ALBERT HEALTH, PRIVACY POLICY UPDATED JANUARY, 2023
We have the highest regard for your privacy and personal information and realize that the success of our services depends on the trust that you have in the way we handle your personal information. By entrusting us with your information, we would like to assure you of our commitment to keep such information private. We have taken considerable steps to protect the confidentiality, security, and integrity of this information. We encourage you to review the following information carefully.
This Privacy Policy applies to your use of the ALBERT HEALTH mobile device application (the “App” or “Albert Health Assistant”) and related website located at https://albert.health (including the mobile-optimized versions of such website, the “Site”) owned by Albert Health Ltd., a United Kingdom limited company (known as “Albert Health” brand name of Albert Health Ltd.) (“we” or “us”). The App and the Site are referred to together as the “Service”. ‘You’ refers to any user of the Service, including individuals who use the Service to track medication compliance (such as “Caregivers” (described below)).
This policy sets out our commitments and explains the rights that you have with respect to your personal information. If you do not agree to the terms of this Privacy Policy, please do not use the Service.
This Privacy Policy becomes effective on June 01, 2022, for all users, provided that enhanced data protection rights in this Policy required by the EU General Data Protection Regulation (including, without limitation, the “EEA Resident Rights” described in the “EEA RESIDENTS RIGHTS”) becomes effective on June 01, 2022, for all EU-resident users who are natural persons.
GROUNDS FOR DATA COLLECTION
When you use our Service, you consent to the collection, storage, use, disclosure, and other uses of your personal information as described in this Privacy Policy.
Processing of your Personal Information (meaning, any information which may potentially allow your identification with reasonable means; hereinafter “Personal Information”) is necessary for the performance of our contractual obligations towards you and providing you with our Service, to protect our legitimate interests, and to ensure compliance with legal and financial regulatory obligations.
HOW DO WE RECEIVE INFORMATION ABOUT YOU?
While you may use some of the functionality of the Service without creating a profile or registration, certain tools of the Service require registration and provision of your information, including Personal Information.
If you use the Service without creating a profile or registering – we will only collect information through the use of cookies, web beacons, device data, and navigational data collection, as well as any voluntary information you provide us, including Health Information (as defined below). While we cannot directly identify you through such data, in some jurisdictions, this information is still subject to applicable data protection laws and requires your consent as described below.
If you choose to create a profile or register with us – you will be asked to provide Personal Information which will be associated with your Health information.
Whenever you submit information via our Service – including, but not limited to, by telephone or email with customer service, we may collect Health Information and other Personal Information you provide us, in order to provide you with our Service.
If you choose to sign up via your Google account – when you sign up to the Service via your Google account, we will have access to basic information made publicly from your Google account, such as your full name, home address, email address, birthdate, profile picture, friends list, personal description, as well as any other information you made publicly available on such account, or agreed to share with us.
It is your voluntary decision whether to provide us with any Personal Information or Health Information, however, if you do not provide this information you may not be able to create a profile or register with the Service and your use of the Service may be limited.
WHAT TYPES OF INFORMATION DO WE COLLECT?
Personal Information
We collect the following Personal Information about you:
Create Profile and Registration information – your name, email address, gender, birth year, and optionally zip code.
We may collect the following information – country of residency, home address, birthday, and phone number.
If you are a healthcare provider, you will be asked to provide information regarding your professional qualifications as well as additional Personal Information during registration.
Voluntary information – when you communicate with us (for example when you send us an email or use a “contact us” form) we collect the Personal Information you provided us with.
Technical information – we collect certain technical information that is automatically recorded when you use our Services, such as your IP address, and the device's approximate location.
Personal Health Information – you may choose to use certain features of the Service that will allow you to input other Personal Information with respect to your health, such as the medications you take, the date of your prescriptions, the number of refills you have made, how often you take your medication, dosage, physical measurements your doctor’s name, and the name of your pharmacy (collectively your “Health Information”).
Fitness and Wellness Data – you may choose to connect and use your fitness and wellness data such as step count, body measurements, and sleep data with your Albert. Those data will be stored in your profile and will be accessible to you and your connected profiles with your consent. These data can be imported via Google Fit or Apple Health with your permission.
Non-Personal Information
Site:
Site usage data – We collect information about your use of the Site. This includes but is not limited to: the type of computing or mobile device you use, the language of your operating system, the Internet browser you are using, geo-location, and use of the Site.
Health Information – We may also collect your non-identifiable Health Information if you choose to provide it (in case of non-registered users)
App:
Installation ID – When you download and install our App onto a mobile device, we assign a random number to your App installation. We do not use this number to identify you personally unless you choose to become a registered user of the App. We use this random number in a manner similar to our use of cookies as described in this Privacy Policy. Because the random number is assigned to your installation of the App itself, it cannot be removed through the settings of your App or your device. If you do not want us to use the random number for the purposes for which we use cookies, please do not install our App. Technical information – The App automatically collects certain information about you when you use the App, this includes, but is not limited to the type of computing or mobile device you use, advertiser ID, your device’s operating system, the language of your operating system and the Internet browser you are using. The App might also access a list of installed apps on your device. This is done only to ensure proper quality of service, as some apps might interfere with the App functionality, such as blocking notifications, and in such cases, we will notify you.
We may collect and use non-personal information in the following circumstances. To have a better understanding of user behavior, solve problems in products and services, and improve our products, services, and advertising, we may collect non-personal information such as installed application name and package name, the data of installation, frequency of use, country, equipment, and channel.
Data Retention Policy
We use Albert's own database servers to store account registration information.
We store your information using Albert's own database servers until you delete your Albert account. This deletion involves only personally identifiable data, which includes for example (username, password, all images, GPS data, and entered programs).
If you do not log any activity in the application for a period of two years, we remove all personal data and thereby anonymize your account automatically. This removal of personal data includes all personally identifiable information, that includes for example (username, password, all images, GPS data, and entered programs).
The registration data along with usage data is stored using Albert's own database servers whose databases are located in the EU.
TRACKING TECHNOLOGIES – COOKIES
A cookie is a small piece of text that is sent to a visitor’s browser. The browser provides this piece of text to the device of the originating visitor when this visitor returns. We use cookies to help personalize your Albert Health experience.
A “persistent” cookie may be used to help save your settings and customizations. Also, if you log in to the Site, such a cookie will be used to recognize you as a valid user so you will not need to log in each time you use the Site.
Most Web browsers automatically accept cookies however allow you to modify security settings so you can approve or reject cookies on a case-by-case basis or reject all cookies. You can configure your web browser to remove cookies by following the directions provided in your Internet browser’s “help” section.
Also, you are free to delete any existing cookies at any time. If you delete or disable cookies from our Site, some parts or functions of the Site may not work properly for you.
We also use “Google Analytics” to collect information about the use of the Service. Google Analytics collects information such as how often users visit the Service, what pages they visit when they do so, and what other sites they used prior to coming to the Service. Google Analytics collects only the IP address assigned to you on the date you use the Service, as well as information regarding your operating system, language, and information regarding your use of the Service, rather than your name or other identifying information. We do not combine the information collected through the use of Google Analytics with Personal Information. We use the information we get from Google Analytics only to improve the Service. Google’s ability to use and share information collected by Google Analytics about your use of the Service is restricted by the Google Analytics Terms of Use located here and the Google Privacy Policy located here.
We also use "Branch IO" to collect information about the use of the Service. The branch collects information about installed application names and package names to help us. The Branch IO privacy policy is located here.
HOW DO WE USE THE INFORMATION WE COLLECT?
Provision of service – we will use the Personal Information you provide us for the provision and improvement of our Service to you. For example, data collected automatically on the Service may be used to help diagnose problems with our servers, to make our Service more useful, customize it, and personalize its content for you (for example, we will use your health information to send you reminders to take your medications).
General communication – we also use your Personal Information to send you texts, emails, or other communications regarding general adherence information, Service maintenance, updates, or changes to this Privacy Policy or any other relevant agreements.
Marketing purposes – we will use your Personal Information (such as your email address or phone number) to communicate with you. We may also send you promotional material concerning our services or our partners’ services (which we believe may interest you), including but not limited to, building an automated profile based on your Personal Information, for marketing purposes.
Opt-out of receiving marketing materials – If you do not want us to use or share your Personal Information for marketing purposes, you may opt out in accordance with this “Opt-out” section. Please note that even if you opt-out, we may still use and share your personal information with third parties for non-marketing purposes (for example to fulfill your requests, communicate with you, and respond to your inquiries, etc.). In such cases, the companies with whom we share your Personal Information are authorized to use your Personal Information only as necessary to provide these non-marketing services.
Analytics, surveys, and research – we are always trying to improve our services and think of new and exciting features for our users. From time to time, we may conduct surveys or test features, and analyze the information we have to develop, evaluate and improve these features.
Protecting our interests – we may use your Personal Information when we believe it’s necessary in order to take precautions against liabilities, investigate and defend ourselves against any third-party claims or allegations, investigate and protect ourselves from fraud, protect the security or integrity of our Service and protect the rights and property of Albert Health, its users and/or partners.
Enforcing of policies – we may use your Personal Information in order to enforce our policies, including but limited to our Terms, or Client Agreement.
Compliance with legal and regulatory requirements – we also use your Personal Information as required by law, regulation, or other governmental authority, or to comply with a subpoena or similar legal process.
WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?
Research partners – We may share your Personal Information with third parties, such as research institutes, healthcare systems, and healthcare providers, that they may associate with other information that they have about you, for research purposes and for the improvement of our services.
Providers of personalized third-party content – From time to time, we may also ask whether you would like us to share your Personal Information with another company that may want to send you information about their products or services. If you consent to such transfer by us of your Personal Information to another company, please note that the information provided will be subject to such company’s privacy practices and shall not be within our control.
Content providers – We may also use your Personal Information in order to provide you with personalized third-party content or links to third-party sites that might interest you. We provide this third-party content and/or links to third-party sites for information purposes only and are not liable for such content or sites. For more information see the “Links to other Websites or Apps” section below.
Third-Party Health Apps – We participate in Apple HealthKit, Samsung S-Health, and Google Fit frameworks (the “Apps”). We will use information that you consent that we receive from those Apps for medical research purposes, internally in order to improve our products and services and in the form of aggregated and/or analytical data as described in the Use of Aggregated Data section of the Privacy Policy, and may transfer this data to third parties for such purposes. We may provide our users with the ability to share their Albert Health data with other authorized Services on their devices after receiving their consent for the same. We will not sell any Personal Information nor will we use this data for advertising purposes. Please note that when you share information with third-party apps, such information will be subject to their privacy policy, over which we have no control. In order to learn more, please visit each of Apple, Samsung, or Google’s relevant pages and their respective privacy policies.
Service providers – We might share your Personal Information, as is reasonably necessary, with our contractors or consultants, including vendors and suppliers that provide us with development services, technology (such as Google Analytics), services, or content for the operation, development, and maintenance of our Service or data and analysis on Service use, who are bound by an obligation of confidentiality, provided that we will only share Personal Information to the extent necessary with such contractors or consultants.
Law authorities – we may share your personal data with law enforcement authorities, courts, and tribunals, including with legal advisors and consultants, in case we need to respond to law enforcement requests or other legal requests or pursuant to a requirement imposed by law, order, judgment or decree, or courts in order to protect and defend our rights and property or those of Service users.
Merger, acquisition, or sale – We may transfer your Personal Information in the event of a merger, acquisition, or sale of all or a portion of our assets.
Albert Health may offer you, from time to time and at its sole discretion, participation in customized programs, based on specified criteria (“Programs”). Participation in Programs may require sharing of your personal data with additional third parties. If you choose to participate, Albert Health will provide you with additional information and seek your consent for such sharing.
Your Personal Information will not be combined with other information and will not be used for other purposes, except as explained in this policy. Please note that we are not subject to medical secrecy obligations.
Personal Information you may share through our Service
Caregiver – You may send family members or friends an invitation to be your “Caregiver” by means of the Service so that such Caregiver will receive alerts regarding your compliance with your medication regime. By sending such an invitation, you represent that you have the right to contact the Caregiver and that you consent to our sending Personal Information about your medications and your compliance with your medication regime to the Caregiver. Sharing of your Personal Information in this manner is solely your responsibility.
Medical professionals and Doctors – You may use the Service in order to share your Personal Information or other information with your doctor or healthcare providers. Such sharing may be enabled by inviting your healthcare provider to monitor your Personal Information, by accepting an invitation from your healthcare provider to download and use the Service, or otherwise by using the Service settings to share your information with your healthcare provider; in these cases, you consent to our sending Personal Information about your medications and your compliance with your medication regime with your healthcare providers. Confirm with your healthcare provider that they have sent you an invitation to download the App. Such sharing of your information is at your discretion and is solely your responsibility.
Pharmacies and coupon companies – you may choose to share your Personal Information with pharmacies with which we partner, and/or third-party coupon companies, in order that we may send you coupons and/or provide you with reminders to get your prescription refilled. If you choose to share your Personal Information in this manner, please note that such information may be disclosed to the coupon companies and/or pharmacies and will be subject to their privacy practices.
While we take great care to keep your Personal Information confidential and secure, when you share your health or medication information with others or provide feedback regarding health matters, medications and otherwise, including by means of social media sites, or when you participate in a forum on the Service, any information disclosed by you in such way is solely your responsibility. You should exercise caution when disclosing any information (including Personal Information) in such ways, as you do not know who will access or use such information and for what purposes
USE OF AGGREGATED DATA
Aggregated data will not contain any information that could be used to contact or identify you. We may analyze and/or combine all information we receive, including Health Information and information regarding your use of the Service, with information from other users to create aggregated data that may be disclosed to and utilized by us, our affiliates, and by third parties without restriction, on commercial terms that we can determine in our sole discretion, for purposes such as; content marketing, research purposes, in order to understand behavior patterns, in order to increase adherence to medication regimens, marketing strategies and for entering into commercial contracts in order to provide our users with the Service. As an exception to the above, we will not include data received via Apple HealthKit in the aggregated data we share with and/or sell to affiliates or third parties.
INTERNATIONAL TRANSFERS
Please note that some of our service providers may be located outside the European Economic Area (“EEA”). In such cases, we will transfer your data only to such countries as approved by the European Commission as providing an adequate level of data protection, or enter into legal agreements ensuring an adequate level of data protection.
We may transfer our databases containing your Personal Information in connection with the transfer or sale of all (or substantially all) of our business assets, or in the event of a merger, consolidation, or similar transaction.
EEA RESIDENTS RIGHTS
If you are a resident of the European Economic Area, you have the following data protection rights:
At any time, you can stop the collection of your information by uninstalling the App and refrain from using the Service.
You may request to:
Receive confirmation as to whether or not Personal Information concerning you is being processed, and access your stored Personal Information, together with supplementary information.
Receive a copy of the Personal Information you directly volunteer to us in a structured, commonly used, and machine-readable format.
Request rectification of your Personal Information that is in our control.
Request erasure of your Personal Information.
Object to the processing of Personal Information by us.
Request to restrict processing of your Personal Information by us.
Lodge a complaint with a supervisory authority.
However, please note that these rights are not absolute, and may be subject to our own legitimate interests and regulatory requirements.
If you wish to exercise any of the above rights or ask us a question please contact us:
ATTN: DPO, Albert Health Ltd
Albert Health Ltd, 90A High Street Berkhamsted, Hertfordshire, United Kingdom
RETENTION
We will retain your Personal Information for as long as necessary to provide our services. We will retain and use your information as necessary to comply with our legal obligations, resolve disputes, and enforce our policies. Retention periods will be determined taking into account the type of information that is collected and the purpose for which it is collected, bearing in mind the requirements applicable to the situation and the need to destroy outdated, unused information at the earliest reasonable time.
LINKS TO OTHER WEBSITES OR APPS
Our Service may link to or refer to websites or mobile device services that we do not control. Any Personal Information you provide on the linked pages is provided directly to this third party and is subject to this third party’s provider’s privacy policy. This Privacy Policy does not apply to such other websites or Services, and we are not responsible for the privacy practices or content of any website or Service not controlled by us. If you have any concerns, we urge you to review the terms of those other websites or Services for more information about their applicable policies.
HOW WE PROTECT YOUR INFORMATION
We have implemented administrative, technical, and physical safeguards to help prevent unauthorized access, use, or disclosure of your Personal Information. Your information is stored on secure servers and isn’t publicly available. We limit access to your information only to those employees or partners who need to know the information in order to enable the carrying out of the agreement between us.
You need to help us prevent unauthorized access to your account by protecting your password appropriately and limiting access to your account (for example, by signing off after you have finished accessing your account). You will be solely responsible for keeping your password confidential and for all use of your password and your account, including any unauthorized use.
While we seek to protect your information to ensure that it is kept confidential, we cannot absolutely guarantee its security. You should be aware that there is always some risk involved in transmitting information over the internet. While we strive to protect your Personal Information, we cannot ensure or warrant the security and privacy of your personal information or other content you transmit using the service, and you do so at your own risk.
CHILDREN
Our Service is intended for use by persons 18 years of age and older. Under no circumstances should the Service be used by children under 16 years of age, and we will not knowingly collect Personal Information from any person we know to be in this age group. If you discover that your child has been using the Service without your consent, or that someone has been using the Service for or on behalf of your child without your consent, please contact us using the information below under “How to Contact Us,” and we will take reasonable steps to delete the child’s information from our active databases. Albert Health reserves the right to check its user base from time to time and remove users whom Albert Health has grounds to believe are in fact minors, including without limitation, restricting those user accounts, or deleting them, as Albert Health may deem appropriate.
HOW TO CONTACT US
IF YOU HAVE ANY QUESTIONS, COMMENTS, REQUESTS, OR CONCERNS RELATED TO THIS PRIVACY POLICY OR THE PRIVACY PRACTICES FOR OUR SERVICE, PLEASE CONTACT US AT:
Albert Health
Albert Health Ltd, 90A High Street Berkhamsted, Hertfordshire, United Kingdom