Last updated: 12 Jan, 2023 

 

1. Who we are

2. The Personal Data we process about you

3. How we collect your personal data

4. How we use your Personal Data

5. How long we keep your Personal Data

6. Disclosures of your Personal Data

7. How we protect your Personal Data

8. Third party links

9. Your rights in relation to your Personal Data

10. Glossary

 

1. Who we are

1.1 This Privacy Policy

 

This Privacy Policy covers how LEIA Health AB (“LEIA”, “we”, “us”, or “our”) collect and process your Personal Data (defined in section 2) obtained by us through your use of the Services or otherwise shared by you. It is important that you read it together with any other privacy notice that we may provide when we are collecting your Personal Data so that you are fully aware of how and why we are using it.

 

We keep our Privacy Policy under regular review and may make changes to it. Any changes will be posted on our website (the “Website”) and, where appropriate, notified to you.

 

1.2 The Services

 

Delivered in the form of an application (the “App”), LEIA is a digital postpartum app guiding you through your fourth trimester. The App can also be used while you are in your third trimester. 

 

1.3 Controller

 

LEIA is a controller and responsible for the processing of your Personal Data. We care deeply about the confidentiality and integrity of the information that is shared with us, and will only process your Personal Data in accordance with this Privacy Policy and applicable laws and regulations.

 

We have appointed a Data Protection Officer (“DPO”). If you have any questions or comments about this Privacy Policy or our processing of your Personal Data, please contact our DPO at dpo@meetleia.com or reach out to our customer support at info@meetleia.com.

 

Contact details

LEIA Health AB

Reg. no 559311-0520

Frejgatan 32, 
113 45 Stockholm, Swede

 

The Personal Data we process about you

LEIA may process the following kinds of personal data about you (collectively referred to as “Personal Data”):

 

• Account Data includes registration date, payment plan and whether you have an active subscription or not..

• Contact Data includes email address.

• Device Data includes device identifier, your mobile operating system, the type of mobile browser you use and time zone setting.

• IP Data includes your approximate position based on your IP address.

• Identity Data includes first name, last name, username and date of birth.

• Marketing Data includes your preferences in receiving marketing from us.

• Profile Data includes your feedback and survey responses.

• Sensitive Data includes health data and referred to as special categories of Personal Data as defined in article 9 of the European Union's General Data Protection Regulation (“GDPR”), such as information on whether you are using the App to follow a pregnancy or post pregnancy as well as your physical and mental history, current moods and physical symptoms and personal notes.

• Transaction Data includes details about purchases and payments, but excluding bank account and full payment card details (we do however receive card expiration date and some payment card digits from our payment service providers in order to allow access to the App). Usage Data includes details of your use of the Services, such as traffic data and the features that you access.

• Usage Data includes details of your use of the Services, such as traffic data and the features that you access.

• User Data includes data provided by you when setting up an account with LEIA and using the App, such as Contact, Identity, Marketing and Sensitive Data as well as other Personal Data that you may provide in connection with such use.

• Employment information includes which company you’re employed at, start and leave date for parental leave if you sign up through one of our special initiatives such as LEIA Health Business.

 

We also use cookies and HTML local storage to distinguish you from other Users of the Services and to remember your preferences. This helps us provide you with a good experience when you use the Services and allows us to improve them. For more information on cookies, please see our Cookie Policy.

 

How we collect your personal data

3.1 Information you give us

 

LEIA process Personal Data provided by you when registering for an account and using the App, using our social media platforms, answering surveys, contacting our customer support or otherwise corresponding or interacting with us and our Services.

 

When signing up for the App, you will be requested to consent to our use of your Sensitive Data (please note that you will need to consent in order for the App to work). You have the right to withdraw your consent at any time by changing the setting in the App, or by contacting us at support@meetleia.com. If you provide sensitive data to us by other means than the app – for example via support – this is described in greater detail in section 4.1.

 

It is important that the Personal Data we hold about you is accurate and current. Please keep us informed if your Personal Data changes during our relationship with you.

 

3.2 Information we automatically collect about you and your device

 

When you are using our Services, we will automatically collect Device, IT and Usage Data. Some Usage Data is collected by using cookies. Please see our Cookie Policy for further details.

 

3.3 Information we receive from suppliers

 

We receive Device and Usage Data about you from analytics providers such as Mixpanel and Transaction Data from our payment service providers.

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How we use your Personal Data

4.1 – To enable and provide the Services

 

4.1.1 – General

 

It follows from the nature of our Services that we must process such Personal Data that you add to the Services to enable and provide them. This includes to administer the Services and our relationship with you, to give you personalized information, to secure the quality and develop the Services and to communicate and provide customer support, as further explained below. Consent for processing sensitive personal data must be obtained in order for the app to work.

 

4.1.2 – To administer the Services and our relationship with you

 

We use your User and IT Data to administer the Services and our relationship with you. This includes setting up your account for the App, troubleshooting, system testing as well as notifying you of changes to the Services or technical issues and reaching out to you via in-app messages to ensure your correct and optimal use of the App.

 

Lawful Basis: Contract, Consent, Legitimate interest in running the business, provide and ensure the proper function and use of the Services

 

4.1.3 – To give you personalized information

 

LEIA provides you with personalized information and we do this by analyzing the User Data that is added to the App. Hence, LEIA uses automated methods for processing User Data in order to provide you with an adequate App.

 

Lawful Basis: Consent, Contract

 

4.1.4 – To secure the quality and develop the Services

 

We process your User, Usage and Account Data to monitor and analyze how our customers engage and interact with the Services so that we can secure the quality and develop the Services to better align them with your usage patterns and preferences. While we have access to Personal Data for the purpose of analytics, the results are aggregated and stripped of any Personal Data.

 

We may also contact and enable you to complete surveys. We use the Profile Data from these surveys to better understand how we can improve your user experience.

 

Lawful Basis: Contract, Consent, Legitimate interest to analyze how our customers use the Services and to develop and improve them

 

4.1.5 – To communicate with you and provide customer support

 

We will process Personal Data that you provide in inquiries to our customer support, on our social media channels or through contact forms provided by us at congresses and events, for the purpose of communicating with you and acting on complaints. What type of Personal Data we collect for this purpose depends on the nature of your inquiry. If you are a User, our support agents may request access to your User Data if necessary to respond appropriately to your inquiry. Such access is subject to strict access controls and security measures to protect your integrity.

 

When you interact with us publicly on our social media channels, ensure that you do not submit any Personal Data that you do not want to be seen by other people. We recommend that you also read through the privacy policies of such platforms.

 

Lawful Basis: Contract, Consent, Legitimate interest to respond to your inquiries, as far as Personal Data is processed to communicate with you on matters that are not related to your agreement with us
 

4.2 – To process purchases and deliver the Services

We use your Identity, Contact, Transaction, IP Data and Account Data to process purchases and manage subscriptions. This includes logistics, preventing fraudulent payments and contacting you regarding your purchase.
 

Lawful Basis: Contract, Legal obligation (eg Swedish bookkeeping law SFS 1999:1078), Legitimate interest to inform you of matters concerning your purchase that we deem relevant for you, but which are not covered by our Terms of Use

 

4.3 – To conduct research

 

Women's health is important to LEIA and we invest in scientific research in postpartum and parental health in order to advance women's and parents' health. 

 

All our published research is subject to independent peer review and has ethical approval from the relevant professional bodies where required.

 

If we have your consent, we will use your User Data and other Personal Data that you may provide, in pseudonymized or anonymized form (see the Glossary for more information on pseudonymization), for scientific studies, scientific articles and other research purposes as may be disclosed when your Personal Data is collected. However, Personal Data is anonymized and aggregated before any such publications are shared outside of LEIA. We may also contact you with requests to participate in specific research projects run by us or our business partners.

 

LEIA also contributes to research carried out by selected universities, institutions and other parties by sharing anonymized and minimized data with them. For the avoidance of doubt, we do not share any Personal Data with such external parties.

 

Finally, we may analyze sensitive data in order to publicly share insights learned from aggregated data with the purpose of increasing the public knowledge and understanding of women's health. This kind of publication is always based on aggregated anonymized data and as such does not contain any personal information.

 

Lawful Basis: Consent

 

4.4 – Marketing

 

4.4.1 – Marketing Communication

 

We use Identity, Contact, Device and Marketing Data of our users of the App to send you newsletters and other marketing communications eg push notifications regarding LEIA and our Services, including campaigns and offers. We also process Account, Contact and Usage data to conduct internal usage analysis for the purpose of creating and sending relevant messages about our Services. Some Marketing Data is collected by using cookies. These cookies include third party services that may collect information about your visits to our site for analytics, retargeting and conversion tracking purposes. Please see our Cookie Policy for further details.

 

Lawful basis: Legitimate interest to market ourselves and our Services

 

4.4.2 – Social media marketing – custom audiences, lookalike audiences and advertising

 

We use tools that help us identify and reach out to existing and new customers, by matching cookies, device identifiers and hashed (a pseudonymisation technique) email addresses of people who have been using our Services with people on social media platforms to create so called " Custom Audiences” (this enables us to send targeted ads to people who have been using our Services), and “Lookalike Audiences” (this enables us to send targeted ads to people who have similar traits to our Custom Audience). The social media platforms will not share the hashed email address with third parties or other advertisers and will delete it promptly after the match process is complete. Please note that we do not share any Sensitive Data or group users based on sensitive data for the purpose of Custom and Lookalike Audiences.

 

Lawful Basis: Legitimate interest to market ourselves and our Services

 

4.4.3 – Surveys and interviews

 

You may also be contacted and enabled to complete surveys or take part in interviews for marketing purposes. We will process the Profile Data that you provide in such surveys and interviews to analyze user preferences, improve and assess the effectiveness of marketing activities, use as marketing material or other promotional purposes as disclosed when your Personal Data is collected.

 

Lawful Basis: Consent

 

4.4.4 – Marketing opt-out

 

You always have the right to opt-out of receiving marketing communication or having your data being processed to identify Custom and Lookalike Audiences from us by opting out, by adjusting your settings in the App or contacting us at info@meetleia.com.

 

How long we keep your Personal Data

We retain your Personal Data for as long as necessary to achieve the purposes set out in this Privacy Policy. In some cases, we may be required to continue to process your Personal Data for a longer period of time to comply with legal obligations (eg accounting or audit obligations) or for the establishment, exercise or defense of legal claims. If you terminate your account with us, all your data will be deleted. 

 

Lawful basis: Consent

 

Disclosures of your Personal Data

6.1 Recipients

 

LEIA never sell your Personal Data and we conduct extensive assessments before engaging any processor to ensure that they have appropriate technical and organizational measures in place that provide adequate protection of your Personal Data. Anyone who is processing Personal Data on our behalf is bound by contractual obligations to keep Personal Data confidential and secure, and to use it only for the purposes as instructed by us.

 

LEIA may share your Personal Data:

 

• with our service providers that we use to support and provide our business, such as technical service or operation providers, to the extent needed to enable and provide the Services to you,

• with our affiliates LEIA, related by common ownership or control, to the extent needed to carry out the processing of Personal Data as described in this Privacy Policy,

• with our successors, if we are involved in eg a merger, acquisition or asset sale, giving you notice of this,

• with others with whom you ask us to share your Personal Data, if we reasonably believe it is necessary to comply with a legal or regulatory obligation, and/or to protect and defend LEIA, our business partners' or users' rights and interests.
   

If you choose to share your Personal Data with any third person (eg a partner), you accept that you have done so at your own risk.

 

6.2 Payment service providers

We do not process your financial data such as bank account and full credit card number. That information is provided directly to our payment service providers. Our payment service providers are themselves responsible for the processing of your personal data which means that you will be requested to enter into separate agreements directly with them. The personal data you provide to them will be stored in accordance with their privacy policies, which we recommend you to read carefully.

Any payment transactions carried out by our payment service providers are encrypted and subject to compliance with the Payment Card Industry Security Standard (“PCI DSS”) regulations. PCI DSS requirements help ensure the secure handling of payment information.

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6.3 International transfers

 

Your Personal Data may be transferred and processed in countries outside the EU/EEA where LEIA's affiliates or service providers are located. Such international transfers are carried out in accordance with applicable laws and are subject to at least one of the following safeguards to protect your Personal Data:

1) The recipient country has been deemed to provide an adequate level of protection for personal data by the European Commission.

 

If your Personal Data is processed in the United States, it may also be subject to protection by federal and state regulations, as well as agency policy and guidance by the Federal Trade Commission.

 

How we protect your Personal Data

All information you provide to us is transferred using TLS encryption (HTTPS) and stored on secure servers. We use generally accepted industry standards, technologies, procedures and methods, such as firewalls, encrypted storage, pseudonymization, regular software updates, security scans, access control, audit logging and review of admin actions as well as external penetration tests to protect the integrity of your Personal Data and to prevent unauthorized access. We also have policies and other organizational measures in place, including recurrent employee training on data protection and strict procedures to deal with any suspected personal data breach.

 

Third party links

The Website may contain links to other websites. Please note that we do not accept any responsibility or liability for personal data that may be collected through these websites or services. We recommend that you read their privacy policies before you submit any personal data to them or use their services.

 

Your rights in relation to your Personal Data

9.1 Your rights

 

You have the right to:

 

• request access to and information about your Personal Data that is being processed by us,

• request correction of your personal data if it is inaccurate or incomplete, including to provide additional data if relevant information is missing,

• request erasure of your Personal Data,

• object to our processing of your Personal Data (i) if the processing is based on our legitimate interest, or (ii) for direct marketing purposes,

• request that we restrict the processing of all or some of your Personal Data in certain situations and to ask us not to send you any direct marketing, and

• request a copy of your Personal Data in a structured, commonly used and machine readable format and that we transfer your personal data to another controller.

• If you have any concerns regarding our processing of your Personal Data, you have the right to file a complaint with the Swedish Data Protection Authority (Sw. Integritetsskyddsmyndigheten), or your local supervisory authority.

 

9.2 How to exercise your rights

 

You may contact us in writing at any time to exercise your rights, preferably using the email address that is associated with your user account. We may need to request specific information from you to help us confirm your identity.

 

We do our best to respond to your request within a few days, and at least within one (1) month. If the request is complicated or if we have received a large number of requests, we may need to extend our response time with one (1) additional month.

 

You can exercise your rights at no cost to you. However, we may charge you a reasonable fee if your request is clearly unfounded, repetitive or excessive.

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11.1 – Response Timing and Format

 

We endeavor to respond to a verifiable consumer request within 45 days of its receipt. If we require more time (up to 90 days), we will inform you of the reason and extension period in writing. If you have an account with us, we will deliver our written response to that account. If you do not have an account with us, we will deliver our written response by mail or electronically, at your option. Any disclosures we provide will only cover the 12-month period preceding the verifiable consumer request's receipt. The response we provide will also explain the reasons we cannot comply with a request, if applicable.

 

If you have any concerns regarding our processing of your Personal Data, you have the right to file a complaint with the Swedish Data Protection Authority (Sw. Datainspektionen), or your local supervisory authority.

 

11.2 – Non-Discrimination

 

We will not discriminate against you for exercising any of your CCPA rights. We will not:

 

• Deny you goods or services.

• Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.

• Provide you with a different level or quality of goods or services.

• Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.
   

Glossary

• Anonymized data means that the identifying information is irreversibly removed so that an individual is not identifiable. Anonymized data is not Personal Data.

• App LEIA' application

• Consent means that you have expressed your agreement to our processing of your personal data for a specific purpose by a statement or clear opt-in. You can withdraw your consent at any time by changing your settings in the App, contacting us at info@meetleia.com or following the instructions provided when the consent was collected.

• Contract means that the processing of your Personal Data is necessary for the performance of a contract to which you are a party, eg our Terms of Use, or to take steps at your request before entering into a contract.

• Legal obligation means that the processing of your Personal Data is necessary for compliance with a legal obligation that we are bound by, eg medical device regulations or accounting laws.

• Legitimate interest means that we assess that we have a legitimate interest in conducting and managing our business that, considering and balancing any potential impact on you and your rights, we do not consider are overridden by the impact on you. Please contact us if you would like to know more about how we have conducted this balance of interest.

• Minimized data means that only the minimal amount of data needed for a certain kind of processing is included.

• Pseudonymized data means that identifying information is replaced with something else so that additional information is needed to re-identify an individual. Pseudonymization is a security measure.

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