Please review the privacy policy for your country:

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Introduction

At myrecovery we are dedicated to improving the lives of more people with musculoskeletal disease by evolving their care and treatment. We bring together patients, healthcare providers, academia, life science companies and regulators to evolve musculoskeletal care and treatment; combining the most advanced technology, data-driven knowledge and our expertise in musculoskeletal disease.

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We are committed to protecting your personal data and respecting your privacy. Transparency and clarity are important for us and we want you to feel in control of and understand how we handle your personal data. We appreciate that you do not want your personal data distributed indiscriminately and in this policy we explain how we collect information, what we do with it and what rights you have in relation to your personal data.

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We may revise this policy from time to time and will notify you if we are making any significant changes. This Privacy Policy was last updated on 03 June 2025.

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Please read this policy carefully so that you understand the terms and how they apply to you.

If you have any questions about how we process your information, please do not hesitate to get in touch by contacting us at dpo@myrecovery.com

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Important information and who we are

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This is the Privacy Policy for the https://www.myrecovery.com/ website (Site), any mobile application we provide (App) and any online dashboard portal that accompanies an App (Dashboard) (together, the Services). The Services are operated by or on behalf of HOPCo Ltd. (trading as myrecovery) (we, us and our). HOPCo Ltd. is a company registered in England and Wales with company number 09336986 and having its registered office at 3rd Floor, 1 Ashley Road Altrincham Cheshire WA14 2DT, United Kingdom.

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For the purposes of the General Data Protection Regulation (GDPR), when you access our Services we are acting as the data controller (this is a legal term that describes a person or entity that controls the way your data is used and processed). We are registered under the Data Protection Act 2018 with the Information Commissioner’s Office (the UK data protection regulator). Our registration number is ZA230517 and can be viewed online at www.ico.org.uk. You can also access useful guidance and information about your rights in relation to your personal data on that website.

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By accessing or using the Services you acknowledge and consent to the collection and use of information in accordance with this Privacy Policy, our Terms of Service (either our Terms of Service for App and Site Users or Terms of Service for Dashboard Users, as applicable to you), together with our End-User Licence Agreement (EULA) and any additional terms of use incorporated by reference into the EULA. By accessing our Services you agree that we may treat your information as set out in this Privacy Policy. If you do not agree with any of the terms of this Privacy Policy, our EULA or Terms of Service, you should refrain from using our Services.

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Please take the time to read and understand how this policy applies to you, according to the different categories of user described below and referred to throughout this document:

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• as a Patient, who has been referred by a charitable organisation or your surgeon, doctor or other healthcare professional to download and use the App as part of your care and recovery process pre- or post- treatment, or invited to use the App as part of your involvement in a clinical study or research project;
• as a Healthcare Professional User (HCP), being an individual who accesses the App and Dashboard in your capacity as a person responsible (whether as a surgeon, doctor or other healthcare professional) for the medical care and treatment of Patients, and with permission from those Patients to monitor such activity and other medical data as they may submit to the App in order to inform their care pre- and post- treatment, or as a person administering a clinical research trial or study involving consenting App users for medical and device research purposes;
• as a Healthcare Administrator, being an individual or entity responsible for the management and oversight of a healthcare institution and its HCPs, or an employee of a healthcare organisation, and who is a registered user of the Dashboard for the purposes of managing and/or supporting HCPs engaged in medical care and treatment, as well as viewing practice summaries and statistics for your clinical practice, or being an administrator involved in a clinical study or research project; or
• as a Partner, being an entity (or individual acting on behalf of an entity) involved in research and development relating to the treatment of diseases, including the improvement of existing technologies and development of new technologies, to improve the treatment and care of patients and support patient safety, and who is a registered user of the Dashboard in order to access information relating to Patients pre- and post- treatment of health conditions and diseases and the use and effectiveness of medical devices or medication used by surgeons, doctors and other healthcare professionals as part of treatment.
• We reserve the right to change this Privacy Policy from time to time by changing it on the Site or by updating the App or Dashboard.

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Information we may collect from you

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Personal data, or personal information, means any information about an individual from which that person can be identified (Personal Data). It does not include data where sufficient information has been removed or randomised such that an individual can no longer be identified directly or indirectly (Anonymous Data).

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We collect information about you if you:

• register with or use our Site;
• download and use our App; or
• access our Dashboard.

We may collect, use, store and process the following different kinds of Personal Data about you that you submit through your use of the Services:

• Identity information including your first and last names, date of birth and gender that you provide by completing forms on the Site, the App or the Dashboard, including if you register as a user of the Services, upload or submit any material via the Services, or when you request any information;
• Contact information including your email address and telephone numbers;
• Login information including information in connection with an account sign-in facility, such as your login and password details; and
• Technical information including additional data which, when you access the Services we may (like most modern websites and online applications - for more information, please refer to the ‘All About Cookies’ website), by means of cookies and/or other similar technologies, automatically collect about you – such as the type of internet browser or mobile device you use, any website from which you have come to the Site, your IP address (the unique address which identifies your computer or mobile device on the internet) and/or the operating system of your computer or mobile device. See the Cookies & other technologies section for more information.

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If you are a Patient:

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By providing us with additional information about you and your recovery, we are able to provide better and more personalised services and information to you and the healthcare professionals responsible for your treatment, and as a result your healthcare professional will be able to better tailor the care to your individual needs. We may collect the following additional data (including medical data):

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• Treatment-specific Health information including information about your surgery or treatment, including pre- and post- treatment care information, such as the dates and details of your treatment, the type of medical device you have received and the details of that device, and the details of your healthcare team;
• Other Health information including data relating to you, your treatment, and how your recovery is progressing, including pain scores, exercise compliance data, and responses to surveys and questionnaires, as well as any other content that you choose to create and post or upload to the App (which may include videos, photographs, audio, messages or other materials);
• Third-party Health App data including data collected where, if you install the App on to an Android or Apple device which has the respective Google Fit or HealthKit features enabled, we will request access to third-party health app data such as your exercise and fitness level through your device. You will be prompted by your device to allow access the first time this content is requested by us and, even if you grant us access, you can stop this access at any later point by changing the settings on your device. You are under no obligation to provide this information. However, if you should choose to withhold requested information, this may reduce our ability to provide you and your healthcare team with information on your recovery from treatment;
• Communication and App Usage information including details of any communications you send to us, for example to report a problem or to submit queries, concerns or comments regarding the Services or content made available through the Services; information from videos you have watched or surveys that we may, from time to time, run on the Services for research purposes, if you choose to respond to, or participate in, them; and
• Location information including information provided by your device to enable us to show you content that is local to you and to help authenticate the use of the Services. We may approximate your location from your device using the GPS connection information used by your device to help your healthcare team understand your recovery from treatment, for example to understand your activity levels. Where we collect location data via the App, we will always prompt you about sharing your location and you can disable location sharing at any time through the settings of your device.

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If you are a HCP, Healthcare Administrator or Partner, we may collect the following additional data (the below categories of information are not collected from Patients):

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• Employee information including Identity Information and Contact Information of your employees. You should properly inform your employees on the processing of their personal data according to the provisions of the GDPR.
• Practice information including data relating to the management of a healthcare organisation, such as performance assessments and ratings, number of patient registrations, staff and patient demographic information, and number and type of treatments offered and patient outcomes.

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Anonymised Data

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We also collect, use and share anonymised data about our users pre- and post- treatment, such as statistical or demographic data, in order to help us and the third parties we collaborate with to improve existing technologies and develop advanced new technologies to improve the treatment and care of patients and support patient safety.

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Anonymised data could be derived from your de-identified personal data having been combined with a pool of data from of other users of our Services, but is not considered personal data as it has been sufficiently anonymised such that it cannot be used to directly or indirectly reveal your identity. For example, we may anonymise your data by aggregating your non-identifying data with that of other Patients, including:

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• your usage data to calculate the percentage of users accessing a particular feature of the App to inform how we develop and improve our products;
• any pain score and Third-party Health App data you provide following treatment to help HCPs, Healthcare Administrators and our Partners assess the effectiveness of that treatment, calculate average recovery times and better understand the recovery process;
• any information you provide in relation to the function of medical treatments, devices, in order to deliver research information to third-party organisations who we collaborate with, to help them understand how well their devices, treatments or therapeutics are functioning and how they could be improved to inform and advance the development of more effective and safer treatments for patients; to produce statistical data for research purposes including for use and reference in connection with clinical studies, scientific articles, medical conferences and health reports; and to develop, train and improve analytical healthcare systems based on machine learning or artificial intelligence technologies.

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How is your personal data collected?

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We use different methods to collect data from and about you, including through:

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• Direct interactions: you may provide us with your identity and contact details when you register to use our Services. You may provide further data by submitting information to the App or Dashboard, responding to surveys or providing feedback.
• Automated technologies or interactions: when you interact with our Services, we will automatically collect technical data about the device you are using, your browsing actions and patterns and (if you enable location sharing) your location data, using cookies or other similar technologies (explained further below).
• Integration with third-party health apps: if you choose, when prompted, to grant the App permission to access other health or fitness related applications installed on your device, we may access and use your Third-party Health App data collected by those third-party applications, as defined above. You may disable such permissions at any time in your device settings and/or via the relevant third-party application.

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How we use your Personal Data and purposes for processing your data

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We take the protection of your personal information very seriously and will only ever use your Personal Data lawfully and in accordance with the requirements of Data Protection Legislation.

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Common legal grounds for processing your data:

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The most common purposes for which we use your personal data and the legal grounds on which we do so are as follows:

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• to enable us to perform our contract we have entered into or are about to enter into with you to provide you with the services and information offered through the Site, App and Dashboard (as applicable), subject to our EULA and Terms of Service with you, and to improve those services;
• where it is necessary for our legitimate interests (or those of a third-party) as a commercial organisation for the purposes of managing and planning our business, and your interests and fundamental rights do not override those interests, in which case we may (keeping our information secure at all times and in a way that is proportionate and respects your privacy rights) use your personal information which we collect in the course of running and/or improving our business and developing new products and services, including to:
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  • audit the downloading of the App and data from the Services;
  • improve the layout and/or content of the pages of the Site, App and Dashboard and customise them for users;
  • identify visitors to the Site and/or users of the Dashboard and App;
  • conduct analysis and carry out research to further and improve medical care and treatment of health conditions and diseases;
  • analyse aggregated and anonymised outcome data to provide recommendations on patients journeys and develop technology to automate guidance;
  • forecast demand of service and to understand other trends in use, including which features users use the most and find the most helpful, and what features users require from us. This does not involve making any decisions about you - it is only about improving the Services we deliver to you and other users. Strict confidentiality and data security provisions will apply at all times;
  • troubleshoot bugs within the Services; and
  • troubleshoot and help you with any questions/enquiries; or
  • where we need to comply with a legal or regulatory obligation.

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Legal grounds for processing Special Category Data:

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Due to the nature of our Services, if you are a Patient accessing the App we will collect and process certain types of data about you which are classified by law as being Special Category Data. This includes information about your health and other medical data, which we collect in order to effectively provide our Services to you. In order to lawfully process such data, we will only do so where one of the following conditions applies:

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A. Where necessary for the purposes of preventative or occupational medicine, medical diagnosis, the provision and management of healthcare and treatment

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As necessary for reasons of public interest in:

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• preventative or occupational medicine;
• medical diagnosis;
• the provision and management of healthcare and treatment; or
• the management of healthcare systems,

we may process your Special Category Data in order to facilitate the delivery and improvement of the treatment delivered by HCPs and Healthcare Administrators who use our Services (at all times, where applicable and appropriate, having taken suitable measures to safeguard your fundamental rights and interests through the irreversible anonymisation of your data).

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B. Where necessary for reasons of public interest to ensure high standards of quality and safety of healthcare and medical devices

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Where necessary for reasons of public interest in the area of public health to ensure high standards of quality and safety of healthcare and medical devices, we may process your Special Category Data for the purposes of advancing research and understanding of the effectiveness of treatment of medical conditions and disease progression by ourselves and our Partners (at all times, having taken suitable measures to safeguard your fundamental rights and interests, including through the irreversible anonymisation of your data where appropriate).

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C. You have given your explicit consent to such processing of your personal data

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Where neither of the grounds set out in A or B above applies, and where you have consented to the processing, we will also use your personal data to:

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• provide your surgeon, doctor or other health professional with information about the progress of your recovery and treatment, for example, survey scores or symptom surveys; or
• to (always having removed personal identifiers, such as your name, address and contact details) improve our healthcare products and services, and our artificial intelligence systems, so that we can deliver better healthcare to you and other users, and further research into care and disease progression. This does not involve making any decisions about you - it is only about improving our products, services and software so that we can deliver a better experience to you and other users, and help achieve our aim of making healthcare affordable and accessible to everyone. Strict confidentiality and data security provisions apply at all times.

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No General Marketing to Patients

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For Patient users, to help the surgeon, doctor or other healthcare professionals involved in your care to better track your progress pre- or post- treatment, we may contact you via email, over the phone or through the App, requesting you to fill out a survey or answer questions about your treatment and recovery progress. We may still contact you, even if you uninstall the App. Please note, we will only contact you with information related to your treatment and use of the Site and App, including to share articles, referrals or other content related to your treatment which we think would be of particular interest to you. We will not, without your express opt-in permission, use it to send you general marketing emails on behalf of third-parties.

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Purposes for which we will use your Personal Data

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When processing your personal data, we will always rely on one or more of the following lawful grounds:

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Ground 1: It is necessary in order for us to perform a contract we have entered, or are about to enter, into with you (such as our EULA, to provide the services made available through the App).

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Ground 2: It is necessary for our legitimate interests (or those of a third-party) as a commercial organisation for the purposes of managing and planning our business and your interests and fundamental rights do not override those interests.

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Ground 3: You have provided your express consent to the processing of your personal data for the relevant specified purpose.

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Ground 4: It is necessary for the purposes of preventative or occupational medicine, medicinal diagnosis or the provision and management of healthcare and treatment.

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Ground 5: It is necessary for reasons of public interest to ensure high standards of quality and safety of healthcare and medical devices.

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Ground 6: It is necessary for the purposes of complying with a legal or regulatory obligation.

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The table below sets out in more detail some examples of the types of personal data that we will collect, examples of the purposes for which it will be used and on which of the above legal bases we rely (on a non-exhaustive basis):