Privacy Policy
Effective Date: March 2023
Protecting your data, privacy and personal data is very important to MoveMed Limited (‘us’, ‘our’ or ‘we’). This privacy policy provides information about how we collect and process your personal data when you use our digital platforms. This privacy policy applies to the personal data we collect about you when you use our digital platforms (including the mobile phone application MoveMed and connected web portal, as well as our website [www.movemed.io]).
Our digital platforms are used to collect and analyse data relating to users, many of whom we expect to be patients diagnosed with a neuro-muscular disease (our “Services”). The platforms are not intended for children, and we do not knowingly collect data relating to children and they should only be used by users with sufficient knowledge of the English language to understand and agree to the Terms & Conditions, this Policy and any in-app or web-based content.
It is important that you read this privacy policy together with any other privacy policy or fair processing policy we may provide on specific occasions when we are collecting or processing personal data about you, so that you are fully aware of how and why we are using your data. This privacy policy supplements other notices and privacy policies and is not intended to override them.
Who are we?
We are MoveMed Limited, a company registered in England and Wales with company number 12815255. We are the data controller and responsible for your personal data.
Have a question about something in this policy?
We have appointed a data protection officer. If you have any questions about this privacy policy, or how we process your data, please use the contact details below;
Data Protection Officer
Email: legal@movemed.io
Address: 10 Wellington Street, Cambridge, England, CB1 1HW.
We’re registered with the UK data protection authority (the Information Commissioner’s Office or ICO under number ZB296605).
The information we hold about you, and how we use it
We may collect, use, store and transfer different kinds of personal data about you as a result of your interaction with our digital platforms. Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data). We collect such personal information as follows:
Information that you provide to us when you use our digital platforms
● When an account is registered on one of our software applications, this includes ‘identity data’ such as your name, date of birth, mobile telephone number and email address, so we can set up an account for you and provide the Services. It is not possible to access our Services unless all necessary data is provided.
● When you input information onto our platforms: You may provide ‘sensitive personal data’ for example when you respond to the health-related assessments, or agree to share information from other 3rd party applications or systems. We collect this information to provide the Services, that is, to provide an indication of your health conditions. Please note that if you fail to provide information when requested in the assessment, we may not be able to provide the Services to you.
● Survey and questionnaire data: Survey and questionnaire data are your responses to any surveys or questionnaires, if you choose to complete these. Our surveys and questionnaires are used to improve measurement, patient experience and improve the provision of Services
Information which you provide to us is processed on the basis that we are performing a contract with you (by providing the Services) and you have consented to this. We may also process your information for our legitimate interests (for example, to understand how our Services are used and to further develop them) or to comply with a legal obligation.
We process your ‘personal data’ and ‘sensitive personal data’ on the basis of your explicit consent only where there is no other legal basis available.
Information that we collect when you visit the MoveMed website, use the MoveMed App (jointly “Platform”), and complete any assessment
Although we will not use it to identify you, we collect the following types of data via our Platform and any assessments, surveys or questionnaires you choose to complete. We collect and process this information to provide the Services in a safe and lawful way, and to keep improving them. This includes:
● Device data: Technical information about the device you are using and the software you’ve used to access the Services.
● Analytics data: Operating system and browser type. Details of your visit to our digital platform such as page interaction information and length of visits to certain pages.
This may include the use of cookies, which are small files of letters and numbers that we store on your browser or the hard drive of your device if you agree. Cookies contain information that is transferred to your device's hard drive.
We use the following cookies on our website:
● Strictly necessary cookies. These are cookies that are required for the operation of our digital platforms. They include, for example, cookies that enable you to log into secure areas of our platform.
● Analytical or performance cookies. These allow us to recognise and count the number of visitors to our website and to see how visitors move around our website when they are using it. This helps us to improve the way our website works, for example, by ensuring that users are finding what they are looking for easily.
You can find more information about the individual cookies we use and the purposes for which we use them in the list below:
Cookie Name & Purpose :
Session token - This is used to remember that you are currently logged in or have used the app before. - Essential
Sign up token - This is used to remember and track where in the sign-up flow you have reached - Essential
Cookie settings - This is used to remember your cookie preferences, to avoid asking on every visit - Essential
Google analytics cookie - This is used to understand how our users access, use and return to the landing page - Optional
You can block cookies by activating the setting on your browser that allows you to refuse the setting of all or some cookies. However, if you use your browser settings to block all cookies (including essential cookies) you may not be able to access all or parts of our Platform or other parts of our digital platforms.
Except for essential cookies, all cookies will expire after 2 years.
Where do we store or send your personal data?
● Companies that provide services to us. Here we mean companies that help us to provide the services you use and that need to process details about you for this reason. We share as little information as we can and encrypt and/or make it impossible for you to be identified by the recipient where possible (for instance by using a User ID rather than your name). These companies include: [Amazon Web Services].
We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.
Your information may be transferred outside the United States (USA) and United Kingdom (UK), for example due to storage on the Cloud Platforms. Whenever we transfer your personal data out of the UK, we ensure a similar degree of protection is afforded to it as in the US and UK by putting in place appropriate safeguards.
Disclosure of your personal data/who we share your data with
Your personal data will be kept strictly confidential and will not be shared with anyone without your prior consent other than on a secure basis with those responsible for your care (if applicable) or if we are under a duty to disclose or share personal data to comply with any other legal or regulatory obligation.
Keeping your data safe
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They are subject to a duty of confidentiality and, where they are the data processor, will only process your personal data on our instructions.
How long do we keep your information?
We will only keep your personal data for as long as reasonably necessary, such as for the performance of the Services. When deciding the appropriate retention periods, we will take into account:
● The amount, nature and sensitivity of the personal data, risk of potential 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;
● The purposes for which you are accessing our digital platforms;
● The duration for which your personal data is required for the performance of the Services and the purpose for which it was collected; and
● Any legal and regulatory obligations under applicable law, contract or with regard to any statutory obligations.
We will, however, retain an anonymised set of your and other users’ personal data (so that it can no longer be associated with you) for research or statistical purposes, to improve the measurement of disease, in which case we may use this information indefinitely without further notice to you. For the avoidance of doubt, this will not include your name, e-mail and internet protocol addresses or telephone number.
Your data protection rights
Under data protection law, you have rights including:
● Your right of access – You have the right to ask us for copies of your personal information.
● Your right to rectification – You have the right to ask us to rectify information you think is inaccurate. You also have the right to ask us to complete information you think is incomplete.
● Your right to erasure – You have the right to ask us to erase your personal information in certain circumstances.
● Your right to restriction of processing – You have the right to ask us to restrict the processing of your information in certain circumstances.
● Your right to object to processing – You have the right to object to the processing of your personal data in certain circumstances.
● Your right to data portability – You have the right to ask that we transfer the information you gave us to another organisation, or to you, in certain circumstances.
● Your right to withdraw consent – You have the right to withdraw consent at any time where we are relying on consent to process your personal data.
You are not required to pay any charge for exercising your rights. If you make a request, we have one month to respond to you, but occasionally it could take us longer if your request is complicated or you have made a number of requests. We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights).
Please contact the DPO using the details set out above if you wish to make a request.
Changes to this policy
We may update our privacy policy from time to time. Any changes we make will be updated on the MoveMed website and if you have already registered for the assessment, an email will be sent to notify you.
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