to you Providing information that may be of interest to you relating to the pharma sector Arranging for payments to be made by you Allowing us to understand your role in your organisation	Identity Contact Educational and biographical Marketing and communications Financial	Performance of our contractual obligations owed to you Necessary to meet our legal obligation (to keep our records updated and gather feedback on performance) Necessary for our legitimate interests (to develop our products/services and grow our business)	Authorised subcontractors as set out in our contract with you Our potential investors OPEN Health Group companies Our external third parties and other similar providers	For 6 years following the termination of our contract(s) with you unless otherwise specified in our contract(s) with you
You are a supplier or potential supplier (or an employee of the same)	To create and manage our relationship with you including: Communicating with you regarding services you are providing to us To understand your role in your organisation Making payments Researching your credentials	Identity Contact Educational and biographical Financial	Performance of contractual obligations owed to you and to our clients Necessary for our legitimate interests (to develop our products/services and grow our business)	Our clients and potential clients	For 6 years following the termination of our contract(s) with you unless otherwise specified in our contract(s) with you
You are a journalist or freelancer working with us	To create and manage our relationship with you including making payments and researching your credentials	Identity Contact Financial Educational and biographical	Performance of a contract with you Necessary for our legitimate business interests (to develop our products/services and grow our business)	Our clients and potential clients	For the period of our agreement plus up to 7 years unless specified differently in our contracts
You are taking part in a survey or formal research project as a research participant	To facilitate your participation in the survey or formal research project	Identity Contact Educational and biographical Special categories of personal data (e.g. health data you have agreed for us to hold)	Performance of a contract with you Necessary for our legitimate interests to perform research in an area Necessary for a task carried out in the public interest Necessary for archiving in the public interest, scientific or historical research purposes, or statistical purposes (Article 89 GDPR) necessary for complying with a legal obligation Consent you have given us	As set out in our agreement with you but may include: Specified healthcare research organisations and identified healthcare providers, e.g. NHS The applicable regulators, e.g. in the UK, HRA, REC, IRB, ABPI, MHRA, BHBIA, and EFPIA Our clients	For a minimum period of 3 years unless otherwise specified in our agreement with you or specified by law
You are a company director of our client, supplier, or potential client or supplier	To create and manage our relationship with you	Identity	Necessary for our legitimate business interests to perform any reasonable compliance checks and anti-bribery and anti-corruption checks as part of supplier due diligence	OPEN Health Group companies including its parent companies and investors Potential investors in the OPEN Health Group External third parties (e.g. auditors and Northrow)	For 6 years following the termination of our contract(s) with you unless otherwise specified in our contract(s) with you
You are browsing our website	To ensure that you can navigate the website appropriately and have a positive user experience To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, and reporting and hosting of data) To deliver relevant website content and to measure or understand the effectiveness of the advertising we serve to you	Technical Usage	Necessary for our legitimate business interests to: Promote and develop services and grow our business Run our business, provide administration and IT services, ensure network security, and prevent fraud Study how customers use our products/services, to develop them, to grow our business, and to inform our marketing strategy To keep our website updated and relevant, to develop our business, and to inform our marketing strategy	Your IP address is recorded by Google Analytics and stored in our web server logs at Rackspace hosting in the UK	Due to the fact that we cannot identify users by their IP address and for the security and performance of our web services, we keep such data indefinitely
You register your request for us to send you information	To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you	Identity Contact Profile Usage Marketing and communications Technical	Necessary for our legitimate interests (to send you information requested, study how customers use our products/services, to develop them, to grow our business. and to inform our marketing strategy)	No one	12 months
You are a visitor at our local offices and/or sites	To protect the health and safety of all our staff and visitors	Contact Identity Temperature (where necessary as set out above in relation to major incidents and health emergencies)	Necessary for our legitimate interests for the protection of public health	Your temperature test results will not be shared Your contact and identity data will be shared with NHS Test and Trace where requested	Temperature test results will not be stored Contact and identity data will be kept for a minimum period of 21 days and no more than 12 months
You are a prospective employee seeking employment via prospective email or via an online application process	To create and manage our relationship with you: Within any recruitment or prospective recruitment process you may enter	Identity Contact Educational & work history (e.g. within a CV)	Performance of a contract with you Necessary for our legitimate business interests (to evaluate your suitability for a role which may or may not exist at the time of your contact)	OPEN Health Group companies including its parent companies External third parties (for managing your interest/application)	In accordance with our Recruitment Privacy Notice available here: https://www.openhealthgroup.com/recruitment-privacy-policy
You are a patient participating in a non-clinical research study where you may not know your data is being used in this capacity	To conduct analysis and research for the purpose of reporting outcome findings to a healthcare provider organisation	Pseudonymous patient data (non-identifiable to Open Health, e.g. NHS HES Data)	Performance of a contract with you. Necessary for our legitimate business interests	Reports which will not include pseudonymous patient data are provided to: Our clients Healthcare Provider Organisation(s)	For 8 years following the research project end

Direct Marketing

We may contact you to promote our services to you. We may obtain your personal data from third parties. This data may include your name, business email address, job title, employer details and your telephone number.
We will only contact you if we think our services are a good fit for your organisation.
When we contact you, we do so because it is in our legitimate interests to promote our services to individuals at organisations that we think may be interested in or would benefit from those services. You can object to us contacting you to promote our services by contacting us on details above under the “Contact Us” section.

Cookies

You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. For more information about the cookies we use, see our Cookie Policy.

The website does not respond to the Do Not Track (DNT) setting configured on the user’s web browser

Change of purpose

We will use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If we need to use your personal data for an unrelated purpose, if required, we will notify you and we will explain the legal basis which allows us to do so. Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law

Disclosures of your personal data

We may have to share your personal data with the third parties set out below as well as those set out in the table above. We require all third parties to respect the security of your personal data and to treat it in accordance with the law:

The following external third parties:

Key service providers who provide compliance, IT, and system administration services; these include Contego Solutions Limited (trading as “Northrow”) for compliance, Exponential-E Limited for IT services, UKFast.Net Ltd, Nimbus Hosting and Rackspace International GmbH for server administration services, Cisco WebEx, Microsoft Corporation (for Microsoft Applications including Teams and SharePoint), Zoom Video Communications, Inc., GoToWebinar and GoToMeeting for teleconferencing and webinar services, and recruitment software (JobAdder, ApplicantTracker, Workable)
Professional advisers including lawyers, bankers, auditors, and insurers who provide consultancy, banking, legal, insurance, and accounting services
HM Revenue & Customs, regulators, and other authorities based in the EEA or outside the EEA who require reporting of processing activities in certain circumstances including the public interest
Marketing and social media tracking providers, including Survey Monkey Inc., Smart Monkey Marketing Limited, and The Rocket Science Group LLC (trading as MailChimp), QuestionPro, Inc., and Brightcove, Inc. for marketing activities and Runtime Collective Limited (trading as Crimson Hexagon and/or Brandwatch) for social media tracking
Third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets; alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy notice

By providing us with your personal data you agree that OPEN Health may share personal data, on a confidential basis, to third-party individuals and organisations that assist us, including contractors, financial service providers, web hosts, and others as set out in the table and list above

International transfers

We may share your personal data within the OPEN Health Group. This may involve transferring your data outside the EEA or the UK.

For UK and EU personal data, whenever we transfer your personal data out of the EEA or the UK, we ensure a similar degree of protection is afforded by implementing at least one of the following safeguards:

We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data. For further details, see European Commission: Adequacy of the protection of Personal Data in non-EU countries.
Where we use certain service providers, we may use specific contracts approved by the European Commission and/or ICO as appropriate which give personal data the same protection it has in Europe. For further details, see European Commission: Model contracts for the transfer of Personal Data to third countries and International data transfer agreement and guidance. These contracts are often referred to as ‘Standard Contractual Clauses’ and ‘International Data Transfer Agreement’. We will also assess in-country standards as part of this process.

OPEN Health Group will implement further supplementary measures where possible and appropriate including technical, organisational, and contractual measures to augment the above-mentioned safeguards.

Post departure of the UK from the European Union, we will continue to take privacy of your data very seriously and manage your data according to the General Data Protection Regulations as they apply in the UK.

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

Data security

We have put in place risk-based controls to safeguard your personal data. In addition, we limit access to your personal data to those employees, agents, contractors, and other third parties who have a business need to know. If we share your personal data with our agents, contractors, and other third parties, we have minimum Privacy and Security requirements, which are available at https://www.openhealthgroup.com/privacy-security-requirements.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so

Data retention: how long we use your personal data

We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.

To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting, or other requirements. We are required by law to keep basic information about our customers (including contact, identity, financial and transaction data) for at least 6 years after they cease being customers for legal and tax-reporting purposes.

Details of retention periods for different aspects of your personal data are available in our retention policy, which you can request from us by contacting us at dataprivacy@openhealthgroup.com (a subset of which is set out in the table Purposes for which we will use your personal data above).

In some circumstances we will anonymise your personal data or aggregate it (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.

Artificial Intelligence

Artificial Intelligence “AI”: we use AI technologies to deliver benefits to Clients and ultimately the healthcare sector. Internally AI is used to drive efficiencies in line with our internal policies and procedures (including human oversight where applicable). Your data may be processed by providers of AI either directly sourced by us or via third party AI tools embedded in systems providing IT services to us. Any use of AI technologies by us will be in accordance with technical and operational safeguards appropriate for data types. OPEN Health utilise the AI development services of third parties including Fusion, Artefact, and Triradial, as well as AI platforms such as ELO AI, and Nested Knowledge with additional AI functionality utilised within existing platforms.

Automated technologies or interactions: as you interact with our website, we may automatically collect technical data about your equipment, browsing actions, and patterns. This may also include your internet protocol (IP) address. We collect such personal data by using cookies, server logs, and other similar technologies. Please see our Cookie Policy for further details.

Your legal rights

Under certain circumstances, you have rights under data-protection laws in relation to your personal data. Where we have not collected the data directly from you, you have similar rights which may require you to communicate your request to the data controller from which OPEN Health received the data (OPEN Health would not have the ability to identify you should your data reside within a pseudonymised data set). You have the right to:

Request access to your personal data (commonly known as a “data subject access request” or “data portability request” or “right to know”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise, or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.
Request for erasure or deletion of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully, or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts your fundamental rights and freedoms. You also have the right to object if we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which overrides your rights and freedoms.

Please contact us if you would like to exercise any of these rights. You can do this by sending an email to dataprivacy@openhealthgroup.com.

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive, or excessive. Alternatively, we may refuse to comply with your request in these circumstances.

For requests made under GDPR: We try to respond to all legitimate requests within 1 month. Occasionally it may take us longer than 1 month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

We will not discriminate against you for exercising any of the above rights.

Personal Information Protection Law (“PIPL”) Specific Processing

If you reside in the People’s Republic of China (“PRC”), this Privacy Policy applies as follows:

Open Health is the Personal Information Processing Entity for your personal data.

The trusted third parties with whom we share your Personal Data as described in the Privacy Policy are our Entrusted Parties for personal data. We enter into data processing agreements with any Entrusted Parties that we use in the provision of our Service to ensure that your personal data is handled in accordance with PIPL.

We only transfer your personal data outside of PRC to our Entrusted Parties with your explicit consent and where otherwise permitted by law to do so.

You have the following rights in respect of your personal data:

You have the right to know and decide upon Personal Data Processing.
You have the right of access to your Personal Data and can request copies of it and information about our processing of it.
If the Personal Data we hold about you is incorrect or incomplete, you can ask us to rectify or add to it.
You have the right to request that your Personal Data is deleted, in certain circumstances.
You have the right to object and have the right to restrict the use of your Personal Data in certain circumstances.
You have the right not to be subject to a decision based solely on automated processing.
You have the right to portability, subject to conditions stipulated by the Cyber space Administration of China
Where we are processing your Personal Data with your consent you can withdraw your consent at any time. If you withdraw your consent, we may not be able to provide you with access to certain specific functionalities of the Service.
You have the right to ask Entrusted Parties to explain their processing rules on data subjects’ requests.
The close relatives of a deceased data subject also have certain rights.
You can also raise a complaint with the data protection supervisory authority in the country in which you reside.
- To exercise your rights in respect of Personal Data you can contact us by sending an email to dataprivacy@openhealthgroup.com.

Disclosures under the California Consumer Privacy Act of 2018 (“CCPA”)

As required under the CCPA we have provided the metrics regarding the consumer rights requests we received from California residents from January 1, 2020 to December 31, 2021 in the following table:

Request Type	Received	Granted (in whole or in part)	Denied	Mean Days to Respond
Requests to Know	Nil	Nil	Nil	Nil
Requests to Delete	Nil	Nil	Nil	Nil

What we may need from you

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data are not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

Time limit to respond

For Californian residents: We will acknowledge receipt of your request within 10 days and begin the process of verifying your request. Depending upon the sensitivity of the data collected and the nature of your request, we are required to verify your identity by matching at least 2 pieces of personal information or, for more sensitive information, 3 pieces of personal information. If you use an authorized agent, we will require written evidence of the authorization and identity.