Advoca Health Ltd

Privacy Policy

Last updated: October 23, 2025

Your privacy is critically important to us. This Privacy Policy explains how Advoca Health Ltd ("Advoca," "we," "us," or "our") collects, uses, stores, shares, and protects your personal data when you use our Advoca mobile application and related services (collectively, the "Services"). We are committed to being transparent about our data practices and ensuring you understand how your information is handled.

By using our Services, you acknowledge that you have read and understood this Privacy Policy and agree to the collection and use of your information as described herein.

1. Who We Are

Advoca Health Ltd is a company registered in London, United Kingdom. We operate the Advoca mobile application, which acts as an appointment assistant for patients. Our Services help you record and summarise health-related appointments, explaining medical terms in simple language and providing links to official, verified information sources.

2. What Information We Collect

We collect different types of information, including personal data and special category health data, to provide and improve our Services.

(a) Appointment Data

This is the core data processed by Advoca and includes:

  • Audio Recordings: Live audio from your appointments recorded through the app, or audio from telephone appointments that you choose to upload. Please note, we do not store audio files on our backend servers; they are temporarily cached for processing and immediately deleted (see Section 4 for details). Audio is encrypted and stored locally on your device.
  • Transcripts: Raw and verified text versions of your audio recordings.
  • Summaries: AI-generated summaries of your appointments in simple language, created from the verified transcripts.
  • Associated Metadata: Data related to your appointment recordings and summaries (e.g., date, time).
  • Personal Data: Audio recordings and raw transcripts may contain personal data about you or others. We employ processes to remove personal data from transcripts, but some may remain in verified transcripts and summaries.

(b) User Profile Data

When you register for our Services, we collect:

  • Account Information: Your email address and name, provided by third-party authorisation services upon login. This is used for account management and essential communications from Advoca.
  • Optional Health and Personal Data: You can choose to provide additional personal data, including special category health data such as your health conditions and care status. This information is only used to help us understand our user base, tailor the application to you and to improve our Services.

(c) Technical Information

We collect certain technical information about your device and how you use the App to ensure the proper functioning, security, and management of our Services. This may include information about your mobile device (e.g., operating system) and data related to your interactions with the App for purposes such as monitoring for violations of our terms, preventing fraud, and managing service performance.

(d) Anonymised Data

With your separate and explicit consent, we process certain data in a fully anonymised form. Once anonymised, this data is no longer considered personal data under GDPR, meaning it cannot be used to identify you.

3. How We Use Your Information (Purposes and Lawful Basis)

We process your data for the following purposes and rely on the specified lawful bases under UK GDPR:

(a) To Provide Core Services

  • Purpose: To record, transcribe, and generate patient-friendly summaries of your health-related appointments. This helps you retain information, improves communication with carers, relatives, and healthcare professionals, and enables you to conduct further research.
  • Lawful Basis: Your explicit consent (UK GDPR Article 6(1)(a) and Article 9(2)(a)). This consent is obtained through a clear and accessible process within the App before you can use these features.

(b) For Account Management and Communications

  • Purpose: To manage your Advoca account and send you essential service-related communications.
  • Lawful Basis: Your explicit consent for the Services, which includes the creation and management of your account.

(c) To Understand Our Users and Improve Services

  • Purpose: To analyse our user cohort based on the optional health and personal data you provide (e.g., care status, health conditions) to enhance the Advoca application and tailor our services to you.
  • Lawful Basis: Your explicit consent to submit this optional data.

(d) For Optional Anonymised Data Processing

  • Purpose: If you provide explicit consent (given separately), your data will be fully anonymised and may be used for research, development and commercial purposes. This includes being shared with trusted partners to promote medical research, foster innovation in healthcare and improve patient outcomes. It also includes internal use within Advoca to optimise the application.
  • Lawful Basis: Your separate and explicit consent for this optional purpose. Once anonymised, the data is no longer personal data and cannot be traced back to you.

(e) For User-Initiated Sharing

  • Purpose: To enable you to share specific transcripts and summaries with other Advoca users you choose (e.g., carers, relatives).
  • Lawful Basis: Your explicit consent each time you choose to share data within the App.

(f) For Security and Service Management

  • Purpose: To monitor the Services for compliance with our Legal Terms, prevent fraud, troubleshoot technical issues, and ensure the proper functioning and security of the Services. This includes managing excessive data or system burdens.
  • Lawful Basis: Our legitimate interests in maintaining a secure and functional service, and where necessary, compliance with a legal obligation.

4. How We Share Your Personal Data

We only share your personal data under specific circumstances and with robust safeguards in place:

(a) With Data Processors for Core Service Delivery

  • We use enterprise-grade cloud service providers located in the EU to process audio into transcriptions and generate summaries.
  • Zero Data Retention: Crucially, we have strict zero data retention policies in place with these processors. This means no audio or transcription data is stored by them; it is only processed and the output (transcription or summary) returned to us.
  • Data Processing Agreements (DPAs): We have signed DPAs with all our processors to ensure they comply with data protection laws and our strict privacy standards.

(b) For Legal Obligations and Enforcement

  • We may disclose your information where legally required to do so in response to lawful requests by public authorities, including to meet national security or law enforcement requirements, or to enforce our Legal Terms.

We do not sell your personal data to third parties.

5. How We Store and Secure Your Information

We are committed to protecting your personal data through stringent security measures:

(a) Storage Location

  • All your summary, transcript, and user profile data is stored securely in a database server located entirely within the United Kingdom.

(b) Security Measures

  • End-to-End Encryption: Data is encrypted both when it is in transit (between your device, our backend, and processors) and when it is at rest (stored in our database or temporarily cached). We enforce Transport Layer Security (TLS 1.3) for all data in transit.
  • Enterprise Cloud Services: We exclusively use enterprise-grade cloud services (Microsoft Azure, Google Cloud Platform) with reputable state-of-the-art security controls.
  • Zero Data Retention: As noted in Section 4(a), our processors for sensitive data (audio, raw transcripts) operate under zero data retention policies.
  • Access Controls:
    • Application Access: The Advoca app enforces multi-factor authentication (MFA) and biometric identification (where supported by your device) for secure login.
    • Internal Access: We implement a Zero Trust architecture, strict Role-Based Access Control (RBAC), and mandate Two-Factor Authentication (2FA) for all developer and administrative access to our infrastructure services. Sensitive production access keys and variables are secured in enterprise cloud services key vaults.
  • Auditing and Monitoring: We implement auditable logging on our database and web console to monitor and audit database access.
  • Personal Data Minimisation: We use AI to greatly minimise your personal identifiable information being present in transcripts and summaries.
  • Anonymisation: When you consent for us to process your data for the purposes described in 3(d) we use a robust process to fully anonymise your transcripts and summaries. After this process it is not possible to trace this data back to you.
  1. International Data Transfers

While all your personal data is stored entirely within the United Kingdom, some processing occurs with our partners in the EU region. These transfers are conducted in accordance with UK GDPR Chapter V (Articles 44–49), based on appropriate safeguards under Article 46, ensuring your personal data remains protected.

7. Your Data Rights

As a user, you have significant control over your data. We provide mechanisms within the application and via contact with our support team to exercise your rights:

  • Right to Be Informed: This Privacy Policy serves to inform you about our data processing activities. We also provide clear information within the App before you consent to processing.
  • Right of Access: You can request a copy of all data associated with your account, including appointment summaries, transcripts, associated metadata, profile health data, personal data, and account data, in a machine-readable format, via the application.
  • Right to Rectification: You can modify your profile health and personal data directly in the app. You can also report any summary or transcript content as inaccurate and request rectification.
  • Right to Erasure (Right to Be Forgotten):
    • You can delete specific appointment data (summaries, transcripts, and associated metadata) from within the app. Access for any secondary users you have shared this data with will also be revoked.
    • You can delete all data associated with your account (appointment data, profile health data, personal data, and account data).
    • We will automatically remove all your information if your account is inactive for a continuous period of two (2) years.
  • Right to Withdraw Consent: You can separately give or revoke consent for Advoca to anonymise your data for the purposes stated in 3(d) at any time through the application. Withdrawing consent will not affect the lawfulness of processing based on consent before its withdrawal.
  • Right to Data Portability: This is covered by your right to request a local copy of your data in a machine-readable format.

To exercise any of these rights, please use the features within the Advoca application or contact us directly using the details provided in Section 10.

8. Data Retention

We retain your summary, transcript, and profile data for as long as your account is active or as needed to provide you with the Services.

  • Active Accounts: Your data (summaries, transcripts, and profile information) is retained for the duration of your active use of the Services.
  • Inactive Accounts: If your account remains inactive for a continuous period of two (2) years, we will remove all associated information.
  • Audio Files: Audio files are only temporarily cached on our backend servers and are immediately deleted once they have been processed. They are not stored on our servers long-term.
  • Anonymised Data: Once data has been fully anonymised for LLM optimisation or aggregated insights, it is no longer considered personal data and is not subject to personal data retention rules.

9. Children's Privacy

Advoca is not designed for or marketed to children. Our Terms of Service strictly prohibit use by individuals under the age of 18.

In cases where an appointment concerns a child, the user (e.g., a parent or legal guardian) must be an adult with the legal authority to provide explicit consent on the child's behalf for the processing of any personal data.

10. Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our practices or for other operational, legal, or regulatory reasons. We will provide you with prior notice of any scheduled changes to the Services you are using. Changes to this Privacy Policy will become effective seven (7) days after the notice is given, except if the changes apply to new functionality, security updates, and bug fixes, in which case the changes will be effective immediately. By continuing to use the Services after the effective date of any changes, you agree to be bound by the modified terms. If you disagree with such changes, you may terminate Services as per our Terms and Conditions.

11. Contact Us

If you have any questions or concerns about this Privacy Policy or our data practices, or if you wish to exercise your data rights, please contact us at:

 

Advoca Health Ltd

London
United Kingdom
Email: [email protected]