Babylon Privacy Policy

Last Updated: August 19, 2022

At Babylon Inc. (“Babylon”, “we”, or “us”), we respect your privacy and are thankful for your trust in us.

This Privacy Policy (“Policy”) explains what we do with the information we collect from you or about you when you access or use our website, app, or our technology products (such as Symptom Checker, Digital Care Plan, and MyHealth). It applies to the information we collect directly from or about you, or from our partner’s app or and/or website. Collectively, our website, app, and technology products, regardless of how they are accessed, are our “Services”.

We treat information collected through the Services as PHI that is subject to HIPAA if the information indicates that you are a Babylon patient or have completed the registration process to become a patient of Babylon. In contrast, this policy will apply to other information collected through the Services, including information indicating that you downloaded a Babylon app, clicked on a page to learn about Babylon services, or indicating that you began but did not complete the patient registration process.

If you do not agree with our policies and practices, please do not use the Services or provide us your information.

Babylon may link to other websites or services provided by unaffiliated third parties. Third-party websites or services do not fall under Babylon's privacy or security policies. We are not responsible for any third party’s collection of information and we encourage you to review their privacy and security policies before giving them any of your information.


This policy can be updated to show changes in our information practices or relevant laws. We may do this without giving notice to you. You can find the date of the most recent update at the beginning of this Policy where it says “Last Updated”.

A Note About Protected Health Information

You may be using the Services as a recipient of health care clinical services from us. If so, the protected health information (“PHI”) that we collect about you in the context of providing those Services is governed by the Health Insurance Portability and Accountability Act of 1996 (“HIPAA”), and other applicable state health information privacy laws, not this Policy.

Find more information on how we manage your PHI in our Notice of Privacy Practices (NOPP)

Find out more about HIPAA

Information We Collect

When you use the Services, we may collect information about you directly from you, automatically through your use of the Services, from our partners and/or from third parties. The information that we collect about you depends on how you interact with us.

Information You Provide

We collect information you provide to us when you:

  • Use our Services (including Services we offer in our partner apps and websites)

  • Contact us

  • When you request information from or about our Services


For example, this can include:

Information we collect

Examples

Contact information:

full name; phone number; email address; physical address

Demographic information:

gender; date of birth

Health information:

symptoms; risk factors; medications; procedures and other health related information you enter in our app or web Services, including those Services (like our symptom checker) as part of our partner or customer’ applications

Payment information:

card details; when you have made a payment; records of previous payments

Other information:

registration date; contact history; username and password.

*If you make a payment to Babylon, your credit or debit card details are processed by a payment provider that follows strict data security industry standards. Babylon does not store any of your credit card information, and Babylon only keeps details of the transactions on its secure servers.

Information We Collect Automatically

When you use our app or website, we may collect location information unless you have disabled location services on your device.

We and partners working on our behalf may use log files, cookies (find out more about cookies), or other digital tracking technologies to collect the following information from the device you use to interact with our Services.

  • Device information, including IP address, device identifiers, and details about your web browser.

  • Analytical information, including details about your interaction with our website, app, and electronic newsletters. Device information may be attached and added to Analytical information. This information may include information collected from the Babylon app, obtained when you clicked on a link to learn more about our Services, or collected when you began the patient registration process.

  • Diagnostic information, including web traffic logs.

  • Advertising information, including special advertising and other unique identifiers that enable us or third parties working on our behalf to target advertisements to you and measure their performance. Please be aware that our advertising partners may collect information about you when you visit third-party websites or use third-party apps. They may use that information to better target advertisements to you on our behalf. Your protected health information is not used for these advertising services.

We also create records when you make purchases or otherwise interact with the Services including details of when you logged in to use the Services.

The following is a list of our partners who collect the information described above. Please follow the links to find out more information about the partner’s privacy practices.

Partner

Information Type Collected

Microsoft: Bing Ads; LinkedIn Ads

Analytical; Advertising

LinkedIn: LinkedIn Ads

Analytical; Advertising

Google: DoubleClick, Google Tag Manager, GA Audiences; DoubleClick Bid Manager, Google Dynamic Remarketing, GA Audiences

Analytical; Advertising

Facebook: Facebook Custom Audience

Analytical; Advertising

Optimizely

Analytical; Advertising

Drawbridge

Analytical; Advertising

YouTube

Analytical; Advertising

Tealium

Analytical; Advertising

Craft CMS

Analytical; Advertising

Information We Collect from Other Sources

We may obtain information from third parties and sources other than the Services, including:

  • Our sponsors and advertisers.

  • Advertising partners who collect information about the advertisements we place on third-party websites.

  • Companies that compile information about individuals from multiple sources.

  • Social media networks and other places where you choose to share information publicly.

  • Review or feedback websites.

We might also receive some information about you and your health from other apps, devices and Services. This will only happen if you've agreed to sharing that data with us; for example, if you decided to share information collected from a smartwatch with our app.

How we use and share your personal information

We use your information to:

  • Provide the Services and create personalized products and services that are unique and relevant to you. For example, we may use cookies to remember your login information so you don’t have to enter it again, or we may use the information you’ve provided with our artificial intelligence systems to help inform the information and services we provide you.

  • Improve our Services, including our artificial intelligence systems. This helps us deliver better healthcare to you and other Babylon users. We sometimes analyze your data and how you use our products to help us manage our business better. This could be things like fixing bugs in our app, understanding current user trends, how people use our Services, or working out what users might want in the future.

  • Communicate with you. For example, we may need to contact you if we have quality or safety concerns resulting from your use of our Services or if we have a suggestion on how you could make better use of our Services.

  • Comply with our legal obligations and to establish, exercise and defend legal claims, or enforce our Terms of Use.

  • Offer you recommendations and tailor the Services to your preferences.

  • Send you marketing communications, personalize the advertisements you see on third-party online properties, and measure the effectiveness of our advertising. We may share your information with business partners, online advertising partners, and social media platforms for this purpose.

  • Audit how you use our Services, for example to review the quality of results provided by our Services, for internal training, and to ensure our Services are safe.

We may combine information that we collect from or about you from multiple sources together. We may create aggregated or de-identified information from the information we collect from or about you and use it for any purpose.

We share your information with

  • Affiliates. Your information may be shared with affiliated companies, which are companies related by common ownership or control, such as companies that make their clinical or artificial intelligence services available through our app.

  • Partner Apps and Websites. If you are using our Service through a partner app or website, information relating to your use of the Service (such as your use of the Symptom Checker, Digital Care Plan, and MyHealth), may be shared with our partner. Also, when it's in your vital interests, we may need to share your information with our partner in order to protect you or give you the right care. We may share information with our partner to assess the effectiveness of our Service, fix bugs, or analyze trends.

  • Service Providers. We engage vendors to perform specific business functions on our behalf, and they may receive information about you from us or collect it directly. These vendors are obligated by contract to use information that we share only for the purpose of providing these business functions, which include:
    • Supporting Service functionality, such as vendors that support customer service and customer relationship management, application development, and communications (e.g. via email).

    • Auditing and accounting firms, such as firms that assist us in the creation of our financial records.

    • Professional services consultants, such as firms that perform analytics, assist with improving our business, provide legal services, or supply project-based resources and assistance.

    • Analytics and marketing services, including entities that analyze traffic on our online properties and assist with identifying and communicating with potential customers.

    • Security vendors, such as entities that assist with security incident verification and response, service notifications, and fraud prevention.

    • Information technology vendors, such as entities that assist with website design, hosting and maintenance, data and software storage, and network operation.

    • Marketing vendors, such as entities that support distribution of marketing emails.

  • Online Advertising Partners. We partner with companies that assist us in advertising our Services, including partners that use cookies and online tracking technologies to collect information to personalize, retarget, and measure the effectiveness of advertising.

  • Social Media Platforms. If you interact with us on social media platforms, the platform may be able to collect information about you and your interaction with us. If you interact with social media objects on our Services (for example, by clicking on a Facebook “like” button), both the platform and your connections on the platform may be able to view that activity. To control this sharing of information, please review the privacy policy of the relevant social media platform.

  • Other Businesses in a Transaction or Merger. We may transfer your information to another company if any of the following events happen:

    • Another company buys or merges with Babylon

    • We sell, liquidate, or transfer our assets, such as in the unlikely event of bankruptcy

  • To Comply with Law. We share your information if we believe doing so is necessary or for legal reasons, for example:

    • If we are required by law, regulation, legal process, court order, or subpoena

    • In response to requests by government agencies (like law enforcement)

    • If we think releasing information will protect against physical, financial, or other harm, injury or loss of property

    • In connection with an investigation of suspected or actual unlawful activity

  • With Your Consent. We share your information with your consent or at your direction

Some of the information we collect may be shared with others in a way that does not identify you. We may combine this information and use it to create statistics or other information. We do not sell or share your information with third parties for their own marketing purposes.

If we intend to use or share information that we collected in a materially different way than what we described above, we will ask for your permission.

Your Choices and Rights Regarding Your Information

Your Account: Please use the options available in our app to update your account information.

Email Unsubscribe: If you do not wish to receive marketing information from us or wish to opt out of future email promotions from us, please contact us. Please note that all promotional email messages you receive from us will include an option to opt out of future email communications.

Ad Choices: You have options to limit the information that we and our partners collect for online advertising purposes.

  • You may disable cookies in your browser or mobile device using their settings menus. Your mobile device may give you the option to disable advertising functionality. Because we use cookies to support Service functionality, disabling cookies may also disable some elements of our website.

  • The following industry organizations offer opt-out choices for companies that participate in them: the Network Advertising Initiative, the Digital Advertising Alliance, and the European Interactive Digital Advertising Initiative.

  • You may use our cookie settings menu link on the Babylon home page.

  • You may contact us directly.

If you exercise these options, please be aware that you may still see advertising, but it will not be personalized. Nor will exercising these options prevent other companies from displaying personalized ads to you.

If you delete your cookies, you may also delete your opt-out preferences.

Do Not Track: Your browser or device may include “Do Not Track” functionality. The information collection and disclosure practices and the choices that we provide to you will continue to operate as described in this privacy policy, whether a Do Not Track signal is received.

Jurisdiction-specific rights: You may have certain rights with respect to your information depending on your location or residency. We describe those rights below. Please contact us to exercise your rights.

How We Store and Protect Your Information

We take care to keep information we collect and maintain secure, complete, and accurate. This includes:

  • Encryption of your data when it's stored in secure facilities

  • Encrypt your data in transit where possible

  • Using strict access controls to personal data in our care

Please be aware that no security measures are perfect or impenetrable. We can't guarantee that information about you will not be accessed, viewed, disclosed, altered, or destroyed if the safety steps we use to protect information are broken. Babylon can't guarantee security of networks that we do not control. This includes the internet, and any wireless networks in which information may be transferred to Babylon.

Children's privacy

We don’t knowingly collect information online from children under the age of 16. If we find someone submitting information to our Services is under the age of 16, we will delete any information collected as soon as possible.

We may collect medical information about children from their parents in certain circumstances. Please see our Notice of Privacy Practices for more information about how we process protected health information, including children’s health information.

International users

Babylon Services are for users located within the United States. If you, as a U.S. person, choose to use the Services from outside the U.S, you may also be transferring your information outside the U.S. This means that the laws around data collection may be different from U.S. laws.

We may support our corporate customers located outside the U.S. and in doing so access the personal information of individuals in those customers’ jurisdictions. We may transfer your information from the U.S. to other countries or regions to support our Services.

If you are accessing Babylon’s website or Services from outside of the U.S., please be aware that your information is being transferred to Babylon in the U.S.

How to Contact Us and How We Verify Your Requests

Contact: Please contact us at us-privacy@babylonhealth.com or by calling us at 1-800-650-9383 for any of the following reasons:

  • Questions or comments about this privacy policy or our privacy practices

  • If you want to exercise your rights or choices

  • Our privacy practices or if you would like to exercise your rights and choices

Making Requests to Exercise Rights:

  • Submitting requests: You may request to exercise your rights by submitting the form from the link here or on Babylon’s home page or making a request using the contact information above.

If you are a California resident, you may authorize another individual or a business registered with the California Secretary of State, called an authorized agent, to make requests on your behalf.

We may have a reason under the law why we do not have to comply with your request, or why we may comply with it in a more limited way than you anticipated. If we do, we will explain that to you in our response.

  • Verification: We must verify your identity before responding to your request. We verify your identity by asking you to provide personal identifiers that we can match against information we may have collected from you previously. We may need to follow up with you to request more information to verify identity.

We will not use information we collect in connection with verifying or responding to your request for any purpose other than responding to your request.

Product-Specific Disclosures

Babylon Cloud Services (“BCS”)

BCS is a digital platform that offers Babylon’s organizational clients the ability to import health information about their employees or constituents from third-party sources, give individuals access to Symptom Checker and other Services, navigate members to the right care, make preventative clinical interventions, provide members with 24/7 health information, and more.

Babylon offers BCS to its organizational clients. For example, a grocery store chain could contract with Babylon to deploy BCS in its stores, which would enable shoppers to use services like Symptom Checker and other Services. In this context, Babylon may collect information about its clients’ employees to facilitate the BCS services. Those clients may also give Babylon access to information about their end-users. (In the grocery store example, end-users would be shoppers.) In both cases, Babylon collects, uses, stores, and discloses information consistent with this Policy and the contracts Babylon may have with its organizational clients.

Jurisdiction-Specific Disclosures

The CCPA requires that we make certain disclosures about our general collection, use, and disclosure of personal information over the past 12 months. Accordingly, in the past 12 months:

  • We have collected the following categories of personal information: your direct identifiers, commercial information, medical information, and internet and other electronic/network activity information. From this information we may also draw inferences that reflect your preferences. Examples of the types of personal information, the sources of this information, and the purposes for which we have collected it are detailed in the “Personal Information We Collect” and the “How We Use and Share Your Personal Information” sections above.

  • We disclosed the following categories of personal information to the categories of entities described in the “How We Use and Share Your Personal Information” section: your direct identifiers, commercial information, medical information, internet and other electronic network activity information, and inferences we have made about you.

With some exceptions, you have the right to make the following requests with respect to the personal information we maintain about you:

  • Request to know: You have the right to request to know: (i) the specific pieces of personal information we have collected about you; (ii) the categories of personal information we have collected about you in the past 12 months; (iii) the categories of sources from which that personal information was collected; (iv) the categories of your personal information that we have sold or disclosed in the past 12 months; (v) the categories of third parties to whom your personal information was sold or disclosed in the past 12 months; and (iv) the purposes for collecting and selling your personal information. You may exercise your right to request to know twice a year, free of charge.

  • Request to delete: You have the right to request that we delete the personal information we have collected from you. We may deny your request under certain circumstances, such as if we need to comply with our legal obligations or complete a transaction for which your personal information was collected or if the data is PHI protected by HIPAA. If we deny your request to delete, we will let you know why.

  • Request to opt out of sale: While we do not sell your personal information, if we were to do so, we will update this Policy and you have the right to request that we not sell your personal information.


If you exercise any of these rights, we will not discriminate against you in any way. If you exercise certain rights, understand that you may be unable to use or access certain features and services.

To make a request to know or a request to delete, contact us at us-privacy@babylonhealth.com. We will take steps to verify your identity before processing your request to know or request to delete. We will not fulfill your request unless you have provided sufficient information for us to reasonably verify you are the individual about whom we collected personal information. If you have an account with us, we will use our existing account authentication practices to verify your identity. If you do not have an account with us, we may request additional information about you so that we can verify your identity.

You may use an authorized agent to submit a request to know or a request to delete. When we verify your agent’s request, we may verify both your and your agent’s identity and request a signed document from you that authorizes your agent to make the request on your behalf. To protect your personal information, we reserve the right to deny a request from an agent that does not submit proof that they have been authorized by you to act on your behalf.

California

California residents have additional privacy rights under the California Consumer Privacy Act (“CCPA”) and the Shine the Light law. To exercise your rights, you will need to follow the directions that are specific to each law. Please note that certain information, such as PHI and medical information (as defined under the Confidentiality of Medical Information Act (“CMIA”)), may be exempted from the California Consumer Privacy Act. This means that we and certain service providers or other recipients may not be required to honor the rights described in this section and instead we comply with our obligations under other laws, such as HIPAA and CMIA.

California Consumer Privacy Act

The California Consumer Privacy Act (“CCPA”) provides California residents with rights to receive certain disclosures regarding the collection, use, and disclosure of information about them, as well as rights to know/access, delete, and limit disclosure of personal information. You have the right to be free from discrimination based on your exercise of your CCPA rights. To the extent that we collect personal information that is subject to the CCPA, that information, our practices, and your rights are described below.

Notice at Collection Regarding the Categories of Personal Information Collected

You have the right to receive notice of the categories of personal information we collect and the purposes for which we use personal information. The following table summarizes the categories of personal information we collect, the categories of sources of that information, and whether we disclose or sell that information to service providers or third parties, respectively. The categories we use to describe personal information are those enumerated in the CCPA. We collect this personal information for the purposes described in “How We Use and Share Information.”

Category

Information Type

Source

We disclose to:

We sell to:

Identifiers

  • Contact information or personal characteristics (name; email address; postal address; telephone number; signature)

  • Social media handles

You; our social media pages

Service Providers

None

Health Information

  • Protected health information

  • Physical or mental status or ailments

You

Service Providers

Not sold

Financial Information

  • Payment card data

  • Credit information

You

Service Providers

Not sold

Protected Classifications and Other Sensitive Data

  • Date of Birth

  • Gender

You

Service Providers

Not sold

Commercial Information

  • Transaction information

  • Billing and payment records

  • Order history

You

Service Providers

Not sold

Geolocation Information

  • Precise (information that describes location with more precision than ZIP code, e.g., GPS data)

  • Coarse (information that describes location at ZIP code-level or less precision)

You; our analytics and advertising partners

Service Providers

Advertising partners (coarse location only)

Internet or Electronic Network Activity Information

  • IP address

  • Device identifier (e.g., MAC)

  • Advertising identifier (e.g., IDFA, AAID)

  • Information provided in URL string (e.g., search keywords)

  • Cookie or tracking pixel information

  • Information about your interaction with our website, app, email correspondence, or products

  • Browsing history

  • Search history

  • Diagnostic information (e.g., crash logs, performance data)

You; our analytics and advertising partners

Service Providers

Advertising partners

Audio, Electronic, Visual, Thermal, Olfactory, or Similar Information

  • Call recordings

  • Photographs

  • Video

You

Service Providers

Not sold

Professional or Employment-Related Information

  • Current employer

  • Job title

You

Service Providers

Not sold

Education Information

  • Education history

  • Level of education

You

Service Providers

Not sold

Inferences Drawn About You

  • User profile reflecting preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes

You; our analytics and advertising partners

Service Providers

Advertising partners

Content of Communications

  • Contents of phone calls, emails, or text messages

  • Contents of reviews or feedback provided on third-party websites

You; third-party websites

Service Providers

Not sold

Contacts

  • List of contacts that you supply to us

  • List of contacts we collect from your device with your permission

You

Service Providers

None

Entities to whom we disclose information for business purposes are service providers, which are companies that we engage to conduct activities on our behalf. We restrict service providers from using personal information for any purpose that is not related to our engagement.

Entities to whom we “sell” information are third parties. Under the CCPA, a business “sells” personal information when it discloses personal information to a company for monetary or other benefit. A company may be considered a third party either because we disclose personal information to the company for something other than an enumerated business purpose under California law, or because its contract does not restrict it from using personal information for purposes unrelated to the service it provides to us. Please note that it is not a “sale” if Babylon obtains your permission or direction to disclose data to a third party.

Your Rights under the CCPA

With some exceptions, you have the right to make the following requests with respect to the personal information we maintain about you:

  • Request to know: You have the right to request to know: (i) the specific pieces of personal information we have collected about you; (ii) the categories of personal information we have collected about you in the past 12 months; (iii) the categories of sources from which that personal information was collected; (iv) the categories of your personal information that we have sold or disclosed in the past 12 months; (v) the categories of third parties to whom your personal information was sold or disclosed in the past 12 months; and (iv) the purposes for collecting and selling your personal information. You may exercise your right to request to know twice a year, free of charge.

  • Request to delete: You have the right to request that we delete the personal information we have collected from you. We may deny your request under certain circumstances, such as if we need to comply with our legal obligations or complete a transaction for which your personal information was collected or if the data is PHI protected by HIPAA. If we deny your request to delete, we will let you know why.

  • Request to opt out of sale: You have the right to opt out of our sale of your personal information to third parties. To exercise this right, please visit our Do Not Sell My Personal Information link here or on Babylon’s homepage or contact us. Please be aware that your right to opt out does not apply to our disclosure of personal information to service providers.

If you exercise any of these rights, we will not discriminate against you in any way. If you choose to delete your information, understand that you may be unable to use or access certain features and services.

Shine the Light

California residents may also request information from us once per calendar year about any personal information shared with third parties for their own direct marketing purposes, including the categories of information and the names and addresses of those businesses with which we have shared such information. To request this information, please contact us at us-privacy@babylonhealth.com. Your inquiry must specify “California Privacy Rights Request” in the subject line of the email, and you must include your name, street address, city, state, and ZIP code.

Nevada

Residents of the State of Nevada have the right to opt out of the sale of certain pieces of their information to third parties. Currently, we do not engage in such sales. If you are a Nevada resident and would like more information about our data sharing practices, please contact us.