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HEALTHILY “GEN AI” MEDICAL CHATBOT TESTING PRIVACY POLICY
 

(June 2025)

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The “Gen AI” Medical Chatbot testing (the “Test”) is organised by Healthily Ltd, a company incorporated in England and Wales, with a registered number 8727263  and registered office address at 36 Egerton Road, Bournemouth BH8 9AY (“Healthily”), acting as controller in regard to your data.
 

How Healthily uses your data


Please remember that the purpose of the Test is not to get information about your health, but to get your feedback and gather information about your interactions with the ChatBot.
 

Healthily does not require that you provide your actual health data, and will not verify its true or false character. Please make sure you do not provide any personal information while interacting with the Chatbot or while completing the Survey. Your identification is not necessary to perform the Test, so please do not provide any information that may allow us to identify you.
 

Healthily will only process the data you agree to insert into the Chatbot, and only you decide how much information you want to share, knowing that OpenAI will have access to it. 
 

Legal basis. We process your data on a contract performance basis, and we are relying on consent when processing health data.
 

PURPOSES OF DATA PROCESSING
 
TO ENABLE YOU TO TEST THE CHATBOT
 

ChatBot data will be processed in a pseudonymised manner with the help of an identifier, which will change every time you visit the Chatbot. This means that Healthily will not be able to identify you directly or link different conversations to you. The information you provide will be used by the Chatbot to provide you with information you have enquired about.

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When interacting with the Chatbot, do not enter personally identifiable information, such as your full name, email address, or national identification numbers. 

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ChatBot data. Any information you enter when interacting with the Chatbot (e.g. questions asked), including health data (e.g. symptoms, health history, health condition, etc.), session ID (a unique identifier that changes whenever you visit the ChatBot).

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TO DEVELOP AND IMPROVE THE CHATBOT

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Healthily will collect Analytical data with the help of an identifier (session ID) and create reports by analysing Analytical data. Analytical data will be used for the purposes of development and improvement of the ChatBot. 

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Analytical data. With the help of the session ID assigned to your visit to the ChatBot, Healthily will analyse Activity data and Chatbot data to perform internal analytics and research for the purposes of development and improvement of the Chatbot. 

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Activity data. Information about how you use and interact with the ChatBot, for example, how many testers have initiated the conversation with the Chatbot, what type of questions were entered, how many testers have clicked on YES/NO button, and session duration.

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Survey data. Your survey responses. Healthily will use your responses to create aggregated reports about your Feedback and use this data for the development and improvement of the ChatBot.

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Your rights

 

As a data subject, you have the following rights:

 

  • to request information about the processing of your data, as well as to receive a copy of your personal data. Among other things, you may request information on the purposes of the processing, the categories of personal data processed, the recipients of the data (if a transfer is made), the duration of the storage or the criteria for determining the duration;

  • to receive personal data relating to you in a structured, common and machine-readable format or to transfer it to another person in charge;

  • to correct your data. If your personal data is incomplete, you have the right to complete the data, taking into account the purposes of the processing;

  • to have your data deleted or blocked;

  • to have the processing restricted;

  • to object to the processing of your data;

  • to revoke your consent to the processing of your data for the future; and

  • to complain to the responsible supervisory authority about unauthorised data processing.

 

You can exercise your rights by sending an email to  privacy@healthily.ai, with the subject: Testing session.

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Who has access to your data?

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Your data will be processed by Healthily employees and contractors and third-party service providers engaged by Healthily for the Testing Purpose: 

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Google BigQuery - hosting, analytical, and environment management services  owned by Google Cloud EMEA Limited, a company incorporated under the laws of Ireland, with its offices at 70 Sir John Rogerson’s Quay, Dublin 2, Ireland. Please read their Privacy Policy for more information. 

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Google Cloud Platform – hosting, analytical, and environment management services (Google Ireland Limited, with offices at Gordon House, Barrow Street, Dublin 4, Ireland); Please read their Privacy Policy for more information.

 

Tableau – analytical services (Tableau Software LLC, 1621 N 34th St., Seattle, Washington 98103); Please read their Privacy Policy for more information.

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OpenAI – LLM service provider (OpenAI Ireland Ltd.1st Floor, The Liffey Trust Centre 117-126, Sheriff Street, Upper, Dublin 1, Ireland, D01 YC43). Please note that we will only share with OpenAI information that you voluntarily provide to the chatbot. Please read their Privacy Policy for more info.

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Attest - consumer research platform (Attest Technologies Limited, 25 Worship Street, London, England, EC2A 2DX, UK). Please read their Privacy Policy for more info.

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Storing, Security and Data transfers

 

Storing. Healthily stores and analyses your data within Google BigQuery, owned by Google Cloud EMEA Limited, a company incorporated under the laws of Ireland, with its offices at 70 Sir John Rogerson’s Quay, Dublin 2, Ireland. For more information, please see Google Service Specific Terms.  

 

Healthily will store your data for as long as needed to perform the Testing Purpose.

 

Security. To safeguard your privacy, Healthily processes your data with the help of identifiers, namely session ID, to avoid personal identification. Healthily does not require that you provide your actual health data, and will not verify its true or false character. Please make sure you do not provide any personal information while interacting with the Chatbot or while completing the Survey. Your identification is not necessary to perform the Testing, so please do not provide any information that may allow us to identify you.

 

Healthily will only process the data you agree to insert into the ChatBot, and only you decide how much information you want to share, knowing that OpenAI will have access to it. 

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Transfers. Data is being transferred to countries outside the United Kingdom and the European Economic Area. Healthily only transfers personal data to third countries where the ICO and the EU Commission have confirmed an adequate level of protection or where we can ensure the careful handling of personal data by means of contractual agreements or other suitable guarantees, such as certifications or proven compliance with international security standards, which you can review on request.

 

General

 

Should you have any privacy-related questions, please contact Healthily at privacy@healthily.ai. If Healthily is not able to help, will forward your enquiry to our External Data Protection Officer (DPO), ePrivacy GmbH, represented by Prof. Dr. Christoph Bauer, Große Bleichen 21, 20354 Hamburg. Should you have any concerns or complaints that our DPO is not able to resolve, you have the right to lodge a complaint with our supervisory authority Der Hamburgische Beauftragte für Datenschutz und Informationsfreiheit, Kurt-Schumacher-Allee 4, 20097 Hamburg. If you are a UK customer, you can lodge a complaint with the Information Commissioner's Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF. Our EU Representative is ePrivacy Holding GmbH, Große Bleichen 21, 20354 Hamburg, Germany. For more information, click https://www.eprivacy.eu/en/legal.

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