1. Who we are

HealthyLiving is a personal health record service available at staging.healthyiliving.com. It lets you keep your own health information, and the information of people you care for, in one private place.

The service is operated by HealthyLiving (Private) Limited, registered in Sri Lanka under number PV 000000, whose registered address is No. 1, Sample Road, Colombo 00100, Sri Lanka ("we", "us"). We are the controller of the personal data described in this policy under the Personal Data Protection Act, No. 9 of 2022 of Sri Lanka ("the Act").

2. The short version

• Your record belongs to you. You decide what to put in it, and you can correct it at any time.
• We use your information to run the service for you. We do not sell it, and we do not use it for advertising.
• Health information is sensitive. We only process it because you choose to give it to us for this purpose.
• Some things this service cannot do yet, such as permanently erasing a record on request from inside the app. We say so below rather than leave it out.

3. What we collect

Information you give us when you create an account

Your full name, your email address and your mobile number. Your email address is how you sign in: each time, we send a single-use code to it. Your mobile number is stored as contact information only. It is not checked and is not used to sign in.

Information about you that you choose to add

As you complete your record, you may add: date of birth or age, gender, address and administrative division, an identity document type and number (NIC, passport, driving licence or SL-UDI), blood group, ethnicity, religion, occupation, marital status and emergency contacts.

Identity numbers are recorded as you type them. We do not check them against any government system.

Health information you choose to add

This is the heart of the service and is the most sensitive information we hold. Depending on what you enter, it may include: measurements such as blood pressure, weight and blood sugar; medical conditions, allergies, concerns and symptoms; a symptom diary; medicines and other treatments, and whether you took them; procedures and surgical history; family history; lifestyle information; laboratory investigation results; imaging reports; calculator and risk-predictor results; and health packs you choose to follow.

Documents you upload

Copies of laboratory reports, imaging reports, prescriptions and similar documents that you upload, and any documents you send us for assisted typing of your records.

Readings from devices and apps

The service has a place to keep readings imported from health devices and apps. No live connection to any device or app platform is switched on in this version; when one is, this policy will say which, and you will choose whether to connect it.

Information about people you care for

If you add a family profile, you give us the same kinds of information about that person. See section 14.

Messages you send us

If you use our contact form, we keep your name, email address, the topic you chose and your message. The form asks you not to include health information.

Technical information

When you sign in, change your record or carry out other sensitive actions, we keep a security record of what happened, when, from which internet (IP) address and with what browser. We also use a small number of cookies to keep you signed in (see section 10). We do not use analytics or advertising trackers.

Sign-in with Google, Apple or Facebook

The service contains code for signing in with these providers, but it is not switched on. If it is switched on and you use it, we will receive from the provider an identifier for your account with them and, if they share it, your email address. We would still send a code to your email address before creating an account.

Payments

Paid plans and online payment are not switched on. Every account is on the free plan. Before payment is switched on, this policy will be updated to describe the payment provider and what it collects.

4. Why we use it

• To create and run your account, and to let you sign in securely.
• To store your record and show it back to you, including in the Doctor View and visit summary you can show or print for a doctor.
• To work out values from what you enter, such as body mass index, and to show you automatic checks and reminders on what you have recorded.
• To send you service emails: sign-in codes, invitations to take over a family profile, and some reminders.
• To answer messages you send us.
• To keep the service secure, investigate misuse, and keep a record of who changed what.
• To meet our legal obligations.

We do not use your health information for marketing, and we do not sell or rent your information to anyone.

5. Our lawful basis

Under the Act we may only process personal data where there is a lawful basis for it. We rely on:

• Your consent for the health information and other sensitive information you choose to enter. You give it by entering the information for the purpose of keeping your own record. You can withdraw it (see section 13).
• Our contract with you (the Terms of Use) for running your account.
• Legal obligations, where a law requires us to keep or disclose information.
• Our legitimate interest in keeping the service secure, for the security records described above.

When you create an account we record which version of the Terms of Use and of this policy you accepted. The service does not yet ask for a separate, specific consent before you enter health information, or before an optional feature such as an automated assistant is used.

6. Who can see your information

• You. Each record is tied to your account. The service is built so that one account cannot reach another account's records.
• Anyone you show it to. The Doctor View and visit summary are shown or printed by you. There are no doctor or pharmacy accounts in this version, and no link that lets someone else open your record.
• Our support staff can see account details needed to help you: your email address, mobile number, account status, the names of the profiles on your account, and your plan. They do not have a screen that shows your health records.
• Our clinical staff, only if you ask us to type in documents for you (assisted record typing). They then see the documents you sent for that request and the entries they make from them.
• Administrators who maintain the system and its security records.
• Authorities, only where the law requires us to disclose information.

Every member of staff has a separate administrator account with a defined role, and administrator actions are recorded.

7. Service providers

We use a small number of companies to run the service. They act on our instructions.

• Hosting. The website, its database and uploaded documents are stored with Hostinger on a shared hosting plan, in Singapore. Hostinger also keeps backups of the hosting account.
• Email. Sign-in codes and other service emails are sent through Hostinger's email service.
• Automated assistants. See section 8.

Sign-in providers and a payment provider would be added to this list before those features are switched on.

We use each provider listed here under its terms for business customers, which require it to protect the information it handles for us.

8. Automated and AI features

Some features can use an artificial intelligence (AI) service run by another company: Anthropic, OpenAI or Google. When these features are switched on by us:

• reading a laboratory report you upload may send the document to the AI service to pick out the results;
• matching the words you use to describe a symptom may send those words to the AI service; and
• the health record assistant may send a summary of your record, together with your question, to the AI service to prepare an answer.

When these features are not available, the service uses its own built-in rules instead and nothing is sent.

AI answers are information, not medical advice (see the Medical Disclaimer). They do not make decisions about you.

These AI services are run from outside Sri Lanka. Each one is used only after an administrator has deliberately switched it on; until then nothing is sent to it. The service does not yet ask your separate permission before sending information to a service that has been switched on.

9. Information sent outside Sri Lanka

Your information is stored by our hosting provider in Singapore. If AI features are used, the information described in section 8 is processed by those providers outside Sri Lanka, for example in the United States.

The Act allows personal data to be transferred out of Sri Lanka only under the conditions it sets. We transfer information out of Sri Lanka only where the Act permits it, and only to the providers named in this policy.

10. Cookies

We use only cookies that are needed for the service to work. We do not use analytics, advertising or tracking cookies, and we do not store information in your browser's local storage.

• hil_session keeps you signed in. It lasts up to 14 days, and you are signed out sooner after a period of inactivity.
• hil_profile remembers which profile (yours or a family member's) you are viewing.
• hil_form_session protects forms against misuse and carries one-time messages such as "Saved". It ends when you close your browser.
• hil_pending_auth and hil_social_pending remember a sign-in or registration that is waiting for its email code, for up to 15 minutes.
• hil_admin_session is used only by our staff on the administration pages.

These cookies cannot be read by scripts on the page and are sent only over a secure connection. Because they are strictly necessary, we do not ask for cookie consent. If you block them, you will not be able to sign in.

11. How we protect it

We take the following measures:

• All connections to the site are encrypted (HTTPS).
• There are no passwords to steal. You sign in with a single-use code sent to your email, and the number of attempts is limited.
• We store only a scrambled (hashed) form of your sign-in session, so a copy of our database alone cannot be used to sign in as you.
• Each record is tied to its account, and every request is checked against the account that is signed in.
• Uploaded documents are kept outside the public part of the website and are only given to the signed-in owner.
• The security record of sign-ins and changes cannot be changed or deleted through the database.
• Staff use separate administrator accounts with limited roles.

What we do not do yet: the information in our database is not separately encrypted inside the database; it relies on the security of the hosting account. The service runs on shared hosting rather than on a dedicated server. No online service can be made completely secure, and we cannot promise that your information will never be accessed without permission.

You can help by keeping your email account secure, not sharing your sign-in codes, and signing out on shared devices.

12. How long we keep it

• Your record is kept for as long as your account exists.
• Records you remove. When you remove an entry in the app, it is hidden from you and from your Doctor View, but it is not erased. We keep it, together with a history of what it said before and after each change, so that a mistaken removal can be undone and so there is an honest record of changes.
• Documents you remove stop being available to you, but the file itself is not deleted from our storage.
• Security records are kept and cannot be altered. No end date for them has been set yet.
• Sign-in codes and sessions are deleted by a scheduled clean-up after they expire.
• Contact form messages are kept until two years after our last reply.

A full retention schedule, saying how long each kind of information is kept after an account closes and how backups are handled, has not been written yet.

13. Your rights

Under the Act you have the right to:

• Access your information. Everything you have entered is visible to you in the app, and you can show or print your Doctor View or visit summary. You can also ask us for a copy of what we hold about you.
• Correct your information. You can edit your entries yourself at any time, or ask us to.
• Withdraw consent. You can stop adding information, remove entries, or ask us to stop processing your information. Withdrawing consent does not affect processing that already took place.
• Ask us to erase your information, subject to any law that requires us to keep it.
• Object to, or ask us to review, a decision about you made only by automated means. The service does not make such decisions about you.
• Complain to the Data Protection Authority of Sri Lanka if you think we have not handled your information lawfully.

To exercise any of these rights, use the contact form and choose "Privacy and data request", or write to our data protection officer (section 16). We may need to confirm your identity before acting. We will reply within the time the Act allows.

There is no button in the app yet to close your account, download all your information, or permanently erase it. These requests are handled by our staff. Removing an entry in the app hides it but does not erase it (section 12). A permanent erasure process is still being built.

14. Children and family profiles

You must be 18 or over to create an account.

An account holder can add family profiles for people they care for, such as a child or an older parent. By adding one, you confirm that you have the right to do so: as the parent or legal guardian of a child, or with the agreement of an adult you are helping. Family profiles are only visible to the account that holds them.

For a child under 16, the only identity number the service accepts is the SL-UDI, which is issued at birth registration.

When someone on a family profile turns 18, the account holder is reminded and can send them an invitation by email. When they accept it, their profile, with its full history, moves into their own account, and the person who held it before no longer has access to it.

15. If something goes wrong

If a personal data breach happens that puts your information at risk, we will notify the Data Protection Authority and tell you, as and when the Act requires, and explain what happened and what we are doing about it.

If a breach of your personal data is likely to put you at risk, we will tell you, and the Data Protection Authority, as the Act requires.

16. Contacting our data protection officer

Our data protection officer can be reached at dpo@example.com.

For anything else, use our contact form or write to support@example.com.

17. Changes to this policy

Every version of this policy has a version number and an effective date, shown at the top of this page, and we keep every earlier version. When we make a change that matters, we will tell you in the app or by email before it takes effect.

The service does not yet ask existing users to accept a new version. It records only the version accepted when the account was created.