At Agile Kinetic Limited our mission is to help anyone, anywhere to become, and stay active. Our vision for MobilityHub© is to make effective, personalised musculoskeletal care accessible and sustainable. We are committed to democratising orthopaedic and musculoskeletal healthcare. We achieve this by making it as simple as possible for our users to share information with their clinical teams, via our platform MobilityHub, for effective monitoring, better informed decision making and recommendations. We are passionate about high-quality and convenient healthcare. We are also passionate about privacy. We strive to comply with the General Data Protection Regulation (GDPR)and the Data Protection Act 2018 (DPA).
This policy explains how we use your personal data. We want to help you understand how we work with your data, so that you can make informed choices and be in control of your information. We invite you to spend a few moments understanding this policy. We may update this policy from time to time and, if we make any material changes, we will notify you when we do so. We will provide you with the opportunity to review such changes. By continuing to use our products and services after the changes have been made and we have notified you of them, the way we use your personal data will be subject to the terms of the updated policy.
This policy explains how we use your personal data for our healthcare services and products, including our private service, and our NHS service. It also governs the use of your data through our App, or any of our websites, which will be jointly referred to as our App. Reference to your clinical team includes any clinicians (surgeons, physiotherapists, and clinical support staff linked to your account).
This policy covers:
1. Who we are;
2. What personal data we hold and how we get it;
3. What we use your personal data for;
4. Sharing your personal data;
6. Data security and transfers; and
7. Your rights.
If you have any further questions about how we process your information, please don't hesitate to get in touch by contacting our Data Protection Officer:
Address: Data Protection Officer,
1. Who we are
Agile Kinetic Limited is a Private Limited Company registered in England & Wales (Company number 10024755). When this policy talks about ‘Agile Kinetic’, ‘us’ or ‘we’, it means Agile Kinetic Limited. Agile Kinetic Limited are controllers of your personal data provided to, or collected by or for, or processed in connection with our healthcare services. Your relationship is with Agile Kinetic Limited. If for example, you would like to access your data, Agile Kinetic Limited is the entity to which you would make such a request.
2. What personal data we hold and how we get it
We use the following categories of personal data:
When you register with us, you or your clinical team provide us with basic information about yourself, such as your name, telephone number, date of birth, physical address and email address. You and your clinical team are responsible for the accuracy of the information that you provide to us.
Health and medical information
The main type of information we hold about you is health and medical information: information about your procedure, levels of comfort/discomfort, range of motion, rehabilitation exercise adherence, consultations and sessions. This includes interactions with our digital services, and may include some details of your consultations with your clinical team. Your interactions with our digital services may be shared with your clinical team in order to provide you with a better experience and for the purposes of providing your healthcare.
We get some of this information directly from you and your clinical team, when you register with us and when you use our healthcare services.
If you use our App, we may retain records and/or recordings of our interactions with you. This can include video and audio recordings or images you upload or capture when using our App. This is in order to provide you and your clinical team with an efficient way to check your progress, so that we can enable the provision of high quality care to you, and, to allow us to learn from interactions to improve our services. To monitor our service quality, we may retain records of when you contact our support teams via email, phone or any interactive livechat service on the App. Any recordings will be held securely in accordance with our retention policy.
We may also hold information about you and your activity levels from other apps, devices and services where you have given your consent to that data being shared with us. Examples include where you decide to share information collected from a smart watch or similar device with our App.
We do not use or retain any of your financial details such as your credit or debit card information.
Technical information and analytics
When you use our App or visit our website, we may automatically collect the following information where this is permitted by your device or browser settings:
We work with partners who provide us with analytics and advertising services (for our services only and not for third party advertising). This includes helping us understand how users interact with our services, providing our advertisements on the internet, and measuring performance of our services and our adverts. Cookies and similar technologies may be used to collect this information, such as your interactions with our services. You can prevent the setting of cookies by adjusting the settings on your browser or your mobile phone.
Information obtained from third party services
You may choose to connect your existing accounts with other providers (such as a social media provider), for example, when signing up to make it easier to create an account with us. If you choose to do this, we will receive limited information about you from that provider, such as your email address and name. Provided we are acting in accordance with data protection laws, we may also use information from other sources, such as specialist companies that supply information, online media channels, our commercial partners and public registers. This information can for example, help us to improve and measure the effectiveness of our services.
3. What we use your personal data for
The purposes for which we use your personal data and the legal grounds on which we do so are as follows:
Providing you a service
Making healthcare accessible
Keeping you up to date
4. Sharing your personal data with others
Information sharing with other healthcare providers
5. Retention periods
We retain your personal data including medical records in accordance with national best practice guidance – in particular, advice provided by the Department of Health (2006) Records management: NHS code of practice, and summary guidance issued by the British Medical Association. We may retain records and aggregate information that does not identify you for legitimate business purposes such as managing or planning our business, or records for other periods as required by law or regulation.
6. Data storage, security and transfers
We do not store your personal health data on your mobile device. We store all your personal health data, including your diagnostic information on secure servers.
Where you have chosen a password that enables you to access certain parts of our App, you are responsible for keeping this password confidential. We ask you not to share the password with anyone.
Your data may be processed or stored via destinations outside of the UK and the European Economic Area (EEA), but always in accordance with data protection law, including mechanisms to lawfully transfer data across borders, and subject to strict safeguards. For example, we work with third parties who help deliver our services to you, whose servers may be located outside the UK or EEA. For further information on the safeguards we take if we transfer data outside of the EEA, contact DPO@agilekinetic.com.
7. Your rights
As indicated above, whenever we rely on your consent to process your personal data, you have specific rights under the GDPR and DPA to:
You may also contact the Information Commissioners Office(the data protection regulator in the UK): Information Commissioner's Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF, telephone: 0303 1231113 (local rate).
For any questions or concerns, you can contact us by sending an email to DPO@agilekinetic.com.