Data that we process and how we use it
When you signed up to be a Beta Tester, you would have provided us with your contact details, information
relating to your health and lifestyle including past, previous and current experiences and conditions s
uch as hormonal information and other genetic or biometric information.
This data is used to assess your health needs and provide you the most suitable clinical recommendations.
This is done via algorithms we have developed with a clinical team.
Your email address is only used to contact you for information relating to Tuune’s system, or if you
have consented, to keep you up to date with our services and research.
We pseudonymise or anonymise data whenever possible. Once data is anonymised,
it falls out of the remit of data protection regulations.
If you request a prescription, then a summary of your request and relevant aspects of your health data
are sent to our Third Party pharmacist prescriber, who will review and make a final decision.
If you opt to be referred to one of our clinical partners, then a summary of your health data will be sent to the clinician.
If you purchased from us then we collect your cardholder details, number and any other data needed
to facilitate transactions when you purchase products on our site. We use Stripe to ensure payment transactions are completed safely.
There is certain data that we are obliged to collect based on the medical device regulatory requirements.
This is to ensure that the service we offer is safe and that we abide by the medical device regulation.
Because you visited our website, we will have collected information via cookies and other similar tracking
technologies if you consented to us placing these cookies on your device. If you did not then we do not collect this data.
This information is a record of data about all visitors who use the Site and interact with the Services
and we will store this information. These logs contain IP address information, type(s) of operating system(s)
you use, the date and time you visited the site, and information about the type of device you use to connect
to the Services and the Site pages you visited.
for more information.
Our Lawful Basis for Processing
When you provided your email to join the wait list, we use legitimate interest to process this data.
Your health data is only ever processed using explicit consent. This includes when we transfer your data to the pharmacy or to the clinical partners.
Where we process your data for the purposes of Post Market Surveillance (PMS) against medical device regulatory requirements, then this is a legal obligation for us.
When you purchase from us, we process your transaction data under the lawful basis of contract.
We only drop cookies on your device, and process the associated data if you have given your consent.
Data Sharing and Transfers
Like most companies, we use a number of other companies as part of our data processing,
for example our Cloud technology services. We have Data Processing Agreements in place with these providers.
Where data is transferred outside of the EEA, we ensure that appropriate protection and mechanisms are in place,
for example Standard Contractual Clauses and due diligence. We do not sell your data to anyone.
As a beta tester/patient we have created a patient record for you and as such we are required by law
to keep that record for up to ten years consistent with our obligations under the GDPR,
the EU Medical Device Regulation and the EU Product Liability Directive.
Where you signed up as a beta tester, but have not yet created a patient record, we keep your email
until you ask us to delete it, or if we have not had interaction with you within the last year.
Your transaction details, i.e. what you bought, how much and when, are held for 7 years.
The actual card details are not held by us at all but by Stripe and retention is defined by their own policies.