Privacy Policy

Effective date: 27 January 2025

Lifecycle Telehealth BV ("Lifecycle," "we," "us," or "our") operates a digital health access and technology platform that enables users to discover, connect with, and communicate with independent, licensed healthcare professionals. Lifecycle does not provide medical care, clinical services, or issue prescriptions.

This Privacy Policy explains how we collect, use, share, and protect personal data when you use the Lifecycle Telehealth digital health access platform, websites, applications, and related services (collectively, the "Platform").

1. Regulatory framework

We process personal data in accordance with:

• GDPR (EU Regulation 2016/679)
• UK GDPR and the Data Protection Act 2018
• Applicable national data-protection laws in jurisdictions where the Platform is accessed

Lifecycle operates as a technology provider and access platform. Medical services, clinical decisions, prescriptions, and treatment are provided solely by independent healthcare professionals, who act as separate data controllers under applicable law. Role Clarity: Lifecycle Telehealth acts as a data processor or technical intermediary in relation to clinical data processed by licensed healthcare providers. Licensed healthcare providers are the data controllers for clinical and health-related data processed through the platform. User account data is controlled by Lifecycle (controller or joint controller), while clinical data is controlled by Providers (controllers).

2. Information we collect

A. Information you provide

• Name, email address, phone number
• Account credentials
• Payment and subscription information
• Communications sent through the Platform
• Profile and onboarding information (for providers)

B. Information collected automatically

• IP address and device information
• Browser type and operating system
• Log files and usage data
• Cookies and similar technologies

C. Information from third parties

Payment confirmation from payment processors, Verification data for provider onboarding, Technical analytics and performance metrics. Lifecycle does not require users to submit medical information to create an account. Any health information shared during consultations is shared directly with healthcare professionals via secure infrastructure.

3. How we use information

• Operate and maintain the Platform
• Create and manage user accounts
• Enable secure communication and scheduling
• Process subscriptions and payments
• Provide customer support
• Improve performance, security, and usability
• Meet legal and regulatory obligations

Lifecycle does not use personal data to diagnose, treat, or provide medical advice.

4. Sharing of information

• Independent healthcare professionals, solely to enable communication initiated by the user
• Service providers (hosting, payment processing, analytics, customer support)
• Regulators or authorities, where legally required
• Corporate affiliates, subject to equivalent data-protection obligations
• Successor entities, in the event of a merger or acquisition

We do not sell personal data.

5. International data transfers

Where data is processed outside the EU or UK, we rely on:

• Adequacy decisions where available
• Standard Contractual Clauses (SCCs)
• Appropriate technical and organizational safeguards

6. Data retention

• Account data: retained while your account is active
• Subscription and billing data: retained as required by financial law
• Technical logs: retained for security and performance monitoring

Healthcare professionals are responsible for retention of medical records in accordance with their professional and legal obligations.

7. Security

We implement appropriate administrative, technical, and organizational measures, including encryption, access controls, and monitoring, to protect personal data. No system can guarantee absolute security.

8. Your rights

Depending on your jurisdiction, you may have the right to:

• Access your data
• Correct inaccurate data
• Request deletion
• Restrict or object to processing
• Data portability
• Withdraw consent where applicable

Requests can be made via: 📧 privacy@lifecycletelehealth.io

9. Cookies

• Enable core functionality
• Improve user experience
• Analyze Platform usage

You can manage cookies through your browser settings.

10. Children

The Platform is not intended for individuals under 18. Accounts for minors may only be created where permitted by law and facilitated by a parent, guardian, or healthcare professional.

11. Changes to this policy

We may update this Privacy Policy from time to time. The effective date will be updated accordingly. Material changes will be communicated where legally required.

12. Contact & accessibility

Lifecycle Telehealth BV

📧 privacy@lifecycletelehealth.io

We aim to meet WCAG 2.1 AA accessibility standards and welcome feedback on accessibility issues.