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PSC Support App Privacy Policy

APP01.2 24 May 2021

 

Quick links to each section:

Introduction

Important information and who we are

Contact details

Changes to the privacy policy and your duty to inform us of changes

Third party links

The data we collect about you

How is your personal data collected?

How we use your personal data

Purposes for which we will use your personal data

Disclosures of your personal data

International transfers

Data security

Data retention

Your legal rights

Introduction

This policy (together with our end-user licence agreement (EULA) as set out at www.pscsupport.org.uk/app-terms-and-conditions and any additional terms of use incorporated by reference into the EULA, together our Terms of Use) applies to your use of:

  • PSC Support mobile application software (App) hosted by Appoly, once you have downloaded or streamed a copy of the App from the relevant application site (App Site) onto your mobile telephone or handheld device (Device).
  • Any of the services accessible through the App (Services) that are available on the App Site or other sites of ours (Services Sites), unless the EULA states that a separate privacy policy applies to a particular Service, in which case that privacy policy only applies. 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. This App is not intended for children and we do not knowingly collect data relating to children. Please read the following carefully to understand our practices regarding your personal data and how we will treat it.

Important information and who we are

We’re PSC Support, the UK-based charity dedicated to improving the lives of people affected by primary sclerosing cholangitis (PSC). PSC Support is a charitable incorporated organisation (registered charity number 1175427). PSC Support was previously registered with the Charity Commission as an unincorporated association (registered charity number 1115615).

PSC Support is the controller and is responsible for your personal data (collectively referred to as "we", "us" or "our" in this policy).

If you have any questions about this privacy policy, please contact Martine Walmsley, Chair of Trustees, using the details set out below.

Contact details

Our full details are:

  • Full name of legal entity: PSC Support
  • Email address: privacy@pscsupport.org.uk;
  • Postal address: PSC Support, Unit 23056, PO Box 4336, Manchester, M61 0BW
  • Telephone number: 01235 25 35 45

 

You have the right to make a complaint at any time to the Information Commissioner's Office, the UK supervisory authority for data protection issues or other competent supervisory authority of an EU member state if the App is downloaded outside the UK.

Changes to the privacy policy and your duty to inform us of changes

We keep our privacy policy under regular review.

This privacy policy may change and if it does, these changes will be posted on this page and, where appropriate, notified to you when you next start the App. The new policy may be displayed on-screen.

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during our relationship with you.

Third party links

The App may, from time to time, contain links to and from the websites of our partner networks, advertisers and affiliates. 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 Identity and Contact Data. Please check these policies before you submit any personal data to these websites or use these services.

The data we collect about you

We may collect, use, store and transfer different kinds of personal data about you as follows:

  • Health Data: all data concerning your health and associated healthcare information including:
    • Your medical conditions
    • Your hospital and medical team details
    • UK-PSC number
    • Your medications
    • Your medical procedures and tests
    • Your health tracking data (eg symptom tracking)
    • Your medical appointments
  • Identity and Contact Data: to include first name, year of birth, medical number, country and email address.
  • Device Data: includes the type of device (make and model), an anonymised device ID, OS version.
  • Technical Data: includes your email address and password.
  • Usage Data: includes details of your use of our App including but not limited to, the resources that you access.

We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity. For example, we may aggregate your Health Data to identify and analyse particular trends. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy policy.

Health Data is special category personal data. In using the App you will be providing us with your Health Data, the processing for which you will provide your explicit consent. Other than Health Data, we do not collect any other special categories of personal data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, and genetic and biometric data). Where our processing of your personal data is based on your consent, you have the right to withdraw your consent at any time. If you do decide to withdraw your consent we will stop processing your personal data for that purpose, unless there is another lawful basis we can rely on – in which case, we will let you know. Your withdrawal of your consent won’t impact any of our processing up to that point.

Android App users will be required to consent to allowing PSC Support access to device media and photos in order to view a PDF health report within the App. Providing this broad consent is an operating system requirement. However, the app has been coded to look at the file path for that PDF report only. There is no possibility that the app can look at other files, even after consent is given. The same reports can be obtained via email without requiring this consent.

We do not collect any information about criminal convictions and offences.

How is your personal data collected?

  • Information you give us. This is information (including Health, Identity and Contact Data, Device, Technical and Usage Data) you give us about you when you download the App or sign up to use the App, while using the App, by corresponding with us via the App, subscribing to any of our Services, searching for an App or Service, sharing data with another user of the App, entering a survey, and when you report a problem with an App, our Services, or any of our websites. If you contact us, we will keep a record of that correspondence.
  • Information we collect about you and your device. Each time you use the App we will automatically collect personal data including Device and Usage Data. You may be directed to the PSC Support website from the app (www.pscsupport.org.uk) which may collect data about your use of the website. We collect this data using cookies and other similar technologies. Please see our cookie policy for further details.

How we use your personal data

We will only use your personal data when the law allows us to do so. Most commonly we will use your personal data in the following circumstances:

  • Where you have consented before the processing.
  • Where we need to perform a contract we are about to enter or have entered into with you.
  • 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.
  • Where we need to comply with a legal or regulatory obligation.

 

Purposes for which we will use your personal data

 

Purpose/activity Type of Data Lawful Basis for Processing Lawful Basis for Processing Special Category Data (Health)
To install the App and register you as a new App user Health Performance of a contract with you Your consent
Identity and Contact

Device

Performance of a contract with you -
To deliver the following App functions:

●          health, symptom and test results tracking;

●          to diairise your doctor and hospital appointments;

●          to provide you with automated reports based on the Health Data you have inputted to the App; and

●          to enable you to share your data with other nominated App users.

Health Performance of a contract with you Your consent
Identity and Contact

Technical

Performance of a contract with you -
To manage our relationship with you including:

●      notifying you of any changes to our terms and conditions;

●      keeping records updated; and

●      analysing how users use our products/Services.

 

Identity and Contact

Technical

Device

Usage

Necessary to comply with legal obligations (to inform you of any changes to our terms and conditions)

 

Necessary for our legitimate interests (to keep records updated and to analyse how users use our products/ Services)

 

Performance of a contract with you

-
To administer and protect our charity and this App including troubleshooting, data analysis and system testing and to provide you with technical support in respect of your use of the App. Identity and Contact

Device

Usage

Necessary for our legitimate interests -
●      To deliver content to you; and

●      To monitor trends so we can improve the App.

Health

 

Necessary for our legitimate interests (to develop our products/Services) Your consent
Identity and Contact

Device

Technical

Usage

 

Necessary for our legitimate interests (to develop our products/Services) -

Disclosures of your personal data

When you consent to providing us with your personal data, we will also ask you for your consent to share your personal data with the third parties set out below for the purposes set out in the table above:

  • External Third Parties, including:
    • Service providers acting as processors based in the United Kingdom who provide IT and system administration services.
  • Third parties to whom we may choose to sell, transfer or merge parts of our organisation or our assets. Alternatively, we may seek to acquire other organisations or merge with them. If a change happens to our organisation, then the new owners may use your personal data in the same way as set out in this privacy policy.

International transfers

We do not transfer your personal data outside the United Kingdom.

Data security

All information you provide to us is stored in cloud-based software. Where we have given you (or where you have chosen) a password that enables you to access the App, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.

Once we have received your information, we will use reasonable efforts to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way.

We will collect and store personal data on your Device using Core Data and/or Room and other technology.

Certain Services include social networking, chat room or forum features. Ensure when using these features that you do not submit any personal data that you do not want to be seen, collected or used by other users.

We have put in place procedures to deal with any suspected personal data breach and we will notify you and any applicable regulator when we are legally required to do so.

Data retention

We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.

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, regulatory, tax, accounting or other requirements.

In some circumstances you can ask us to delete your data: see Your Legal Rights below for further information.

In some circumstances we will anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.

In the event that you do not use the App for a period of 12 months then we will treat the account as expired and your personal data may be deleted.

Your legal rights

Under certain circumstances you have the following rights under data protection laws in relation to your personal data. You have the right to:

  • Request access to your personal data (commonly known as a "data subject access request").
  • Request correction of the personal data that we hold about you.
  • Request erasure of your personal data.
  • Object to processing of 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. You also have the right to object where we are processing your personal data for direct marketing purposes.
  • Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in certain scenarios.
  • Request the transfer of your personal data to you or to a third party.
  • Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent.

 

You can exercise any of these rights at any time by contacting us at privacy@pscsupport.org.uk.