SmartAir Medical Limited, trading as AIRBRIO, (we) are committed to protecting and respecting your privacy.
SCOPE OF POLICY
- AIRBRIO mobile application software (App) hosted on www.AIRBRIO.com (App Site), once you have downloaded or streamed a copy of the App 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).
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. Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it.
For the purpose of the Data Protection Act 1998, the data controller is SmartAir Medical Limited, a company registered in Northern Ireland under company number NI628186 and with our registered office at The Clinical Translational Research Centre, Glenshane Road, Derry/Londonderry BT47 6SB, Northern Ireland, UK, which is our main trading address.
INFORMATION WE COLLECT FROM YOU
We will collect and process the following data about you:
- Information you give us (Submitted information): This is information you give us about you by filling in forms on the App Site and the Services Sites (together Our Sites), or by corresponding with us (for example, by e-mail or chat). It includes information you provide when you register to use the App Site, download or register an App, subscribe to any of our Services, search for an App or Service, make an in-App purchase, share data via the App’s interactive functions and when you report a problem with an App, our Services, or any of our Sites. Importantly, it also includes the sensitive personal data relating to your health that is collected directly by Bluetooth from the AIRBRIO Product. If you contact us, we will keep a record of that correspondence. The information you give us may include your name, address, e-mail address and phone number, the Device’s phone number, age, username, password and other registration information, financial and credit card information and personal description.
- Information we collect about you. Each time you use our App we will automatically collect information stored on your Device, including the name of the AIRBRIO Product, compliance data (Device shake duration, in halation rate, time of dispense and time of inhalation).
- Location information. AIRBRIO App uses the ‘Breezometer’ feature which works by tracking the location of the AIRBRIO App users with the sole purpose of permitting the user to view air quality score in their immediate area i.e. information that is relevant to asthma and COPD patients.
- Information we receive from other sources (Third Party Information). We are working closely with third parties (including, for example, business partners, sub-contractors in technical, payment and delivery services, advertising networks, analytics providers, search information providers, credit reference agencies). We will notify you when we receive information about you from them and the purposes for which we intend to use that information.
- Unique application numbers: when you install or uninstall a Service containing a unique application number or when such a Service searches for automatic updates, that number and information about your installation, for example, the type of operating system, may be sent to us.
Uses made of the information
We use information held about you in the following ways:
- Submitted Information:
- o Information submitted during payment process will be used for billing shipping and collection purposes.
- o Logged data from the AIRBRIO Product or manually entered by you may also be retained for future marketing & promotion purposes relating to AIRBRIO goods & services i.e. via MMS, e-mail or postal service.
- o Information submitted by users during registration onto AIRBRIO will be used to notify any carer or G.P/healthcare professional of progress with inhalation and or prescription compliance. AIRBRIO may verify user and patient entered details with submitted carer or G.P information. This may include copying regular user reports or on any prompts/personal interventions when there is a concern with analysed data.
- o Data gathered may also be used for research analysis in anonymised form (unless you have given us explicit permission) e.g. marketing, condition prevalence rates, profiling user subgroups.
- o Data may be provided in anonymised form to third parties for product and service development purposes.
- Device information:
- o AIRBRIO operates by using Bluetooth to link a single AIRBRIO Product (having a unique IP) to a single mobile phone number (i.e. users). Future developments may require AIRBRIO to connect to other electronic devices. This data (numbers of both AIRBRIO Product and any registered mobile devices) will be retained to permit remote monitoring of patient use of AIRBRIO Services and to permit AIRBRIO to contact patient, carers, healthcare professionals directly via MMS or e-mail with regular reports, prompts/personal interventions and other AIRBRIO marketing/promotion information.
- Content Information:
- o We use content information for the purposes of enhancing our product & services and for sales and marketing purposes.
- Log information:
- o AIRBRIO operates by logging variable data associated with each use / administration of medication. Data will be retained for each AIRBRIO use. The user can review a representation of this data by synchronising it to their smartphone App. AIRBRIO is a tool that can assist patients in managing their asthma or COPD by recording data associated with taking medication and provides ‘an indication only’ of user compliance to ‘Good Inhalation Technique’ and to their registered prescription. It is not a monitoring device, prescription or diagnostic product and users should always consult their G.P / healthcare professional in the first instance when they have any concerns about their respiratory condition.
- o In addition users may log answers to a prompted questionnaire or a journal entry feature. These will be appraised by AIRBRIO team during periodic analysis of user data and may be referred to in user reports or prompts/personal interventions copied to users, their registered carer and GP/healthcare professional.
- o Monitoring engagement with the product and service to facilitate targeted health promotion.
- Location information:
- o During initial registration users will enter their address details. Data will be retained to permit periodic reports to be issued, promotion & marketing materials to be forwarded and for general research purposes e.g. analysis of AIRBRIO use prevalence and or subgrouping of patient groups for analysis.
- o In addition the AIRBRIO App includes a ‘Breezometer’ widget which works by tracking the location of AIRBRIO App users with the sole purpose of permitting the user to view air quality score in their immediate area i.e. information that is relevant to asthma and COPD patients.
- o Location data may be used for data analysis purposes e.g. provision of information to users, carers and clinicians in relation to respiratory disease management. This data may also be provided to stakeholders/partner organisations listed below in anonymised form unless explicit permission by you has been given..
- Third Party Information:
- o During registration users may register third party details e.g. a carer and/or G.P/healthcare professional. Data will be retained to potentially share periodic reports on user progress with AIRBRIO and for copying on prompts/alerts related to adverse events or trends associated with users progress using AIRBRIO. Data may also be used to make direct contact for AIRBRIO promotional purposes or for forwarding marketing and promotion materials.
- o Third party information may be required in order that AIRBRIO can fully populate a user’s data record for service improvement purposes or for our business process purposes e.g. billing and credit rating agency information.
- o As part of the AIRBRIO healthcare service patient data will be periodically analysed and report issued to any registered user, carer and healthcare professional. The content of this information will be to communicate progress, compliance, trends and any adverse events or concerns to registered user and their carer and GP/Healthcare Professional.
We may associate any category of information with any other category of information and will treat the combined information as personal data in accordance with this policy for as long as it is combined.
We do not disclose information about identifiable individuals to our advertisers, but we may provide them with anonymous aggregate information about our users (for example, we may inform them that 500 men aged under 30 have clicked on their advertisement on any given day). We may also use such aggregate information to help advertisers reach the kind of audience they want to target (for example, women in London SW1). We will use of the personal data we have collected from you to enable us to comply with our advertisers’ wishes by displaying their advertisement to that target audience.
Disclosure of your information
We will disclose the data we collect from you to the following third parties:
You agree that we have the right to 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 will disclose your personal information to third parties:
- In the event that we sell or buy any business or assets, in which case we will disclose your personal data to the prospective seller or buyer of such business or assets.
- If SmartAir Medical Limited 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:
- protect the rights, property or safety of SmartAir Medical Limited 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
All information you provide to us is stored on our secure servers. Any payment transactions carried out by us or our chosen third-party provider of payment processing services will be encrypted using Secured Sockets Layer technology, as facilitated by our third party service provider. Where we have given you (or where you have chosen) a password that enables you to access certain parts of Our Sites, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.
Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to Our Sites; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access.
Certain Services may 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.
You have the right to ask us not to process your personal data for marketing purposes. We will usually inform you (before collecting your data) if we intend to use your data for such purposes or if we intend to disclose your information to any third party for such purposes. You can exercise your right to prevent such processing 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 at firstname.lastname@example.org.
Our Sites 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 Services 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.
Access to information
The Data Protection Act 1998 gives you the right to access information held about you. Your right of access can be exercised in accordance with that Act.