PD NEUROTECHNOLOGY LTD – PHYSICIAN PRIVACY POLICY (LAST UPDATED: 23 MAY 2019)
We are committed to ensuring the security of your personal data and protecting your privacy. This policy will inform you as to how we look after your personal data when you use our app and our service. It will also tell you about your privacy rights and how the law protects you.
Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it.
INTRODUCTION
1. WHO WE ARE
PD Neurotechnology Limited is a limited company incorporated in England. Our company number is 09801981, and our registered office is at 5th Floor, 2 More London Riverside, London, United Kingdom, SE1 2AP.
When we refer to "PDN, "we", "us" or "our" in these terms, we are referring to PD Neurotechnology Limited. We are the "controller" in relation to the personal data you provide to us, which means we determine the purposes and the way in which your personal data is, or will be, processed and are responsible for it.
CONTACT
2. HOW TO CONTACT US
Questions, comments and requests regarding this policy are welcomed. You may either use our contact form to get in touch with us or you may write to our Data Privacy Officer at:
- Email: dpo@pdneurotechnology.com or
- Address: 5th floor, 2 More London Riverside, London United Kingdom SE1 2AP.
ABOUT
3. ABOUT OUR SERVICE
We are a medical solutions tech company that has developed a device and connected app to help people suffering with Parkinson's disease, their caregivers, and their physicians (our " System "). Our System enables you, as their physician, to access our application and website portal (the " Website ") to view a summary of the information uploaded by your patient, or their caregiver, and to view symptom reports located at pdmonitorapp.com. In order for you to be able to access our Website you must first complete our online training program which is available at www.pdneurotechnology.com/academy (the " Portal ").
PURPOSE
4. PURPOSE OF THIS PRIVACY POLICY
This privacy policy aims to give you information on how we collect and process your personal data so that you can be confident when you use our Website and Portal that you know what your personal data is being used for and that it is being kept safe.
It is important that you read this privacy policy together with any other privacy notice or fair processing notice we may provide on specific occasions when we are collecting or processing personal data about you, so that you are fully aware of how and why we are using your data. This privacy policy supplements the other notices and is not intended to override them.
LINKS
5. THIRD PARTY LINKS
You should be aware that our Website and Portal may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our Website and Portal, we encourage you to read the privacy notice of every website you visit or use.
COLLECTION
6. HOW IS YOUR PERSONAL DATA COLLECTED?
We use different methods to collect data from and about you including through:
| Direct interactions | You may give us your personal data by contacting us to register for an account, when you report a problem with our Website and Portal and by corresponding with us in person, by email, by phone, by post or otherwise. |
| Automated technologies or interactions | As you interact with our Website and Portal, we may automatically collect personal data. We collect this personal data by using cookies and other similar technologies. Please see below on Cookies (Section 13) for further information. |
| Third parties or publicly available sources | We may receive personal data about you from various third parties and public sources. This includes the medical practice or other health care provider which you work for. |
INFORMATION
7. WHAT INFORMATION DO WE COLLECT ABOUT YOU?
| Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data). |
We may collect and process the following different kinds of personal data about you:
| Contact data: | includes full name, email address, postal address and/or telephone number |
| Website and Portal sign-up data: | includes your email address, username, password and any other information you provide to us when you register to use our Website and Portal |
| Physician data: | includes registration number, educational details, qualifications and credentials |
| Correspondence data: | includes information submitted to us via our Website and Portal and details of any correspondence between you and us |
| Assessment data: | includes the answers to questionnaires you provide to us when you use the Portal and which we use to assess you |
| Marketing data: | includes your preferences in receiving marketing from us and your communication preferences |
| Technical data: | includes internet protocol (IP) address |
If you want any further information about how we might collect or use your personal data, please contact us (see Section 2).
PROCESSING
8. HOW DO WE USE YOUR PERSONAL DATA?
We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:
|
-Where we need to perform the contract we have entered into with you or to take steps at your request prior to entering into a contract (e.g. when you register to use our Website). -Where we have your prior consent to use your personal data (e.g. where you have consented to receiving marketing). -Where we need to comply with a legal or regulatory obligation. -Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests. |
We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.
Please note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us (see Section 2) if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.
| Purpose/activity | Type of data | Lawful basis for processing |
|---|---|---|
| To register you as a physician on the Website and Portal | Contact data, Website and Portal sign-up data, Physician data, Assessment data and Technical data | Necessary for our legitimate interests - to provide our service |
| To provide our service (i.e. to enable you to view your patient's reports and information) | Contact data, Website and Portal sign-up data and Technical data |
To comply with our legal obligations
Necessary for our legitimate interest - to provide our service |
| To manage our relationship with you. This includes responding to any questions you may ask us; notifying you of changes to the Website and Portal; notifying you of any updates to any contractual terms, privacy policies and other relevant information | Contact data and Correspondence data |
To comply with our legal obligations
Necessary for our legitimate interests - to run our business and provide our service |
| To identify and fix problems if they arise during your use of the Website and Portal | Contact data | Necessary for our legitimate interests - to run our business |
| To send you promotional or marketing materials and contact you about informative and/or commercial content (e.g. new features and services) | Contact data and Marketing data |
Necessary for our legitimate interest - in developing and growing our business
Consent |
|
To use cookies to operate and customise our Website and Portal, including to:
-identify when you use our Website and Portal -recognise you when you return to our Website and Portal (e.g. we may show you relevant content or provide functionality you used previously) -store information about your Website and Portal preferences |
Technical data |
Necessary for our legitimate interests - to operate our Website and Portal and to improve user experience
Consent |
| To use cookies to track how you arrived at our Website and Portal to ensure we are reaching you where and when you need us | Technical data and Marketing data | Consent |
We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us (see Section 2).
If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the lawful basis which allows us to do so.
Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
DISCLOSURE
9. DISCLOSURE OF YOUR INFORMATION
We may have to share your personal information for the purposes set out above with the following third parties:
| Third party | Details |
|---|---|
| Medical practice: | includes the medical practice or other health care provider you work for. |
| Service providers: |
including those who provide:
-Webhosting, IT and system administration services -Metrics and analytics -Marketing services. |
| Professional advisers: | including lawyers, bankers, auditors and insurers who provide consultancy, banking, legal, insurance and accounting services. |
| Authorities: | including regulators and other authorities who require reporting of processing activities in certain circumstances. |
| Corporate partners: | includes third parties who may invest in our business or to whom we may choose to sell, transfer, or merge parts of our business or our assets. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy notice. |
We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.
TRANSFERRING
10. INTERNATIONAL TRANSFERS
Although we don’t currently use any service providers outside of the EU, some of our external third parties may, from time to time in the future, be based outside the European Union (EU). If that happens then their processing of your personal data will involve a transfer of data outside the EU.
If we transfer your personal data out of the EU, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:
- The country has been deemed to provide an adequate level of protection for personal data by the European Commission. For further details, see European Commission: Adequacy of the protection of personal data in non-EU countries.
- If we use certain service providers based outwith the EU, we may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe. For further details, see European Commission: Model contracts for the transfer of personal data to third countries.
- If we use providers based in the US, we may transfer data to them if they are part of the Privacy Shield which requires them to provide similar protection to personal data shared between the Europe and the US. For further details, see European Commission: EU-US Privacy Shield.
- In any other case, we will obtain your explicit consent before any transfer takes place.
SECURITY
11. DATA SECURITY
We have put in place appropriate security measures in accordance with industry best practice to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know.
All information you provide to us is stored on secure servers. Where we have given you (or where you have chosen) a password which enables you to access our Website and Portal, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.
DURATION
12. HOW LONG WE STORE YOUR DATA FOR
We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.
To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.
Below we set out the key retention periods. Further details can be obtained by contacting us (see Section 2).
| Data type | How long will you keep my data? |
|---|---|
| Contact, Website Portal, Physician, and Correspondence data | 10 years from the last use of the App. You can at any time request the deletion of all your Contact, Website Portal, Physician, and Correspondence data. |
| Assessment data | 10 years from the last use of the App. You can at any time request the deletion of all your Assessment data. |
| Marketing data | 12 months from the last use of the App. You can at any time request the deletion of all your Marketing data. |
| Technical data | 2 years from the last use of the App. You can at any time request the deletion of all your Technical data. |
Where we anonymise your personal data (i.e. so that it can no longer be associated with you) for further research or statistical purposes, then we may use this information indefinitely without further notice to you.
COOKIES
13. COOKIES
Our Website and Portal uses cookies to help it function and to improve it. Cookies are small files saved to the user's device that track, save and store information about the user's interactions and usage of the Website and Portal. For information about the cookies we use, please see our Cookie Policy available at: pdmonitorapp.com/cp.
RIGHTS
14. YOUR RIGHTS
Under certain circumstances, you have rights under data protection laws in relation to your personal data. Please read through the table below to find out more about these rights.
| Your right | What this means |
|---|---|
| Access to your information | You have the right to ask for a copy of the information which we hold on you (commonly known as a 'data subject access request'). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it. |
| Correcting personal data |
You have the right to request that we correct personal data that we hold about you. This enables you to have any incomplete or inaccurate information we hold corrected, though we may need to verify the accuracy of the new data that you provide to us.
It is important that the personal data we hold about you is accurate and current, so please keep us informed if your personal data changes during your relationship with us. |
| Deleting personal data |
You may ask us to delete or remove personal data where there is no good reason for us continuing to process it. This is more commonly known as the 'right to be forgotten'. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law.
Please note, however, that we may not always be able to comply with your request to delete or remove personal data for specific legal reasons which will be notified to you, if applicable, at the time of your request. |
| Objecting to processing |
You have the right to stop us processing your personal data for direct marketing purposes. We will always inform you if we intend to use your personal data for such purposes, or if we intend to disclose your information to any third party for such purposes. You can usually exercise your right to prevent such marketing by checking certain boxes on the forms we use to collect your data. You can also exercise the right at any time by contacting us (see Section 2).
You may also object to us processing your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms. |
| Restriction of processing |
This enables you to ask us to suspend the processing of your personal data in the following scenarios:
-if you want us to establish the data's accuracy; -where our use of the data is unlawful but you do not want us to erase it; -where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or -you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it. |
| Transferring your personal data |
In certain circumstances, you may request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format.
Please note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you. |
| Withdrawing consent | Where we are relying on consent to process your personal data you can withdraw your consent at any time. Please note that this will not affect the lawfulness of any processing carried out before you withdraw your consent. |
| Review by an independent authority | You will always have the right to lodge a complaint with a supervisory body. The relevant authority in the UK is the Information Commissioner's Office. If you do have a complaint, we would appreciate the chance to deal with your concerns before you approach the ICO, so please do contact us (see Section 2) in the first instance if possible. |
Where we anonymise your personal data (i.e. so that it can no longer be associated with you) for further research or statistical purposes, then we may use this information indefinitely without further notice to you.
CHANGES
15. CHANGES TO OUR PRIVACY POLICY
This version was last updated on 23 May 2019. Historic versions of this policy can be obtained by contacting us (see Section 2).