Privacy Policy – App

Photo of Medsmart app on smartphone

Dated: 28th of March 2018

Scope of Policy

This Privacy Policy applies to your use of the App and the Service once you have downloaded or streamed a copy of the App onto your mobile device (“Device”).

This policy sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us.

For the purpose of the General Data Protection Regulation 2018, we, Talking Medicines, are the data controller.

Who we are

“Medsmart” is a brand name used by Talking Medicines Limited, a limited liability company registered in Scotland with company number SC447227, whose registered office is at 3rd Floor, 202 Bath Street, Glasgow, United Kingdom, G2 4HW (referred to in these Terms as “Talking Medicines”, “we” or “us”).

What personal information do we collect from you?

We may collect and process the following data about you:

– Submitted Information – this is information you give us about yourself or (where you have registered on behalf of a person you care for) a person you care for, when you register for the Service and when you use the Service. The information you give us may include, but is not limited to, your, or a person you care for’s, name, address, e-mail address and phone number, the Device’s phone number, age, username, password, personal description, photograph and other registration information. It will also include information on your, or a person you care for’s, specific medicine routine and the feedback information you provide to us in relation to your, or the person you care for’s, use of the App and Service.

– Device Information – this is the technical information we automatically collect from your Device when you use the App and the Service including the type of mobile device you use, a unique device identifier (for example, your Device’s IMEI number, the MAC address of the Device’s wireless network interface, or the mobile phone number used by the Device), mobile network information, your mobile operating system, the type of mobile browser you use, and time zone setting.

– Account Information – this is information on the use of your Account which relates to your use of the Service.

Cookies

Our App uses cookies to distinguish you from other users of our Service. This helps us to provide you with a good experience when you use the Service and also allows us to improve our App. We do not use cookies to collect any personally identifiable information. The cookies we use are “analytical” cookies (such as Mixpanel Mobile Analytics, Apple Analytics & Google Analytics). You can change your App settings to reject cookies at any time, although this may impair the functionality of our App.

What we do with the information we gather

We use any information held about you in the following ways:

– To help provide the Service;

– To send you push notifications with relevant information about the content of the App (you can change your settings to turn off such notifications at any time although this may impair the functionality of the App);

– To perform statistical analysis on data to identify patterns of medicine use behaviour (all anonymised data is owned by Talking Medicines and may be licensed to third parties commercially); and

– To administer our App and for internal operations, including troubleshooting, data analysis, testing, statistical and survey purposes;

– To maintain, protect and improve the App and/or the Service and to notify you about changes to either.

– Offline communications between you and the Company to better engage with you as a user and provide a better experience

– Provide the Service, including (but not limited to) customer service;

– Optimise your user experience of the Platform and/or the Service;

– Personalise your experience of the Platform and/or the Service (for example, your information helps us to better respond to your individual needs, e.g., we may use your information to serve you more tailored and relevant adverts based on your interests or usage of the Platform and/or the Service);

– Improve the Platform and/or the Service (we continually strive to improve the Platform and/or the Service based on the information we receive from you);

– Administer Platform and/or Service features or respond to your enquiries or requests;

– Send periodic communications and/or periodic personalised communications. If at any time you would like to unsubscribe from receiving future email communications, we include detailed unsubscribe instructions at the bottom of each email.

Storing your information

We store data for as long as it is necessary to provide services to you and others, personal data. Information associated with your account will be kept until your account is deleted, unless we no longer need the data to provide these services.

Deleting your account

You can delete your account any time. When you delete your account, we delete things you have inputted into the Medsmart App such as your medicines information, personal profile data and your reminder notifications. Information kept within sub folders in the Medsmart App will also be deleted. No further information from your account will be used, however, Talking Medicines reserves the right to use the aggregated data stored and gathered before this point as the act of anonymising and aggregating data de-personalises it. We are unable to retrieve specific details about individuals after completing this process.

To delete your account please contact [email protected] stating the following:

– Medsmart username
– E-mail associated with the username
– E-mail address you wish to be contacted on

We will delete your data within 28 days of your request.

Disclosure of your information

We may disclose your personal information to any member of our group, which means our subsidiaries, our ultimate holding company and its subsidiaries, as defined in section 1159 of the Companies Act 2006.

We may disclose your personal information to third parties:

– in the event that we sell or buy any business or assets, in which case we may disclose your personal data to the prospective seller or buyer of such business or assets;

– if Talking Medicines or substantially all of its assets are acquired by a third party, in which case personal data held by it about its customers will be one of the transferred assets;

– if we are under a duty to disclose or share your personal data in order to comply with any legal or regulatory obligation or request;

– in order to enforce or apply our Terms and/or other agreements or to investigate potential breaches; and in order to protect the rights, property or safety of Talking Medicines, our customers, or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction.

Where we store your personal data

The data that we collect from you may be transferred to, and stored at, a destination outside of the European Economic Area (“EEA”). It may also be processed by staff operating outside the EEA who work for us or for one of our suppliers. This may happen if any of our servers are from time to time located in a country outside the EEA, or if one of our service providers is located in a country outside the EEA. We may also need to share information between companies within our group which are located in other countries. If we transfer your information outside of the EEA, we will take steps to ensure that your rights continue to be protected.

In addition, if you use our Service while you are outside the EEA, your information may be transferred outside the EEA in order to provide you with the Service.

By submitting your personal data, you agree to this transfer, storing or processing.

Where you have chosen a password that enables you to access the Service, you are responsible for keeping this password confidential.

All information you provide us is stored on our secure servers. We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this Privacy Policy.

Your rights

You have the right to ask us not to process your personal data for marketing purposes.

Our App may, from time to time, contain links to and from the websites of our partner networks, advertisers and affiliates (including, but not limited to, websites on which the App or the Service are advertised). If you follow a link to any of these websites, please note that these websites and any services that may be accessible through them have their own privacy policies and that we do not accept any responsibility or liability for these policies or for any personal data that may be collected through these websites or services, such as contact and location data. Please check these policies before you submit any personal data to these websites or use these services.

Accessing your personal data

If you would like to access all the personal data, the General Data Protection Regulation 2018 gives you the right to access information held about you. Your right of access can be exercised in accordance with it.

You can access this data by sending Us a completed Personal Data Request Form which you can find here [FORM HYPERLINK]. You must complete the form and send it to [email protected], please note that data extractions are done in a .xlsx spreadsheet formats only.

Contact

Questions, comments and requests regarding this Privacy Policy are welcomed and should be directed by e-mail to: [email protected].

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