PRIVACY POLICY

Our contact details

Name: Klira Ltd

Address: Labs Atrium, The Stables Market, Chalk Farm Road, London, United Kingdom, NW1 8AH

E-mail: [email protected]

We currently collect and process the following information:

• Personal identifiers and contacts - name and contact details

• Payment information

• Personal medical information

• How we get the personal information and why we have it

Most of the personal information we process is provided to us directly by you for one of the following reasons:

• To become a member of Klira we need to know your name and contact details, and for you to set up a password to allow you to log-in securely

• We need payment information to process payment for the products and services you buy through the Klira website

• In order to do the analysis of your skin we need you to answer our 51 question online diagnostic test, the data from which includes personal medical information

We may share this information with the Dermatology Nurse Contractors working with Klira, and Roseway Labs - our pharmacy partner - in order that they can process your prescription. We only ever share the data that is necessary for these partners to complete the task required of them.

Under the UK General Data Protection Regulation (UK GDPR), the lawful bases we rely on for processing this information are: (a) Your consent. You are able to remove your consent at any time. You can do this by contacting [email protected]

How we store your personal information

Your information is securely stored. We keep the information you provide to us for the time during which you remain a member of Klira. If you no longer subscribe to the service, we will keep your data for up to 12 months in case you wish to re-join the service, we will then securely delete any sensitive health information associated with your online diagnostic test after 12 months.

Your data protection rights

Under data protection law, you have rights including:

• Your right of access - You have the right to ask us for copies of your personal information.

• Your right to rectification - You have the right to ask us to rectify personal information you think is inaccurate. You also have the right to ask us to complete information you think is incomplete.

• Your right to erasure - You have the right to ask us to erase your personal information in certain circumstances.

• Your right to restriction of processing - You have the right to ask us to restrict the processing of your personal information in certain circumstances.

• Your right to object to processing - You have the the right to object to the processing of your personal information in certain circumstances.

• Your right to data portability - You have the right to ask that we transfer the personal information you gave us to another organisation, or to you, in certain circumstances.

You are not required to pay any charge for exercising your rights. If you make a request, we have one month to respond to you. Please contact us at [email protected] or Klira Ltd, Kemp House, 160 City Road, London EC1V 2NX if you wish to make a request.

How to complain

If you have any concerns about our use of your personal information, you can make a complaint to us at Klira Ltd, Labs Atrium, The Stables Market, Chalk Farm Road, London NW1 8AH.

You can also complain to the ICO if you are unhappy with how we have used your data.

The ICO’s address:

Information Commissioner’s Office

Wycliffe House

Water Lane

Wilmslow

Cheshire

SK9 5AF

Helpline number: 0303 123 1113

CO website: https://www.ico.org.uk