Last updated March 8th, 2019
This policy and any dispute or claim arising out of or in connection with it or its subject matter (including non-contractual disputes or claims) shall be governed by and construed in accordance with English law. In the event there is a discrepancy between this English language version and any translated copies of the policy, the English version shall prevail.
We are committed to safeguarding the privacy of our Application users; this policy sets out how we will treat your information. Our Application is a browser based web-app but we may store files on your device (such as a mobile smartphone or desktop computer) which may access and transfer some of your information to our servers. We hereby request your consent to the use of these technologies. By using our Application and agreeing to this policy, you consent to our use of these technologies in accordance with the terms of this policy.
IF YOU DO NOT ACCEPT AND AGREE WITH THIS POLICY THEN YOU MUST NOT ACCESS OR USE THE WEB APPLICATION.
Please read this policy in conjunction with the Legal Information section. Any capitalised terms used but not defined in this policy shall have the meanings given to them in the Legal Information section.
1. WHAT INFORMATION DO WE COLLECT IF YOU REGISTER ON OUR APPLICATION?
The FollowApp care Application enables you to send data relating to your recovery after medical care to your medical practitioner – accordingly, it is important that you recognise that your use of it will necessitate us processing that data and sending it on to your chosen provider of care. The medical data that we process consists of the data that you choose to send to us (via your answers to surveys, questionnaires, etc) and any of your medical data that your care provider directs us to process in order to enable us to send relevant communications about your recovery to you.
We may collect, store and use the following kinds of information: information about your device and about your use of this Application (including your IP address, your device ID, geographical location, browser type and version, and operating system); information relating to any therapeutic care provided to you from your chosen providers of medical services (“External Services”) through your use of this Application, specifically information about your medical condition including your physical and/or mental state; information that you provide to us for the purpose of registering with us (including your name, mobile number, email, address, mobile phone provider or mobile data provider and other information you choose to provide); any other information that you choose to send to us.
If you use the Application as a medical professional, before you disclose to us any personal data which relates to another person, you (or your employer) must have obtained that person’s explicit consent to you processing that person’s data and engaging third parties to assist you in storing, recording and communicating it.
2. WHAT INFORMATION DO WE COLLECT FROM YOU IF YOU JUST VISIT OR DOWNLOAD OUR APPLICATION?
We don’t collect any personal information about visitors to our website or those who do not register to use the Application. If you do visit us without registering, we will place session ID cookies on your device. For more information about cookies generally, look at the answer to “What are ‘cookies’ and what ‘cookies’ do we use?” below.
3. WHAT INFORMATION DO WE COLLECT FROM YOU IF YOU’RE UNDER 18 (OR THE AGE OF MAJORITY IN YOUR JURISDICTION)?
You can only register to use our Application if you are over the age of majority in the country in which you reside. That means that we do not knowingly collect any information about (or market to) children, minors or anyone under the age of majority.
If we become aware that a child, minor or anyone under the age of majority has registered with us and provided us with personal information, we will take steps to terminate that person’s registration and delete their profile information from our Application. If we do delete a profile because you violated our no children rules, we may retain your email and IP address to ensure that you do not try to get around our rules by creating a new profile.
If you are a parent or guardian and you are aware that your child, under the legal age of majority, has provided us with personal information, please contact us.
4. WHAT INFORMATION DO WE COLLECT FROM YOU IF YOU CLICK ON A LINK TO OTHER SITES?
We have no control over, and assume no responsibility for the content, privacy policies or practices of any third party sites or services.
5. WHAT ARE ‘COOKIES’ AND WHAT ‘COOKIES’ DO WE USE?
Cookies do this by storing information about your preferences on your device, including the device model, manufacturer, screen resolution, device capabilities, service provider, country and city location data.
We use certain cookies, which we have set out below:
- Cookies which are strictly necessary and enable the Application to function correctly and deliver content. These cookies do not gather information about users that could be used for marketing or remembering sites that users have visited on the internet.
- Cookies which ensure Performance & Functionality and understand user preferences.
For more information about what cookies are and your rights to control cookies, please don’t hesitate to visit this great third party educational resource www.allaboutcookies.org.
6. USING YOUR PERSONAL INFORMATION
Personal information submitted to us via this Application will be used for the purposes specified in this policy or in relevant parts of the Application. We may use your personal information to:
- (a) administer the Application;
- (b) analyse and search for trends in the provision of therapeutic care;
- (c) improve your user experience by personalising the Application;
- (d) enable your use of External Services available on the Application;
- (e) send you general administrative (non-marketing) commercial communications;
- (f) send you email notifications which you have specifically requested;
- (g) send you our newsletter and other marketing communications relating to our business (if you have opted in);
- (h) provide third parties with statistical information about our users – but this information will not be used to identify any individual user and will be anonymised in accordance with applicable law;
- (i) deal with enquiries and complaints made by or about you relating to the Application;
- (j) verify and keep the Application secure and prevent fraud and ensure compliance with the terms and conditions governing the use of the Application.
Notwithstanding the above we will not, without your express consent, provide your personal information to any third parties for the purpose of direct marketing.
7. SHARING YOUR INFORMATION
We may disclose your personal information to any of our employees, officers, agents, suppliers or subcontractors insofar as reasonably necessary for the purposes set out in this policy and only in accordance with applicable law.
We may disclose your personal information to any member of our group of companies (this means our subsidiaries, our ultimate holding company and all its subsidiaries) insofar as reasonably necessary for the purposes set out in this policy, including in relation to international data transfers as set out below.
In addition, we may disclose your personal information:
- a) to the extent that we are required to do so by law;
- (b) in connection with any ongoing or prospective legal proceedings;
- (c) in order to establish, exercise or defend our legal rights (including providing information to others for the purposes of fraud prevention and reducing credit risk);
- (d) to the purchaser (or prospective purchaser) of any business or asset that we are (or are contemplating) selling under provisions of confidentiality;
- (e) to any person who we reasonably believe may apply to a court or other competent authority for disclosure of that personal information where, in our reasonable opinion, such court or authority would be reasonably likely to order disclosure of that personal information.
8. HOW DO WE PROTECT YOUR PERSONAL INFORMATION?
Information that we collect may, on rare occasions where such a transfer is necessary in order to maintain or repair the system which underlies the Application, be stored and processed in and transferred between any of the countries in which we operate (including those outside of the European Economic Area and/or outside of the jurisdiction in which you use the Application) in order to enable us to use the information in accordance with this policy.
By submitting your information, you agree to this transfer, storing or processing. We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this policy.
9. SECURITY OF YOUR INFORMATION
We will take reasonable technical and organisational precautions to prevent the loss, misuse or alteration of your personal information.
We will store all the personal information you provide on our secure (password and firewall protected) servers.
While we use SSL encryption to protect data in transit, you acknowledge that the transmission of information over the internet is inherently insecure, and we cannot guarantee the security of data sent over the internet.
You are responsible for keeping your password and other login details confidential. We will not ask you for your password (except when you log in to the Application). If you lose your password or give it out, your personal information may be compromised. If that happens, please use the “Forgot Password” button on the Application’s login page to change your password immediately. We cannot be held responsible for your failure to keep your password secure and failure to do so may violate the terms in our ‘Legal Information’ section.
10. POLICY AMENDMENTS
When we change the manner and purpose for which we process your personal information we will use all reasonable endeavours to obtain your consent.
11. YOUR RIGHTS
You may instruct us to provide you with any personal information we hold about you. Provision of such information may be subject to:
- (a) the payment of a fee; and
- (b) the supply of appropriate evidence of your identity (for this purpose, we will usually accept a photocopy of your passport certified by a solicitor or bank plus an original copy of a utility bill showing your current address).
We may withhold such personal information to the extent permitted by law. You may instruct us not to process your personal information for marketing purposes, by sending an email to us. In practice, you will usually either expressly agree in advance to our use of your personal information for marketing purposes, or we will provide you with an opportunity to opt out of the use of your personal information for marketing purposes.
12. THIRD PARTY CARE PROVIDERS
The Application uses the input of Third Party Care Providers and their practices. Where such individuals process your personal information through the Application they shall do so as data processors on our behalf. We are not responsible for fulfilling the lawful requirements of such individuals or their practices where they process your personal information for their own purposes.
13. UPDATING INFORMATION
Please let us know if the personal information which we hold about you needs to be corrected or updated.