HeartTrends Privacy Policy

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Who is Lev-El and what is HeartTrends? 

Lev-El is a company focused on non-invasive technological detection of heart disease. Lev-El has developed HeartTrends, a form of stress test designed to help early detection of Myocardial Ischemia through the use of a smartphone App and a Heart Rate recording device.

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You are downloading this App because you have either been directed to this service by your healthcare provider, or have chosen to run the HeartTrends test for your own personal assessment. This App will be the point of entry of your information, and will be used to run the test and deliver you the results.

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This Privacy Policy applies to all personal data collected by Lev-El through the use of this application. Please review this policy carefully and contact us if you have any questions or concerns. As used in this policy, terms such as “we” or “our” or “us” or “Company” refer to Lev-El, and the term “app” refers to your use of the HeartTrends mobile or web application.

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For further information on the protection of your personal data and your individual rights, please contact us here: info@Levhm.com

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What information do we collect about you and why?

• Name: This will be included in your test result to make clear that these results refer to yourself

• ID number: This will typically be input by your Healthcare Provider if they have requested a test on your behalf, so that they are able to link this test to your health record

• Heart Rate: Your Heart Rate is recorded by a heart rate recording device you will have received for a 20-minute period so that the test can be administered

• GPS Location: This information is collected anonymously in order for us to conduct research into demographic and geographic trends in heart disease. They will not relate back to yourself.

• The following items will also be collected so that they can be included as factors for consideration in your HeartTrends report: Age, Medical Conditions, Weight, Gender, and Health History

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How do we use your personal data?

All personal data is processed and stored securely, for no longer than is necessary for the purpose in which it was collected, namely in performing the HeartTrends test for which you have been directed to our application. Your information is retained by us for a 6 month period from the time your test is conducted, for the purpose accessing your test results again should it be required. When your information is no longer required, we will ensure it is deleted in a permanent and secure manner. Any data retained beyond this is purely anonymous with no possibility of re-identification.

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Where you have downloaded the HeartTrends app for your own personal use:

Where the HeartTrends test is performed for your own personal use, Lev-El is operating in the capacity of a Controller per the General Data Protection Regulation Article 4(7). Due to the collection of heart rate data, the dataset will include both personal data and Special Category data, as defined by GDPR. Therefore, as a Controller, the lawful basis relied upon by Lev-El would be:

• Article 6(1)(b) – processing is necessary for the performance of a contract to which the data subject is party (through your engagement with HeartTrends) or in order to take steps at the request of the data subject prior to entering into a contract. 

• The Article 9 exemption for Special Category Data will be: Article 9(2)(a) – the data subject has given explicit consent to the processing of those personal data for one or more specified purposes. You will have provided your explicit consent on our landing page.

​We will not share your personal data with any organization unless required to do so in law. In such event we will inform you of the disclosure, unless the law determines that we cannot.

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Where your HeartTrends test results are being used as a diagnostic tool by your Healthcare Provider:

In this capacity, Lev-El is acting as a Processor on behalf of the Controller, your Healthcare Provider. As a Processor, Lev-El will process data on behalf of the Controller who will identify the lawful basis for this purpose. Due to the collection of heart rate data, the dataset will include both personal data and Special Category data, as defined by the GDPR, which means both a lawful basis under Article 6 and an exemption to processing Special Category data under Article 9 are relied upon.

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It is likely that the vast majority of ‘clinics’ acting as Controllers will be considered health and care organizations who are providing the device to individuals as part of their care. Due to this, the likely lawful bases to be relied upon are: 

• Article 6(1)(e) - processing is necessary for the performance of a task carried out in the public interest or in the interest of official authority vested in the controller;

• Article 6(1)(f) – processing is necessary for the purposes of the legitimate interests pursued by the controller or by a third party 

• The likely exemption under Article 9 would be: Article 9(2)(h) – processing is necessary for medical purposes (where processing is undertaken by an individual with a duty of confidence).

​We will not share your personal data with any organization except your Healthcare Provider or where required by the law. In such event we will inform you of the disclosure, unless the law determines that we cannot.

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Use of data for development of product  

Lev-El also use some of the data collected to help develop and improve their product and to conduct demographic research. This would be the anonymized data collected and produced by the results, as all identifiable information will be deleted after the temporary 6 month storage period.

Specifically, we will use your personal data for the following purposes:

• Providing and managing your account

• Performing the test for which you have downloaded the application

• Replying to correspondence from yourself

• Providing you with test results after your test is completed

• Re-administering test results if you require another copy

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Third-party disclosure

We do not sell, trade, or otherwise transfer your personal information to any external parties.

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International Transfers

Your personal data will be stored within Israel.  Israel has been recognized as having adequate data protection law by the EU Commission.

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Your legal rights

Where you are conducting this test for personal use, Lev-El is the Controller of your information. Where you have been referred to this test by your Healthcare Professional, Lev-El is a Processor responsible for assisting the Controller (your Healthcare Professional) in satisfying your request to exercise your rights over the data held about you.

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You have the right to privacy under the General Data Protection Regulation, the Data Protection Act 2018 (DPA), the Human Rights Act 1998 and the Common Law Duty of Confidentiality.  The Equality Act 2010 may also apply. You have the right to know what personal data we hold about you, what we use it for and if the personal data is to be shared, who it will be shared with.

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You have the ability to exercise your rights over the data you have consented to allowing us to hold about you during the 6 months period for which we hold it. Upon submitting a request to exercise these rights, Lev-El have one month within which to respond to your request.

This includes:

• Fair processing of information and transparency over how we use your use personal data

• Access to your personal data and to certain other supplementary information that this Privacy Policy is designed to address

• Us correcting any mistakes in your personal data which we hold

• To erasure (i.e., deletion) of personal data concerning you, in certain situations. Please note that if you ask us to delete any of your personal data which we believe is necessary for us to comply with our contractual or legal obligations this may affect our ability to fulfil our contractual duties with you. We may be legally bound to not delete your personal data. It must be noted that in the conduction of clinical trials, where you have requested to be removed from a trial, we are not obliged to delete all data collected about you up to that point, but will no longer continue to collect your personal data.  

• Receiving your personal data which you have provided to us, in a structured, commonly used and machine-readable format and have the right to transmit those data to a third party in certain situations

• Objecting at any time to processing of personal data concerning you for direct marketing

• Objecting in certain other situations to our continued processing of your personal data

• Restricting our processing of your personal data in certain circumstances

• Claiming compensation for damages caused by our breach of any data protection laws

• The right to have your personal data provided to you in a way you can understand, and explained where necessary, for example where abbreviations have been used.

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Obtaining a copy of your record – Subject Access

If you wish to obtain (or delete) a copy of the personal data we hold about you then this is known as a subject access request. To help us process your request:

• You should complete your request on our form, which can be downloaded here OR by contacting directly at
  dpo.lev-el@kaleidoscopeconsultants.com or contacting us via our European Representative at eea.lev-el@kdpc.es

• Send all information and this request form via email to info@Levhm.com

• We will respond to you within one month of receiving your request

• You will be required to provide a form of ID before any information is released to you

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In some circumstances we may be legally allowed to extend the time to process your request, or there may be a legally justifiable reason why your personal data should not be provided to you. Where this is the case we will inform you. Once you receive your records, if you believe any information is inaccurate or incorrect, please inform us directly at: dpo.lev-el@kaleidoscopeconsultants.com or contacting us via our European Representative at eea.lev-el@kdpc.es as soon as possible. If we unable to resolve your issue, you also have the right to complain to your local Supervisory Authority.

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