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Privacy notice

Last updated

Draft. This page is complete except for details about who runs BiomarkerHQ (3 still to fill in, marked below). It is not yet final, and it is kept out of search results until it is.

This notice explains what personal data BiomarkerHQ collects, why, who else handles it, how long we keep it and what your rights are. It covers biomarkerhq.com, the BiomarkerHQ app and the emails we send.

The short version

  • Without an account, your lab results and wearable data stay in your browser. We do not receive them and we cannot see or recover them. Lab PDFs are read on your device and are not uploaded.
  • With an account, we store your data only after you agree. Signing in is not agreement. After you sign in, the dashboard asks separately whether to save your lab results and wearable data to your account. Until you say yes, nothing is saved there, and our server refuses it.
  • Account data is stored in the EU. It sits in a database and a file store in Cloudflare's EU jurisdiction. Only you can open it in the app.
  • A copy of an original PDF is kept only if you choose to keep one.
  • Live wearable sync happens only if you connect a wearable. Then a wearables service we run, in the same EU Cloudflare jurisdiction, holds your provider's authorisation (encrypted) and the daily values it pulls.
  • You can download everything, stop saving, or delete your account, at any time, from the dashboard overview. Stopping and deleting both erase your data.
  • We do not sell personal data, show advertising or use analytics trackers. We do not use your health data to train artificial intelligence models, and we do not share it with anyone to do so.

Who we are

BiomarkerHQ is run by [the name of the person or company that runs BiomarkerHQ], [how it is organised, for example a company and its number], of 20 Wenlock Street, London [postcode], United Kingdom. We are the controller of the personal data described in this notice: we decide why and how it is used.

Write to us about anything in this notice, or about your data, at privacy@biomarkerhq.com. We have not appointed a data protection officer. Messages to that address are read by the person who runs the service.

Health data is special-category data

Blood test results, and wearable measures such as heart rate variability, resting heart rate, sleep and temperature, are health data. Under UK GDPR and EU GDPR, health data is special-category data and needs extra protection. We store it in your account only on the basis of your explicit consent.

  • We ask for it in the dashboard after you sign in, with a box you have to tick and wording that says what is stored and how to undo it. We record which version of the wording you agreed to, and when.
  • If the wording changes in a way that matters, we ask again, and nothing new is saved to your account until you agree.
  • You can withdraw your agreement at any time with Stop saving to my account on the dashboard overview. That deletes every lab draw, result, kept PDF and wearable record we hold for you, including the copy our wearables service holds. Your account stays, so you can sign in and agree again later.
  • Data that stays in your browser never reaches our servers, so we do not process it and no agreement is needed for it.

What we collect, why, and on what basis

The law says we need a lawful basis for each use of personal data. Here is each one, with the basis we rely on. Where the basis is our legitimate interests, the interest is running a secure service that works, and we have weighed it against your rights. You can object to it (see "Your rights").

Personal data we collect, why, and our lawful basis
WhatWhyLawful basis
Email address and name, if you sign in. If you sign in with Google, also your name, email address and profile picture link from Google, and Google's sign-in tokens, kept encrypted.To provide the account you asked for and to send you sign-in links.Contract (Article 6(1)(b))
Sign-in sessions and sign-in links. A session records a random token, when it expires (30 days, extended while you use the site), the browser text your device sends and the IP address it was created from. A sign-in link is kept until it is used or expires, after 10 minutes.To keep your account secure and to stop misuse.Legitimate interests (Article 6(1)(f))
Lab results, notes, tags and wearable data you save to your account. For each draw: the collection date, lab name, whether you fasted, your notes and tags, the file name of any PDF, and each result's marker, value, unit and the reference range printed on your report. For wearables: daily values for HRV, resting heart rate, sleep length and skin temperature, and where each came from (a CSV file or a provider).To draw your timeline and comparisons.Your explicit consent (Article 6(1)(a) and Article 9(2)(a))
Copies of lab PDFs, only if you choose to keep them: the original file, in EU file storage under a random name. Only you can download it.To give you back your original report.Your explicit consent (Article 6(1)(a) and Article 9(2)(a))
A wearable connection, only if you connect one: a random identifier that links your account to your record in our wearables service (we send it no email address and no name), the state of the last sync, your provider's authorisation (stored encrypted) and the daily values pulled: sleep length and efficiency, HRV, resting heart rate and skin temperature. The service reads only sleep and readiness values. It does not ask for your profile, email address, workouts or location, although your provider's consent screen may describe broader access (Oura's daily permission, for example, also covers activity summaries).To keep your wearable data up to date without a file.Your explicit consent (Article 6(1)(a) and Article 9(2)(a))
Waitlist email address and sign-up time, stored with the wording you agreed to.To tell you about launches such as the coach view.Your consent (Article 6(1)(a)). You can withdraw it at any time.
Messages you send us, and our replies.To answer you and to keep a record of what was agreed.Legitimate interests (Article 6(1)(f)), or contract where you are asking about your account
Technical logs. Cloudflare, which runs the site, keeps logs of requests for up to 7 days: the page requested, the result, timing, errors and technical details such as your IP address and country. We do not write lab or wearable values to logs.To run the service, fix faults and protect it.Legitimate interests (Article 6(1)(f))
Abuse protection. Sign-in and waitlist requests are counted per IP address over a short window to stop repeated attempts. We do not keep those counts. If we switch on Cloudflare Turnstile on those forms, Cloudflare checks signals from your browser to tell people from bots.To stop automated misuse of the sign-in and sign-up forms.Legitimate interests (Article 6(1)(f))

Most of this comes from you. The exceptions are your name, email address and profile picture link (from Google, if you use it) and your daily wearable values (from your provider, if you connect one).

Giving us the data for an account is your choice, but we cannot run an account without an email address, and we cannot draw your timeline without the results you ask us to keep.

What we do not do

  • We do not sell personal data, and we do not share it for advertising.
  • We do not build advertising profiles, and we use no advertising or analytics cookies or trackers.
  • We make no automated decisions about you with legal or similar effect. Where BiomarkerHQ marks a value as below, within or above a range, that is a position against the range on your own report, not a decision.
  • We do not use your health data to train artificial intelligence models, and we do not share it with anyone to do so.

Browser storage and cookies

We use one cookie, and only if you sign in: a session cookie, named with the prefix bhq, that keeps you signed in. It is strictly necessary for that, so the law does not ask for your consent to it. If you sign in with Google, short-lived cookies are also set while the sign-in is in progress. We use no cookies for advertising or analytics. If that changes, we will ask you first.

What is kept in your browser
NameWhat it holdsHow long
__Secure-bhq.session_tokenKeeps you signed in (cookie).30 days, extended while you use the site, and removed when you sign out.
bhq:v1:storeYour dashboard data when you have no account, or have not agreed to saving it to one (local storage).Until you delete it or clear this site's data.
themeYour light or dark choice (local storage).Until you clear this site's data.
bhq:v1:… (notices)Which small notices you have dismissed (session storage).Until you close the tab.

Clearing site data in your browser removes all of it, including dashboard data that lives only there. The dashboard overview has a backup export.

Who else handles your data

  • Cloudflare, Inc. Our processor. It hosts the site and runs the app, the wearables service, the databases and the file store (all set to Cloudflare's EU jurisdiction), the job queues (which carry only internal identifiers), the email service that sends sign-in links, and the network that delivers pages. It may use only our instructions and may not use the data for its own purposes.
  • Your wearable provider. Only if you connect one, for example Oura or Whoop. You sign in on the provider's own page, and we never see your provider password. We receive only what you allow. The provider's own privacy notice covers what it holds and shares, and it is a separate controller of that data.
  • Google. Only if you choose to sign in with Google. Google's privacy policy covers your Google account.
  • Authorities. If the law requires it, for example a court order, we may have to disclose data. We will tell you first where we are allowed to.
  • A buyer. If BiomarkerHQ were sold or merged, we would tell you before your data moved, and you could delete it first. Health data would continue to be held only on the basis of your agreement and this notice.
  • No one else. No analytics provider, no advertising network and no external font service.

Where your data goes

We store account data in the EU. Cloudflare is a company based in the United States, and a request can be handled by a Cloudflare data centre near you, so data can pass through other regions on its way to and from the EU. Where personal data is sent outside the UK or the EU to Cloudflare, it is protected by the safeguards in Cloudflare's data processing addendum: the EU standard contractual clauses with the UK addendum, and Cloudflare's certification under the EU–US Data Privacy Framework, including its UK extension.

How long we keep data

  • Your account and what you save to it: until you delete your account or, for lab and wearable data, until you stop saving to your account.
  • In our wearables service: while your wearable stays connected. When you disconnect a provider, the service asks the provider to end the connection and deletes its copy of what it pulled from that provider, and stopping the saving of data or deleting your account deletes your whole record there.
  • When you delete data or your account, it is removed from our database and file store at once, and a deletion request goes to our wearables service. If it cannot be reached, we keep trying every day until it succeeds. Cloudflare keeps a short history of the databases so they can be restored after a fault, and deleted data can remain in that history until it ages out, for up to 30 days.
  • Sign-in sessions: 30 days, extended while you use the site, and removed when you sign out. Sign-in links: until used or 10 minutes.
  • Waitlist email: until launch messages are finished or you ask us to remove it, whichever comes first.
  • Messages to us: for as long as needed to deal with them and any follow-up, and no longer than two years after the last one.
  • Technical logs: up to 7 days.
  • Data in your browser: until you delete it or clear your browser's site data. We cannot delete it for you because we do not hold it.

Your rights

Under UK GDPR and EU GDPR you can ask to see the personal data we hold about you, correct it, delete it, restrict or object to how we use it, receive it in a portable format, and withdraw consent at any time. Withdrawing consent does not affect what we did before you withdrew it.

Most of this you can do yourself on the dashboard overview, under Your account: Download all my data gives you a file with everything we hold, Stop saving to my account withdraws your agreement and deletes your lab and wearable data, and Delete my account removes the account and all of it. For anything else, write to privacy@biomarkerhq.com. We answer within one month, and we do not charge for it unless a request is clearly unfounded or excessive. We may need to confirm that you are the person the data is about before we act, and for an account we do that by asking you to sign in.

For data stored in your browser you are already in control: use the backup export and "Clear all data" options, or clear this site's data in your browser settings.

If you are unhappy with how we handle your data, please tell us first, and we will try to put it right. You can also complain to the Information Commissioner's Office at ico.org.uk (telephone 0303 123 1113), or to the data protection authority where you live or work.

Children

BiomarkerHQ is for people aged 18 or over. We do not knowingly collect personal data from anyone under 18. If you think a child has given us data, write to privacy@biomarkerhq.com and we will delete it.

Security

Pages and data travel over encrypted connections, and Cloudflare encrypts the database and file store at rest. Every request for lab or wearable data is limited to the account that is signed in. The key that gives access to the wearables service is kept on the server and never reaches your browser, the service has no public address, and your provider's sign-in tokens are encrypted before they are stored.

The people who administer the service can technically reach stored data. We limit that access to what is needed to run and secure the service, and we do not look at the contents of your lab or wearable data unless you ask us to help with a problem or the law requires it. If a breach is likely to put you at risk, we will tell you and the regulator, as the law requires.

If you live in the United States

BiomarkerHQ is run from the United Kingdom and stores account data in the EU. If you use it from the United States, this section adds what some US state laws, such as those on consumer health data, ask a notice to say.

  • What we collect: the categories in the table above. The consumer health data among them is the lab results, notes, tags, kept PDFs and wearable values you choose to save to your account.
  • Why: only to give you the timeline, comparisons and sync you asked for, and to keep the service secure. We collect and keep your health data only with your consent.
  • Who receives it: our processor, Cloudflare, to host it for us. If you connect a wearable, your provider shares data with us at your direction. We do not sell your data and we do not share it for advertising.
  • Your choices: you can see and download your data, delete it, and withdraw your consent from the dashboard overview, or write to privacy@biomarkerhq.com. If we decline a request, you can ask us to reconsider by writing to the same address, and you can contact your state's attorney general.
  • Tracking signals: we do not track you across sites, sell or share personal data, so there is nothing for a "do not track" or global privacy control signal to switch off.

Changes to this notice

We will update this page when what we do with data changes, and we will say so on the page before any change to how health data is handled takes effect. If the wording you agreed to changes in a way that matters, we ask for your agreement again. The date at the top is when it last changed. See also the terms and the disclaimer.