Privacy Notice for Healthcare.Anywhere.
This Privacy Notice explains how Healthcare. Anywhere. ("HCA", "we", "us" and "our") collect, store, process and use personal information ("Personal Data") that you provide to us, or that we may otherwise obtain or generate, which relates to you.
Please take a moment to review this Privacy Notice and, if you have any questions, feel free to get in touch via one of the methods set out under the header "Contact Us" below.
Scope of this Notice
The "Healthcare. Anywhere." mobile application (herein the "App") is intended to provide you with immediate access to information and other support to help you manage your health in partnership with care providers.
The "Healthcare.Anywhere." website (herein the "Website") is provided as a source of general information about our company and offering.
What personal information do we collect?
The personal information that we may collect and store through your use of the Website and App includes:
- The email address you provide when registering an App account;
- Data entered into your sub-app such as symptom tracking and medication administration dates;
- Technical information, such as: information about the device you use to interact with the App (including the unique device identifier, hardware model, operating system and version, and mobile network information);
- Activity data, such as which sections or features of the App you access and use;
- Data provided for technical support or responding to requests for information or support via the Contact Us section of the Website and App.
We may also collect additional information about your health status in order to comply with pharmacovigilance or adverse event reporting obligations. For example:
- If you inform us about a health condition you are experiencing.
- If you report that you have experienced a side effect associated with a medicine you are taking.
- Where health information can be inferred from information that you have provided.
How do we collect and store your personal information?
Any personal information you enter into the App whilst using its features will be collected and stored on your device and also on data servers located at a dedicated data centre that is managed by HCA.
Healthcare.Anywhere. hosts and manages the App to provide technical and administrative support. The data is stored to enable the data entered onto the App to be backed up and subsequently recovered should a user lose the device which their App is on and to enable users to log into their version of the App and view their data on multiple devices. Your Personal Data may be used to gain insight and determine improvements to the functionality of the App, it may also be used to help your healthcare professional make more informed decisions about your treatment.
Sponsors. HCA provides the sponsor companies with general statistical information about the App but will not provide them with any personal data or information including any data that identifies you directly such as your name or contact details. This general statistical information will be aggregated and anonymised and can help us gather insights to improve the App and may also be used to help your healthcare professional make more informed decisions about your treatment.
We may also collect your personal information through providing technical support or responding to requests for information or support via the Contact Us section of the App.
Why do we store your personal information online?
Your personal information that is entered into the App is stored to enable it to be backed up and subsequently recovered should you lose your device. This also enables your personal information to be viewed on more than one device (e.g. a smart phone, tablet or PC).
How do we use your personal information?
We may use your personal information in a number of ways:
- To respond to you; where you submit Personal Data, we may use that information to contact you by email, phone or mail as you indicated to provide you with information you have requested or answer a question.
- To determine how the functionality of the App might be improved; your personal data may be used to generate aggregated and anonymised reports to help us gather insights on the App usage in order to tailor future HCA offerings based on the existing user base and the features available. We may also reach out from time to time to gather feedback to determine how the functionality of the App might be improved.
To provide sponsors with general statistical information about the App. Please note that information supplied to sponsors will use anonymised data that will not include your personal details so you cannot be identified.
- To provide limited information (e.g. initials and date of birth) to sponsor companies to enable the recording of adverse events and the monitoring of drug safety.
On what basis do we use your personal information?
- For legitimate business purposes: Using your personal information helps us to operate and improve our business and minimise any disruption to the services that we may offer to you. It also allows us to make our communications with you more relevant and personalised to you, and to make your experience of our products and services an efficient and effective one.
- To comply with our legal obligations and other demands for information: Compliance with laws, regulations, rules, codes and guidance is important to us, and we would want to be able to comply with these, as well as the other requests or demands for data as set out here. They affect the way in which we run our business, and they help us to make our products and services as safe as we can. Where we use your personal information for this purpose, rest assured that where possible we will take measures to protect your personal information.
- Your consent: At times we may need to get your consent to allow us to use your personal information for one or more of the purposes set out above. See the Your rights section for information about the rights that you have if we process your information on the basis of your consent.
How do we protect your personal information?
Your personal information is protected according to the General Data Protection Regulation (GDPR) and Data Protection Act (DPA) 2018.
Compliance with laws, regulations, rules, codes and guidance is important to us, and we do all we can to ensure we comply with these, as well as the other requests or demands for data as set out here. They affect the way in which we run our business, and they help us to make our products and services as safe as we can. Where we use your personal information for this purpose, rest assured that where possible we will take measures to protect your personal information.
How will your personal information be shared?
Your information will only be shared with the parties named above for the purposes set out above. We will not share your personal data with anyone else, unless required to by law or under pharmacovigilance or adverse event reporting obligations.
Transfer of your personal information to another country
We may transfer your personal information to another country in the EU or EEA. If this should occur, your personal information will be protected by the same data privacy laws according to the UK GDPR.
How long will we keep your personal information?
HCA retains your personal information no longer than necessary for the purpose for which it was processed for the duration of our relationship with you unless a longer period is required to comply with applicable laws. Retention periods may vary depending on the purpose for which the personal information was collected and used.
We have a records retention policy that sets out how long we keep your personal information. As a general rule, we keep your personal information for as long as required (a) to comply with the law, (b) in connection with any legal action or an investigation involving HCA or (c) to provide you with information about or access to our digital channels (e.g. websites), products or services that you have requested.
How secure is your personal information?
We take seriously our responsibility to protect your personal information. As such, we use appropriate privacy and security controls and processes that are designed to help protect and safeguard your information.
Users should exercise caution to protect any personal information stored on their mobile phone or other device through the use of passwords and other controls such as phone timeout.
You are entitled to:
- opt out from processing of your personal information for direct marketing purposes (where you have previously opted in);
- ask HCA about the processing of your personal information, including to be provided with a copy of your personal information;
- request the correction and/or deletion of your personal information;
- request the restriction of the processing of your personal information, or object to that processing;
- withdraw your consent to the processing of your personal information (where HCA is processing your personal information based on your consent);
- request receipt or transmission to another organisation, in a machine-readable form, of the personal information that you have provided to HCA; and
You may, should you feel it necessary, lodge a complaint with your local data protection authority at if you feel your privacy rights have been infringed.
What if you do not want to provide us with your personal information?
Where you are given the option to share your personal information with us, you can always choose not to do so.
If you choose not to provide us with your personal information, you object to our processing of your personal information or you choose to withdraw any consent that you may have provided to processing your information, we will respect such requests in accordance with our legal obligations.
This may mean, however, that we may not be able to perform the actions necessary to achieve the purposes set out above. HCA may be required or entitled to retain your information to comply with legal and regulatory obligations and to protect and exercise our legal rights and interests.
Links to other websites or Apps
We may provide links to websites or Apps that are covered by separate privacy policies and/or terms and conditions. This Privacy Notice does not apply to any other website or App. If you choose to use another website or App, please ensure you check their legal and privacy statements, so you understand their privacy policies.
Data Controller and Data Protection Officer
Under UK Data Protection Law and UK GDPR, a “data controller” is the legal entity that is responsible for determining the purpose and means of how your personal data is processed and helping you to exercise your data protection rights. HCA is a data controller in relation to Personal Data concerning the App and Website. You may contact the data protection officer (DPO) of HCA by email at firstname.lastname@example.org, or by post at York House Main Street, Ullesthorpe, Lutterworth, England, LE17 5BT.
Last updated: February 2021