Privacy Policy

1. Definitions

• Party Responsible for Processing Personal Data:

• Pouch Health (Ultrasound Link Ltd), with registered offices at Pouch Health, 36 Spital Square, E1 6DY, London, United Kingdom;

• Company Registration Number: 12147431;

• Data Protection Officer: Tom Ushakov, who can be reached at privacy@pouch.health (the “Controller”).

• Data Protection Authority:

The Information Commissioner’s Office (ICO), the data protection authority for the United Kingdom.

• Data Protection Laws:

• For residents of the European Union: The EU General Data Protection Regulation (GDPR) 2018 and the EU ePrivacy Directive 2002 (soon to be replaced by the EU ePrivacy Regulation).

• For residents of the United Kingdom: The UK GDPR 2020, the UK Data Protection Act 2018, and other applicable national laws.

2. What Information We Collect

2.1. Personal Information

Personal data refers to any information that relates to an identified or identifiable natural person (the “data subject”). An identifiable natural person is one who can be identified, directly or indirectly, by reference to identifiers such as:

• Name

• Location data

• Online identifier

• Or one or more factors specific to the physical, physiological, genetic, mental, economic, cultural, or social identity of that individual.  

We collect personal information to deliver better health services, including:

• Website: When you use our website, we may collect your name, email address, phone number, and mailing address.

• Mobile Application: When using the Pouch Health app, we collect your first name, last name, date of birth, gender, address, phone number, and email address.

• Medical Information: We collect your medical information when you use our Digital Pouch feature. This includes your medical history, prescriptions, and pregnancy-related health data.

2.2. Automatically Collected Information

We automatically collect data from your interactions with our website and app:

• Device Information: IP addresses, device identifiers, operating system data, and interaction logs.

• Cookies and Web Beacons: We use cookies to remember your preferences and improve your experience. You can manage cookie preferences through your browser settings.

At Pouch Health, we handle Electronic Health Records (EHRs) from two distinct user groups: patients of London Pregnancy Clinic (LPC) and general users of the Pouch Health app who are not part of the clinic. Each group has different options and controls over how their medical data is handled and shared.

2.3. Patients of London Pregnancy Clinic (LPC)

Patients who are part of LPC have their medical information collected and stored securely as part of their treatment. These records include consultation notes, test results, and other medical information.

• Data Sharing: By default, patients of LPC can share their EHRs with healthcare providers involved in their care, such as obstetricians, midwives, or other specialists. This is necessary to ensure coordinated, high-quality care.

• User Control: Patients may have the option to share their medical data with external providers or other third parties by request. However, Pouch Health and LPC will always ensure that such data is shared only when it is essential for care, or when the patient has explicitly consented to sharing.

2.4. General Users

General users of the Pouch Health app, who are not patients of LPC, can still create and store personal medical information within the app, such as pregnancy tracking, personal health records, and digital tools.

• Data Sharing: These users have full control over whether they share their records with third parties or external healthcare providers. While the app provides options to share data (e.g., with family members or other healthcare providers), Pouch Health does not require or encourage the sharing of this information unless explicitly requested by the user.

• No Automatic Sharing: For general app users, Pouch Health does not automatically share any health data with third parties or external systems unless the user opts to share the information. We respect your choice to keep your medical data private.

• Security of Shared Data: If users choose to share their records, we implement secure encryption and transmission processes to ensure that the shared data is handled safely and complies with all relevant data protection regulations.

2.5. Data Protection and Security

Regardless of whether you are a patient of LPC or a general Pouch Health app user, your personal health data is stored securely, and we comply with the highest standards of data protection, including GDPR. You remain in control of your personal information at all times.

• User Control: You can update your privacy settings within the app to manage your data-sharing preferences or contact us at privacy@pouchhealth.com for support.

• Right to Opt-Out: You have the right to opt-out of any data-sharing arrangements, ensuring your information remains confidential and under your control.

By ensuring transparency in our data collection and processing practices, Pouch Health is committed to protecting your privacy in compliance with the relevant Data Protection Laws.

For any queries about this Privacy Policy or your personal data rights, please contact our Data Protection Officer at privacy@pouchhealth.com.

3. Medical Record Retention (England Only)

Pouch Health adheres to national best practice guidelines for the retention of medical records in England, in accordance with the Department of Health Records Management (2006) and GDPR. These guidelines ensure that records are not retained for longer than necessary, respecting the principles of data minimisation.

We retain your personal and medical data according to the following retention schedules:

• Medical Records: Retained for 10 years after your last interaction or as required by law.

• Inactive Accounts: Personal data from inactive accounts will be deleted after two years unless otherwise requested.

3.1. Minimum Length of Retention for GP Records in England

• GP Records: Retain for 10 years after the patient’s death.

• Electronic Patient Records (EPR):

If the system has the capacity to destroy records in line with the retention schedule, and a metadata stub remains, this should be done in accordance with the NHS Code of Practice. If the system does not have this capacity, once records reach the end of their retention period, they should be made inaccessible to users upon decommissioning. A log of the destruction should be maintained.

3.2. Minimum Lengths of Retention for Hospital Records in England

• Maternity Records: Retain for 25 years after the birth of the last child.

This includes obstetric and midwifery records, including cases that end in stillbirth or where the child later dies.

• Mental Health Records: Retain for 20 years after the last contact or 10 years after the patient has died, whichever is sooner.

• All Other Hospital Records: Retain for 8 years after the conclusion of treatment or death.

These retention periods ensure that records are kept for the necessary duration to comply with clinical, legal, and regulatory requirements, while protecting patient privacy. If you have any questions about the retention of your records, please contact us at privacy@pouch.health.com.

4. Sharing Information with Your Partner

Pouch Health offers users the option to share certain information from their account with their partner. This feature is designed to support shared pregnancy experiences while ensuring that users remain in full control of what information is shared and with whom.

4.1. Control Over Information Sharing

As the main user, you have complete control over the sharing of your health data with your partner. You can initiate or stop sharing this information at any time directly within the app.

• Opt-in Feature: Information sharing with a partner is entirely optional. You must explicitly enable this feature to begin sharing specific data with your partner.

• Stop Sharing: At any point, you can choose to stop sharing your information by disabling the sharing feature in the app settings.

4.2. What Information Will Be Shared with Your Partner?

If you choose to share information with your partner, they will only have read-only access to the data you select for sharing. This means your partner can view the information but cannot edit or download it. Specifically:

• What Your Partner Can See:

• Pregnancy Updates: Your partner will receive regular updates on your pregnancy, including educational insights and notifications about important developmental milestones for your baby.

• Scans and Classes: Your partner can view your scan schedules and classes and, if you allow, book them on your behalf.

• If you choose to share:

• Electronic Health Records (EHRs): If you choose to share EHRs, your partner will have read-only access to this information.

• Symptoms or Feelings: Any symptoms, moods, or feelings you log in the app will not be shared with your partner.

• What Your Partner Won’t See:

• Interaction with Other Features: Features such as community chats or personal logs will remain confidential and inaccessible to your partner.

• Personal Notes: Your personal notes will remain private.

4.3. What Data is Collected from Your Partner?

To create a partner account and facilitate sharing, Pouch Health will collect a limited set of information from your partner. This data is used solely to set up their account and allow them to receive updates.

• Data Collected from the Partner:

• Name, phone and email address: To create an account and send notifications.

• Date of Birth: To verify that your partner meets the minimum age requirements for using the app.

• Biometric ID: Optional for extra security of Pouch Health app.

• Medical Conditions: Optional disclosure of pre-existing conditions to help push personalised content to users.

• Gender: While not directly collected, this may be inferred based on how your partner interacts with the app.

4.4. Important Disclaimer

Pouch Health does not share your partner’s data or health information unless explicitly enabled by them. You can manage your partner sharing settings directly from your account, and all shared information is encrypted and secure.

Consent and Control: You are in full control of the information shared with your partner, and all shared data can be managed through the app at any time.

How We Use Your Information

We use your personal information to:

• Provide and personalize our services, including pregnancy tracking and appointment scheduling.

• Manage bookings and consultations with London Pregnancy Clinic (LPC).

• Send you health updates, reminders, and relevant pregnancy insights.

• Improve and optimize the performance of our Services.

Your data may also be anonymized and aggregated for research purposes, improving our Services without identifying individual users.

5. Data Sharing with Third Parties

We partner with third-party service providers to deliver our services. Below is a detailed list of third-party processors:

Processor Name

Function

Data Categories Processed

Security Measures

AWS

Cloud Storage

Personal data, health information

Encryption at rest and in transit

Stripe

Payment Processing

Payment details

PCI-compliant, encryption of payment details

Google Analytics

Website Analytics

Website usage data

Anonymisation of IP addresses

Intercom

Customer Support

Name, email, app usage

TLS encryption for all communications

These partners are contractually bound to safeguard your data and only process it in accordance with our strict privacy standards. We do not sell or rent your personal data to third parties for direct marketing purposes without your consent.

6. Data Sharing for Seamless Service Delivery

Pouch Health and London Pregnancy Clinic (LPC) operate under the same parent company. Your personal data may be shared between the two entities for seamless service delivery. For example:

• Antenatal Consultations: When you book an antenatal consultation, your name, medical history, and appointment details may be shared with LPC to facilitate the service.

Opt-out Option: You may opt out of certain data-sharing practices between Pouch Health and LPC, but this may affect your ability to access certain features.

7. International Data Transfers

Your personal data may be transferred outside of your jurisdiction. When transferring data outside the European Economic Area (EEA) or United Kingdom, we ensure that such transfers comply with applicable data protection regulations, including:

• Standard Contractual Clauses approved by the European Commission.

• Adequacy Decisions for countries with equivalent data protection standards.

Further details about our international data transfers can be requested by contacting our Data Protection Officer (see contact details below).

8. Data Security Measures

We are committed to ensuring the security of your data through:

• Encryption: All personal and medical data is encrypted in transit and at rest.

• Access Controls: Access to sensitive information is restricted to authorized personnel using role-based access controls.

• Data Minimisation: We only collect the minimum amount of data required for each purpose.

We also regularly test our security measures through penetration tests and security audits to ensure they meet industry standards.

9. Community Forums and User-Generated Content

9.1. Content Moderation

Our community forums are governed by Community Guidelines that prohibit:

• Medical misinformation

• Personal attacks or hate speech

• Inappropriate or offensive content

Users can report inappropriate content through the app, and we may take action such as issuing warnings, removing content, or suspending accounts.

9.2. Legal Implications

Users are responsible for the content they post and must comply with all applicable laws. Pouch Health does not assume liability for user-generated content but reserves the right to remove harmful or unlawful posts.

9.3. Age Restrictions

Our services are designed for users over the age of 18. We do not knowingly collect personal information from minors, and age verification may be required for certain features.

10. Your Rights

You have the right to:

• Access: Request access to the personal data we hold about you.

• Correction: Request corrections to any inaccurate or incomplete data.

• Deletion: Request the deletion of your personal data, subject to legal and medical record retention obligations.

• Data Portability: Request your data in a portable format for transfer to another service provider.

You can exercise your rights by contacting us at privacy@pouch.health

11. Changes to This Privacy Policy

We may update this policy from time to time to reflect changes in our services or regulatory requirements. We will notify you of significant updates through the app or website, and your continued use of our services will indicate your acceptance of the updated terms.

12. Contact Information

If you have questions about this Privacy Policy or wish to exercise your rights, please contact our Data Protection Officer at:

Email: privacy@pouch.health

Phone: +44 (0) 203 687 2939

Mailing Address: Pouch Health, 36 Spital Square, E1 6DY, London, United Kingdom