My Dose Coach Global Mobile App Privacy Policy
SAN-012437 Rev 01
Effective Date: 25 March 2021.
WHY THIS DOCUMENT?
As part of its day to day operation, SANOFI provides access to a variety of tools and resources that provide information to all the individuals with whom it has business interactions with (patients and their relatives, participants to clinical trials, healthcare professionals, users of products and services, workers, etc.) regarding its activities.
Such tools and resources may be provided in various formats, including, more specifically in electronic format and by means of online electronic communications, including this application or “app” made available by SANOFI and to which this policy applies (hereinafter together the “App”). In order to be able to provide them, SANOFI may need to collect and process Personal Data (as defined below) of their users.
SANOFI is fully committed to the protection of Personal Data and intends to provide you with all relevant information regarding the way in which SANOFI processes your Personal Data on the App and to whom it is or may be disclosed.
This App Privacy Policy does not address, and we are not responsible for, the privacy, information or other practices of any third parties, including any third party operating any website or web property that is available through the App. We suggest contacting those sites directly for information on their privacy policies.
You will find below relevant information regarding the processing of Personal Data conducted on this App. Please note that the content of this App Privacy Policy may change from time to time, for instance in case of change of our processes or as a result of applicable law. SANOFI reserves the right to amend this App Privacy Policy without prior notice. If SANOFI changes this App Privacy Policy, an updated version will reflect those changes. You are advised to consult this App Privacy Policy regularly for any changes. By using this App, you consent to any material changes to this App Privacy Policy and any new practices that may affect your previously collected Personal Data.
REMINDER: WHAT IS PERSONAL DATA & PROCESSING?
For the purposes of this App Privacy Policy, Personal Data is any information relating to an identified or identifiable natural person. SANOFI’s contractors will use the information you provide, including Personal Data, in connection with the objectives and purposes defined in this App Privacy Policy. Such Personal Data may include:
· Basic identification information such as your name or date of birth;
· Information that can be attributed to you directly or indirectly – such as notes provided to your healthcare provider; and
· Information which can be associated to you or your device such as, for instance, an IP address (i.e., the network address of your machine).
In this respect, the notion of “processing” designates any action that is undertaken on your Personal Data, including: collection, storage, access, analysis.
WHAT PERSONAL DATA DOES THIS APP COLLECT?
This App may collect the following categories of Personal Data:
· Identification data: any information provided directly from you while using the App or by your healthcare provider as part of the App onboarding which allows your identification, whether directly or indirectly such as your name, gender, date of birth, or contact details (email address, telephone number) or medical record/patient identification number.
· Messages: you may send your healthcare provider notes while using the App.
· Health Data: any information pertaining to your dose plan sent by your healthcare provider, medication or blood glucose data input by you manually or collected from connected devices, health status information such as weight or A1C, and other similar information.
· Connection data: any information regarding your connection and access to this App (e.g. type of mobile device you use, your mobile device’s unique ID, the IP address of your mobile device, your mobile operating system, and information about the way you use the App).
· Location data: this App is designed to integrate with your connected BLE Insulin Pens as well as your connected Blood Glucose testing devices. The App is designed to log your doses and BG measurements even when the App is in the background from paired devices. In order to scan, discover, and pair with your connected BLE devices, the App requires location service access to function properly. No location service data is stored and the App only requires access to ensure proper Bluetooth connections are established.
FOR WHAT PURPOSES DOES THIS APP COLLECT PERSONAL DATA?
The collection and processing of Personal Data on this App is conducted for the following purposes:
· To allow you to navigate this App.
· To provide patient support: enable healthcare provider to prescribe an individual dose plan based on data entered into the App; patient engagement and medication reminders.
· To improve our products and services: identify usage trends, develop new products and services, and understand how you and your device interact with our services through use of analytics technologies that support IP anonymization, never disclosing your full IP address to SANOFI; track and respond to safety concerns; and conduct surveys. To investigate application crashes: collection and sending of crash reports that include technical information from the App at the time of the crash, the App log, basic metrics such as App launches and session length, and low resolution videos of use of the App before and at the time of a crash, in order to help troubleshoot service problems.
· To protect patient safety: apply filters or algorithms based on the data you entered to be able to detect potential adverse events or potential product complaints regardless of the pharmaceutical product you are prescribed.
· To provide updates to the App: notify you when App updates are available.
ON WHAT GROUNDS DOES THIS APP PROCESS YOUR PERSONAL DATA?
For the purposes of this App, your Personal Data is only processed on the basis of:
· Your prior CONSENT: where you have clearly expressed your approval of SANOFI’s processing of your Personal Data through Contracted Experts. By using this App, you are consenting to collection, use and processing of User Provided Information and Automatically Collected Information set forth in this App Privacy Policy now and as amended.
· Your explicit CONSENT in third party application: If the Personal data is to be shared with a third party company, you will provide an explicit consent to share this data and will be able to disconnect the sharing at any time.
HOW LONG IS THE PERSONAL DATA COLLECTED IN THIS APP RETAINED?
For the purposes defined in connection with the use of this Website, your personal data will be retained in accordance with the principles set out below:
· Website Access and navigation: data processed in this context will be retained in accordance with the principles set out in our Cookie policy which defines the terms of retention applicable to each cookie.
· Communication with Website visitors : data processed in connection with our communications with you are retained for the period necessary to address your request and ensure it has been adequately resolved;
· User registration and Website functioning & data display AND Website user support & guidance: data processed for this purpose will be retained for the entire term of the existence of your account on this Website and for a period of ten (10) years after your last recorded activity on this Website unless local legislation requires the implementation of a shorter or longer term of retention, in which case, this term will apply;
· Therapeutical support: data processed for this purpose will be retained by you as the patient’s healthcare professional in accordance with your own retention policy;
· Product and service improvement: data processed for this purpose will be retained for the term of your use of this Website;
· Patient protection and safety: data processed for this purpose will be retained for ten (10) years.
· Further scientific research : once de-identified, the personal data no longer qualifies as personal data and can therefore be retained for an undetermined period of time.
WHO HAS ACCESS TO PERSONAL DATA?
Unless you contact us directly, SANOFI will not have access to your Personal Data through the App. SANOFI’s contractors, who are helping to develop this App and provide data management, may have access to your Personal Data; however, these staff and contractors are subject to confidentiality requirements restricting the disclosure of such information and have committed not to disclose any identifiable information to SANOFI or any third party unless legally required. SANOFI may have access to de-identified information of users of the App. Other individuals downloading and using the App will not have access to your information at any time.
SANOFI may disclose the Personal Data provided by you or your healthcare provider or automatically collected by the App:
· With our affiliated entities within the Sanofi Group;
· With contracted third parties of our global affiliates, group companies, etc.;
· As required by law, such as to comply with a subpoena, or similar legal process, or to report adverse events;
· When we believe in good faith that disclosure is necessary to protect our rights, protect your safety or the safety of others, investigate fraud, respond to a government request or otherwise exercise our legal rights or defend against legal claims;
· When we believe it is necessary to share information in order to assist in an investigation regarding, or to prevent, illegal activities, suspected fraud, or situations involving potential threats to the safety of any person;
· To third parties with whom SANOFI is jointly marketing a product or service or jointly conducting a program or activity;
· If SANOFI is involved in a merger, acquisition, or sale of all or a portion of its assets, you will be notified via email and/or prominent notice on our website of any change in ownership; and or uses of this information as well as any choices you may have regarding this information;
· To analytics companies as described in this App Privacy Policy.Any affiliated entity, contractors or other third party described above, who is permitted access to, or to whom we transfer Personal Data is required to keep your Personal Data confidential.
YOUR RIGHTS: SANOFI WILL ENSURE THAT YOU CAN EXERCISE YOUR RIGHTS PERTAINING TO YOUR PERSONAL DATA
You can exercise your rights as provided by applicable data protection laws.
As such, you are entitled to:
· object to the processing of your Personal Data. You may opt-out of all collection of information by uninstalling the App from your mobile device. You may use the standard uninstall processes as may be available as part of the mobile device or via the mobile application marketplace or network. You must uninstall the App for data entry and data collection directly collected from you to stop. If you choose to delete the app, we cannot stop your healthcare professional from entering additional Personal Data into the healthcare professional portal. You are responsible for letting your healthcare professional know to stop entering information on the portal or to delete your account.
· access by simple request to your Personal Data – in which case you may request to receive a copy of your personal data, unless such personal data is made available to you directly;
· request a rectification of your Personal Data if such data is inaccurate, incomplete or obsolete;
· obtain the deletion of your Personal Data in the specific cases provided for by law;
· obtain a limitation of the processing of your data in the specific cases provided for by law;
· if applicable, receive your data in a standard format for transmission to another data controller;
· lodge a complaint with your data protection authority.
To exercise your rights as set out above, please contact the My Dose Coach customer service in your country; or contact us via PrivacyOfficeUSA@sanofi.com.
By agreeing to this policy, you are confirming:
· You confirm that you are 18 years of age or older;
· You have read this App Privacy Policy in its entirety, you understand it, and you agree to the collection, use, and processing of information as described in this App Privacy Policy, which may be amended by SANOFI at any time effective upon its posting. Your continued use of this App constitutes your acceptance to this App Privacy Policy and any updates. This App Privacy Policy is incorporated into, and is subject to, the Terms of Use;
· You have provided your healthcare provider with your written authorization to enter your Personal Data into the portal so that you can use this App; and
· You will notify your healthcare provider to stop entering your information and you will uninstall the App if you do not wish to go forward or continue to use the App.
You must confirm your understanding and acceptance of this App Privacy Policy prior to using the App.