Privacy Policy

Full account will be given to data protection aspects. The identity of each participant will be kept confidentially at the site of data collection and will not be shared amongst consortium partners or any other group. Each participant will be assigned a coded identification number once they provide informed consent (via either an electronic consent agreement menu at the smartphone (GData) or a signed one (SData)). All documentation and data collection sheets will have this coded ID number and will not contain any information that would identify the participant. The ID number will be the only way of identifying participants. The coded data will be stored on a separate computer to the study data, in a password protected file. GData/SData will be anonymised and stored on secure file servers in a private Cloud, managed by the partner institutions in line with respective institutional policies. The transfer of data between partners will also be protected. All electronic data will be encrypted and will only have the participant’s ID and relevant clinical or physiological information required to interpret the results. The password to access the encrypted data will be provided by phone and will not accompany the data or be delivered through the same medium. The principal investigator from each participant organisation will be responsible for ensuring compliance with local and EU data protection regulations (95/46/EC and its forthcoming amendments with new guidelines for data protection and privacy to be enforced from 2017).

Details:

Information We Collect

In addition to the data we collect in registration for the OsteoMentor Approach:
  • Data Imports. The OsteoMentor allows you to import data  including voice recordings and data collected in connection with your performance of specified tasks while holding your smartphone like walking and tapping or through sensors on yours smartphone providing infos such as sleeping quality ,gait of walking and emotional status. You may also give permission to import certain data from third party wearable activity devices (like Microsoft Band), as well as other . We are not responsible for the data practices of third parties from which you may elect to import data and you are advised to consult their privacy policies separately. You may choose not to import these data types and to still participate in the Study.
  • Location data. You may elect to turn on the location services on the OsteoMentor  App and grant the app access to your GPS coordinates. With your permission, we use that location data to determine the overall distances you travelled so that we better understand your level of activity and evolving health, but we do not share your actual location.
  • Other Information You Provide to Us. We also receive other information, including personal data, that you may provide to us, such as comments or questions you provide to us.

How We Use Information

We use your contact information, including email address, to contact you for administrative purposes regarding your participation in the Study and your use of the OsteoMentor App.
We use the information that we collect through App to operate, maintain, enhance and provide all features of the OsteoMentor , to provide services and information that you request, to respond to comments and questions and otherwise to provide support to users.
Your data will be used for improving general health, medical and fitness management and for the purposes of improving the Quality of Life of elderly adults and for the active healthy ageing.We will not access your personal contacts, other applications, personal photos nor text and email messages on your smartphone.
We use standard log files and other automatically-collected usage data that is essential for the OsteoMentor App to function effectively, including to: (i) personalize the app, such as by remembering information so that it does not need to be re-entered; (ii) monitor and analyze the data to personilize the customer’s solution (iii) monitor aggregate OsteoMentor App usage metrics. We do not use cookies, beacons or device fingerprinting.

Except as described in this privacy policy, we will not sell, rent, lease, give away, disclose or share your contact information, and will not disclose your information that we collect through the OsteoMentor App and the Study to third parties without your consent. We may provide contact or coded study information to third parties if you consent to us doing so, as well as in the following circumstances:
  • When we work with third parties who provide services on our behalf, we take steps to limit the personal data provided to them to that which is reasonably necessary for them to perform their functions for the allowable purposes listed above. We require them by contract to agree to only process the personal data in accordance with our instructions and to maintain the security and confidentiality of such information by applying adequate technical and organizational measures.
  • To the extent permitted by applicable law, we may disclose your information if required to do so by law to comply with state and federal laws, in response to a court order, judicial or other government subpoena or warrant, or to otherwise cooperate with law enforcement or other governmental agencies.
  • We also reserve the right to disclose your information that we believe, in good faith, is appropriate or necessary to (i) take precautions against liability, (ii) protect ourselves or others from fraudulent, abusive, or unlawful uses or activity, (iii) investigate and defend ourselves against any third-party claims or allegations, (iv) protect the security or integrity of the OsteoMentor Mobile App and the Study and any facilities or equipment used to make the OsteoMentor  App  or (v) protect our property or other legal rights (including, but not limited to, enforcement of our agreements), or the rights, property, or safety of others. We will notify you of any such disclosures.
  • You have the option to share data from your mobile device’s  with the OsteoMentor Mobile App.  Once you agree to share your data through and with the App, such data becomes covered by this Privacy Policy.

Data Security

We take steps having HIPAA and Personal Health Information (PHI) guidelines to ensure that your personal data is kept in de-identified format by removing personal data that reasonably can be used to identify you directly, such as name or telephone number. ISO 27001 and HL-7 are all included in Microsoft Azure Privacy Policy but we encrypt all data users provide to us with ID-based in Mobile Service as well as in the Windows Azure Virtual Machines to keep the anonymity. Data after their processing are deleted to be complied with HIPAA regulations. Your Rights and Choices Subject to applicable law, you may have certain rights regarding the personal data we maintain about you. You may have the right to request access to and receive information about the personal data we maintain about you, or have your personal data rectified, blocked or deleted if it is incorrect, inaccurate or outdated. Following your request, we will accommodate your enquiry as required by applicable law. Changes in Privacy Policy will be applied if EU health data protection regulations and HIPAA updates.