Babylon Privacy Policy

Last Updated: 6/18/21

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 personal information we collect from you or about you when you access or use our website or app (together, the “Services”).

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

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

Personal Information We Collect

When you use the Services, we may collect personal information about you directly from you, automatically through your use of the Services and from third parties. As used in this Policy, “personal information” is information that can be associated with or used to identify you. The personal information that we collect about you depends on how you interact with us.

Personal Information You Provide

We collect personal information you provide to us when you:

  • Use our Services
  • Contact our team
  • When you request information from or about our services

Information we collect

Examples

Contact information:

full name; phone number; email address

Demographic information:

gender; age

Health information:

symptoms; risk factors; medications; procedures and other health related information you enter in our app

Payment information:

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

Other information:

registration date; contact history; username and password.

Personal Information We Collect Automatically

When you use our website or app, we may collect the following personal information if your phone or internet browser settings let us:

Device and usage information, such as:

  • IP address
  • Mobile operating system version (i.e. Apple iOS)
  • Unique device identifiers like numbers or codes set by the device
  • Settings and preferences

Online activity, such as:

  • Time spent browsing our content
  • Dates and times you visited
  • Information provided by cookies, web beacons and other internet technologies.

We collect this information through the use of cookies and other tracking technologies. For more information about cookies, please see the “Cookies and Other Data Collection Technologies” section.

Geolocation information:

  • Some devices share your location. You can turn this off in your device settings.

Other Personal Information We Collect

We may obtain information from third parties and sources other than the Services, such as from our sponsors and advertisers.

How we use and share your personal information

We use your personal information to:

  • Provide the Services and create personalized products and services that are unique and relevant to you. For example, we may use your information to remember who you are so you don’t have to enter it again.
  • We also use your personal information to analyze how people use our services, and try to understand what they like about our services.
  • We may use your personal information to communicate with you or to send you marketing promotions and advertising.
  • We may use your personal information as necessary to comply with our legal obligations and to establish, exercise and defend legal claims or enforce our Terms of Use.
  • Sometimes we combine personal information about you from different sources. We might use this information to make guesses about you. We do this to make our products better and to make sure we send you info we think you will be interested in getting.

We share your personal information in the following circumstances:

  • Your personal information may be shared with affiliated companies. This means companies related by common ownership or control. These may be companies that make their clinical services available through our app.
  • We work with third-party services that provide technical support like development, hosting, and other services. They may have access to or may use personal information we have collected to help provide our services.
  • Your personal information may be transferred to advisors, a business partner, or others 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
  • 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.
  • We share your personal 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 use or share your data differently than we have listed above, we will ask your permission when we collect the personal information.

Cookies and Other Data Collection Technologies

Cookies are information that your browser stores when you access the internet. Cookies help:

  • Make your experience more personal to you
  • Make sure your services aren't interrupted
  • Collect device information about your computer

Find out more about cookies

Web beacons are small bits of code. They are stored in web pages, ads, and e-mails that communicate with third-parties. We may use web beacons to:

  • Count the number of users who have visited a website
  • Deliver or communicate cookies
  • Understand the way people use or interact with us and our Services

Our website and apps may use flash cookies, which are stored on your device or other types of local storage. Other types of local storage can be browser-based or plugin-based. These can be used to store information about your activity and preferences across different services and sessions. Please note that you may not be able to control them using standard browser tools and settings.

Third-party Services

Babylon may link to other websites or services provided by 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 personal information and we encourage you to review their privacy and security policies before giving them any of your personal information.

Third-party Advertising, Links And Content

We allow third-parties like the following to collect your personal information:

  • Business partners
  • Advertising networks
  • Other advertising services

They may do this through cookies, web beacons, or other types of technologies. This information can be taken and mixed with other personal information across different online services.

For example, Babylon uses a service called Braze technology to track your use of services and collect information about your usage. Braze tracks:

  • When you used the services for the first time
  • When you last used the services
  • How many times you used the service

See what kind of information Braze saves about your usage

These third parties may use the personal information to advertise in services or anywhere else. They can also tailor ads to your interests. If you don't want to receive these advertisements, you can opt-out in your device settings.

These companies may take part in programs that can provide you with the choice of receiving advertisements or not. To find out more, visit: Network Advertising Initiative and Digital Advertising Alliance

Your choices and rights

You can choose not to share certain personal information with us, in which case we may not be able to give you some features and functionality. If you wish to exercise any legal rights, you may have to access or amend any personal info we have about you. You can contact us at us-privacy@babylonhealth.com.

How we hold and protect your information

We take care to keep personal 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 personal 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 personal information online from children under the age of 13. If we find someone submitting information to our services is under the age of 13, we will delete any information collected as soon as possible.

International users

Babylon services are for users located within the United States. If you choose to use the services from outside the U.S, you may also be transferring your personal information outside the U.S. This means that the laws around data collection may be different from U.S. laws. We may also transfer your personal information from the U.S. to other countries or regions. By giving any information on our services, including your personal information, you consent to these actions.

Changes to our privacy policy and practices

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”.

How to contact us

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

Notice To California Residents

Certain 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 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 have not sold any of your personal information.
  • 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 exception, 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. 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.

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.