Privacy Policies
Privacy Centre
Data Protection & Security
We take our responsibilities as custodians of your data very seriously. The tabs below explains what personal information we collect, how we use it and your rights with regards to this data.
Our Privacy Mission Statement
The UK General Data Protection Regulation (UK GDPR) sets out some of the important rules about how we treat your personal data. This sits alongside the UK Data Protection Act 2018 (DPA 2018). As we work in the healthcare sector, we are also guided by another set of principles, called the Caldicott Principles which are specifically designed to protect patient data in the UK.
We follow a ‘privacy by design and default’ approach to ensure that our systems and processes continue to meet or exceed the standards that are expected of us by both the UK data protection laws and the Caldicott Principles.
Privacy Notice
Introduction
Lifelight regards your privacy and the handling of your personal data with the utmost importance. This Privacy Notice details how we collect, use and securely store any personal data submitted to us through use of our website and Lifelight Application.
We are what is known as a ‘data controller’ for processing your personal data submitted to us through our website. For patient data submitted to us through use of our Lifelight Application Xim is what is known as the ‘data processor’ and not the ‘data controller.’
There is also an explanation of the various rights you can exercise as a data subject, as well as how you can exercise those rights.
The scope of this Privacy Notice applies to https://lifelight.ai/.
Who are we?
Xim Limited, creators of Lifelight (‘we’ or ‘us’ or ‘our’) gather and process your personal information in accordance with this privacy notice and in compliance with the relevant data protection laws. This notice provides you with the necessary information regarding your rights and our obligations, and explains how, why and when we process your personal data. We are registered as a ‘data controller’ – you can read more about our responsibilities by visiting the Information Commissioner’s Office website here. It should be noted from above that for patient data that is submitted through use of our Lifelight Application Xim is what is known as the ‘data processor’ and not the ‘data controller.’
Xim’s registered office is: The University of Southampton Science Park, 2 Venture Road, Chilworth, Southampton, Hampshire SO16 7NP
We are a company registered in England and Wales under company number: 3699022
Our Information Commissioner’s Office (ICO) Registration number is: ZA24174
We act as the data controller when processing your data. The individual responsible for data protection is Claire Robinson who can be contacted at: The University of Southampton Science Park, 2 Venture Road, Chilworth, Southampton, Hampshire SO16 7NP.
What types of information do we collect?
Xim Limited processes your personal information to meet our legal, statutory and contractual obligations and to provide you with our products and services. We collect information that you give us to process your enquiry and to better understand how our services are used. We’ve outlined the main types of information that we handle below. We will never collect any unnecessary personal data from you and do not process your information in any way, other than as specified in this notice.
Examples of the types of personal data that we collect are:
Name
Personal Email
Business Email
Mobile Telephone Number
Technical information from usage of our Apps
Example of data we DO NOT collect are:
Personally identifiable data from your device, including:
Still images
Video
Audio / sound
The data uploaded from your device and used to predict your vital signs contains only signals generated from light reflected by specific regions of your face during the time taken for the measurement, as well as your biometric data (age, sex, height).
Separate privacy policies will apply to clinical trials in accordance with the respective trial protocol.
How do we collect your information?
We collect your information when you provide it to us through the website contact form or when you communicate with us in other ways. Whenever you subscribe to our newsletter or fill out a form, we may also collect and process data in order to carry out any services you use.
Cookies
Our site uses “cookie” technology to enhance your user experience. A cookie is a small piece of text stored by your browser on your computer, at the request of our server. Please refer to Lifelight’s cookie declaration for information about the cookies we use.
Change your consent
How we use your personal data (legal basis for processing)
Xim Limited takes your privacy very seriously and will never disclose, share or sell your data without your consent; unless required to do so by law. We only retain your data for as long as is necessary and for the purpose(s) specified in this notice. Where you have consented to us providing you with promotional offers and marketing, you are free to withdraw this consent at any time.
The purposes and reasons for processing your personal data are detailed below:
We collect your personal data in the performance of a contract or to provide a service and to ensure that we fulfil our obligations to you
We collect and store your personal data as part of our legal obligation for business accounting and tax purposes
Legitimate interests
We have a legitimate interest in improving our service for you, the user. In order to do this we collect behavioural information so we can see what actions you take within the app so we can continually improve the app’s usability and overall service for you.
Furthermore, this information is also used for auditing and ad hoc issue investigation.
You are entitled to receive more information about our legitimate interests on request. If you would like to receive more information please contact us using the details set out below.
Your data, your rights, your choices
At Xim, we want to make sure you find it easy to access and amend the data we hold about you. Subject to limitations, you can also make certain requests about that data. Please contact us using the details set out below if you wish to exercise your data rights, or contact the data protection regulator to find out more about them.
The right to be informed:
You have the right to be provided with clear, transparent and easily understandable information about how we use your information and your rights. This is why we’re providing you with the information in this Privacy Notice.
The right of access:
You have the right to obtain access to your information (if we’re processing it), and certain other information (similar to that provided in this Privacy Notice). This is so you’re aware and can check that we’re using your information in accordance with data protection law.
The right to rectification:
You are entitled to have your information corrected if it is inaccurate or incomplete.
The right to erasure:
This is also known as ‘the right to be forgotten’ and, in simple terms, enables you to request the deletion or removal of your information that we hold.
The right to restrict processing:
You have rights to ‘block’ or suppress further use of your information. When processing is restricted, we can still store your information, but will not use it further.
The right to object to processing:
You have the right to object to certain types of processing, including processing for direct marketing (i.e. receiving information about Xim’s products and services which may be of interest to you via email or post).
The right to data portability:
You have the right to obtain and reuse your information for your own purposes across different services. To our best ability we will provide your information in an easily accessible format.
The right to lodge a complaint:
You have the right to lodge a complaint about the way we handle or process your information with the national data protection regulator.
The right to withdraw consent:
If you have given your consent to anything we do with your information (i.e. we rely on consent as a legal basis for processing your information), you have the right to withdraw that consent at any time.
Please note that withdrawing your consent does not make unlawful what we have done with your personal data up to that point (when your consent was active).
If you believe that we hold any incomplete or inaccurate data about you, you have the right to ask us to correct and/or complete the information and we will strive to do so as quickly as possible; unless there is a valid reason for not doing so, at which point you will be notified.
You also have the right to request erasure of your personal data or to restrict processing (where applicable) in accordance with the data protection laws; as well as to object to any direct marketing from us. Where applicable, you have the right to data portability of your information and the right to be informed about any automated decision-making we may use.
If we receive a request from you to exercise any of the above rights, we may ask you to verify your identity before acting on the request; this is to ensure that your data is protected and kept secure.
Sharing and disclosing your personal information
Xim does not sell, trade or rent your information to third parties. We will share your information to service providers working on our behalf, or to meet certain other requirements, such as to comply with the law. We will never share your information with any third parties for marketing, advertising or any other purposes.
We may share your information externally to organisations which process data on our behalf. For example, we will need to share your address with Royal Mail to get information posted to you.
Please note that we are obliged to share information as necessary to comply with UK law and regulations. For example, we might need to share your information with regulators.
For further information about who your personal information is shared with, please get in contact with us using the details set out below.
Safeguarding Measures
Xim Limited takes your privacy seriously and takes every reasonable measure and precaution to protect and secure your personal data. We work hard to protect you and your information from unauthorised access, alteration, disclosure or destruction and have several layers of security measures in place, including: SSL, TLS, encryptions, pseudonymisation, restricted access, IT authentication, firewalls and anti-virus/malware.
Transfers outside the UK/EU
Given the worldwide nature of online communications and services, it is very common for users’ data on sites like ours to be transferred outside of the country in which it was collected. For example, the servers which host our sites could be located abroad. Where we transfer your data to countries outside of the UK and/or European Economic Area (“EEA”), we will only do so if measures to maintain to protect your data and its privacy have been put in place.
Whenever we transfer your personal data out of the EEA and/or the UK, 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 (in the case of transfers out of the EEA) or the UK Government (in the case of transfers out of the UK); and/or
where we use certain service providers, we may use specific contracts approved by the European Commission (in the case of transfers out of the EEA) and/or the UK Government (in the case of transfers out of the UK), in both cases which give personal data the same protection it has within the EEA and/or UK as applicable.
Legitimate Interests Assessment
As noted in the ‘How we use your personal data’ section of this notice, we occasionally process your personal information under the legitimate interests’ legal basis. Where this is the case, we have carried out a thorough Legitimate Interests’ Assessment (LIA) to ensure that we have weighed your interests and any risk posed to you against our own interests; ensuring that they are proportionate and appropriate.
How Long We Keep Your Data
Xim Limited only ever retains personal information for as long as is necessary and we have strict review and retention policies in place to meet these obligations. We are required under UK tax law to keep your basic personal data (name, address, contact details) for a minimum of 6 years after which time it will be destroyed.
Where you have consented to us using your details for direct marketing, we will keep such data until you notify us otherwise and/or withdraw your consent.
Special Categories Data
Owing to the products, services or treatments that we offer, Xim Limited sometimes needs to process sensitive personal information (known as special category data) about you. Where we collect such information, we will only request and process the minimum necessary for the specified purpose and identify a compliant legal basis for doing so.
Where we rely on your consent for processing special category data, we will obtain your explicit consent. You can modify or withdraw consent at any time, which we will act on immediately, unless there is a legitimate or legal reason for not doing so.
Patient data is considered to be a special category of data under the UK Data Protection Act which enacts the UK GDPR and is processed under section 6(1)(c) “necessary for compliance with a legal obligation to which the controller is subject” and 9(2)(h) “(h) processing is necessary for the purposes of preventive or occupational medicine, for the assessment of the working capacity of the employee, medical diagnosis, the provision of health or social care or treatment or the management of health or social care systems and services on the basis of Union or member State law pursuant to contract with a health professional and subject to the conditions and safeguards referred to in paragraph 3;”.
Giving your explicit consent for us to process your data does not affect your rights. Details of your rights and our data retention periods are further explained below in this Privacy Notice. It should be noted that for patient’s data Xim is the processor and not the controller. Any queries in relation to patient data should be addressed to the hospitals/trusts as they remain the controllers of patient data.
For all individuals, users and non-user contacts we rely on separate, explicit consent for direct marketing. You may withdraw your consent for further processing, fully or for specific purposes at any time by emailing info@lifelight.ai
It is important to note that this may affect the services we are able to offer you, and we may need to continue to process data relating to your request to withdraw consent.
National Data Opt-out
Information about your health and care helps the NHS to improve your individual care, speed up diagnosis, plan your local services and research new treatments.
The NHS, local authorities, university and hospital researchers, medical colleges and pharmaceutical companies researching new treatments can use your confidential patient information for research and planning. You can choose whether your confidential patient information is used for research and planning and you can change your choice at any time.
You do not need to do anything if you are happy about how your confidential patient information is used. If you do not want your confidential patient information to be used for research and planning, you can choose to opt out securely online or through a telephone service.
Xim Limited expects its Data controllers (Trusts, GP’s etc.), whether solely or jointly with another organisation, to be responsible for ensuring that national data opt-outs are applied in line with the policy.
In some cases, this requires the Controller to instruct Xim Limited (acting as a data processor under their instruction) to apply the national data opt-out.
In line with wider legal requirements, a data processor (Xim Limited) will comply with written instructions from the data controller in relation to the national data opt-out.
Lodging a Complaint
Xim Limited only processes your personal information in compliance with this privacy notice and in accordance with the relevant data protection laws. If, however, you wish to raise a complaint regarding the processing of your personal data or are unsatisfied with how we have handled your information, you have the right to lodge a complaint with the supervisory authority.
Xim Limited – Data Protection Officer – Claire Robinson – Email: dpo@lifelight.ai
Information Commissioners Office (ICO) – ICO Head Office: Wycliffe House, Water Lane, Wilmslow,
Cheshire SK9 5AF
Tel: 0303 123 1113 (local rate) or 01625 545 745 if you prefer to use a national rate number.
Visit: https://ico.org.uk/make-a-complaint
Subject Access Requests
Under data protection law, including the General Data Protection Regulation, you have a right to access your personal data and supplementary information held by Xim Limited.
This includes a right to be made aware of the ways and lawful basis under which your personal data is processed.
Requests for this information are known as Subject Access Requests, and we must respond to such requests within 30 days of a request being made and your identity confirmed.
To help us to verify your identity and process your request as quickly as possible, please provide us with as much of the following:
Your full name and contact details
The email address associated with your Xim account (if applicable)
Any information that may help us to verify your identity and account
Details of the information you require including any relevant time frames or media
Please send this information via email with the subject title “Subject Access Request” to dpo@lifelight.ai or by post to
Xim Limited, The University of Southampton Science Park, 2 Venture Road, Chilworth, Southampton, Hampshire SO16 7NP
Product images shown on our website are for illustrative purposes only and not an exact representation of the product.
Lifelight is compatible with a range of validated mobile devices. Please contact us for a complete list.
