Scope
This Policy presents the privacy notice for the Healthentia Mobile-app developed by INNOVATION SPRINT SRL.
Method
This Policy is based on the guidelines issued by the European Data Protection Authorities and the personal data processing activities conducted by INNOVATION SPRINT SRL.
Privacy Policy
INNOVATION SPRINT SRL values the privacy of your personal data and your usage of our Service and Data.
The mission of INNOVATION SPRINT SRL is to provide Services to Healthcare and Life Sciences industries. To achieve its mission, INNOVATION SPRINT SRL is utilizing its website for its product HEALTHENTIA (www.healthentia.com) to present its activities and the company products (see also: https://healthentia.com/privacy-policy).
This Privacy Policy addresses to natural persons (also mentioned herein as “data subjects”) and refers to how INNOVATION SPRINT SRL collects and processes your personal data through the mobile application HEALTHENTIA (Healthentia Mobile-app) and informs you about your rights in accordance with the General Data Protection Regulation of the EU 2016/679, also known as GDPR.
Under GDPR, INNOVATION SPRINT SRL acts either as data controller or as data processor (with registered Address: Clos Chapelle-aux-Champs 30, 1200 Brussels, Belgium, Tel: +32 2 880 62 90, Company registration number BE0648786874).
Personal data means any information relating to you, which allows us to identify you, such as your name, contact details, information about your access to Healthentia Mobile-app and other embedded services, as well as any other information related to your health status, registered by you on a consent basis.
To achieve its mission, INNOVATION SPRINT SRL makes various features and functionalities available to you using Healthentia Mobile-app as individual end-user. Moreover, Healthentia Mobile-app can also be used as a tool to enable data collection on a consent basis during Patient Care, and/or Clinical Studies, and/or during long-term research activities conducted by INNOVATION SPRINT SRL on anonymized data, as part of the INNOVATION SPRINT SRL services (“Services”).
In general, HEALTHENTIA is a software developed by INNOVATION SPRINT SRL and intended for: a) the collection and transmission of physiological data including heart rate, blood pressure, oxygen saturation, and weight directly to care providers via automated electronic means in combination with validated IoT devices; b) the visualization (subjects-based dashboards) and the mathematical treatment of data (trends analysis, alerts) related to the monitored chronic disease subject’s physiological parameters; c) the transmission of patient’s outcomes and outcome scores related to patient’s health status, health-affecting factors, health-related quality of life, disease knowledge and adherence to treatment through validated questionnaires; d) the user (subject/patient) interaction with a conversational virtual coach for informative and motivational purposes, in order to support subject telemonitoring, decision making and virtual coaching.
Collected data is used for the needs of patient care, and/or clinical studies of affiliated sponsors as described in their separate privacy policies (when INNOVATION SPRINT SRL acts as processor), while processing of anonymized data allows the provision of smart services to the patients, as well as the long-term research activities of INNOVATION SPRINT SRL. In this way, pharmaceutical industry can achieve cost savings, accelerate the drug approval process, and obtain useful insights to develop drugs and interventions of higher efficacy in order to improve the life quality of humans.
In the context described above, HEALTHENTIA collects and processes your data based on:
Your agreement to use Healthentia Mobile-app as a software tool and accept the privacy terms and terms of use before registration. This may be withdrawn at any time by requesting to delete your account (you can use the DELETE ACCOUNT option of the Healthentia Mobile-app menu).
Your explicit consents that are related to self-reporting of health-related data and/or allowing healthcare professionals, and/or organizations to contact you. When you give your consent, you will be given further details on how to change your consent preferences or visit the 'Your rights' section (Section 12) of this Policy for more information.
Our legitimate business interests, for example, fraud prevention, maintaining the security of our network and services, and the improvement of our services. Whenever we rely on this lawful basis to process your data, we assess our business interests to make sure they do not override your rights. Additionally, in some cases you have the right to object to this processing. For more information, visit the 'Your rights' section (Section 12) of this Policy.
Compliance requirements with a mandatory legal obligation, including for example accounting and tax requirements, which are subject to strict internal policies (such as retention periods), procedures, and your right to restrict usage of your data, which control the scope of legal assistance to be provided.
Your consents are registered in Healthentia Mobile-app.
Details of the Personal Data we (INNOVATION SPRINT SRL) may collect follows in the next section (Section 4) and in Sections 5, 6 and 9.
Registering an account in Healthentia Mobile-app is possible from the mobile application with the use of your E-mail address, i.e., as initial step, Healthentia Mobile-app only collects the E-mail address, which is required for the registration purpose.
You are then left free to provide further personal information in a voluntarily manner, to complete your own profile, monitor your daily activities, participate in cohorts and/or clinical studies on a consent basis, and/or conduct videoconferencing with a practitioner of choice.
In general, Healthentia Mobile-app collects the following information you provide:
Activity data, such as: number of steps taken, distance covered, number of calories burned, body weight, heart rate, sleep stages, active minutes, type of physical activities and related information (these may be collected by 3rd parties, as well, after you enable the ACTIVITY sync setting – see Section 6 below), or health-related data (you can visit MY CONSENTS menu of the App for further details);
Other data such as your name (to be used as an extra identification feature and for personalization-better user experience purposes), gender, weight and height (provided in a voluntarily manner);
Location (after informing you and receiving your consent) - in this case, you will have the option to provide your location information from your device location service, or by typing your postal code and country, or not answering this question; This information will be used for location analytics purposes (legitimate interests pursued by INNOVATION SPRINT SRL);
Answers to questionnaires (including personal details, medical- or wellbeing-data, photos) in the context of cohorts and/or clinical studies conducted by healthcare organizations and/or affiliated sponsors (such e.g., pharmaceutical industries, hospitals, investigators), having INNOVATION SPRINT SRL acting as data processor on behalf of these organizations;
Phone number for App functionality and security-fraud purposes (2-factor authentication) in the context of patient care and/or clinical studies conducted by affiliated sponsors;
Device and Tracking Data (see Section 5 and Section 9 below).
INNOVATION SPRINT SRL, as data controller, may use collected, anonymized data for long-term research, such as creating behavioural and lifestyle models.
In addition, you can participate in a cohort and/or study by using a code, or by selecting a running cohort/study, or via E-mail invitation. If you are admitted to a study, which is managed by another party, you will receive additional privacy terms from that party, who will be the controller of the collected data for that study, having INNOVATION SPRINT SRL acting as processor. For these cohorts, you will be first asked to read additional terms from the data controller before you give your consent.
Healthentia Mobile-app also provides video conferencing capabilities between a data subject and a practitioner of his/her choice. It should be noted than no video recording is allowed during the provision of this service. This processing includes hosted or cloud video conferencing and messaging services, involving the collection, organization, storage, retrieval, consultation and use of such personal data, video conferences products and technology and related support services and account management: provisioning, reporting, customer/end-user support & billing. Video conferencing services include the processing of the following categories of data: call record logs (which contain statistics such as the time and duration of calls made or attended by an individual, the number of participants on each call, circumstances of the individual disconnecting from the call, statistics on the version of endpoint used to make the call), contact information (including the individual's user name, E-mail address, Display name used to join the call, IP address, telephone number).
Healthentia Mobile-app may collect (based on your consent and the specific context of the cohort and/or clinical studies you participate) information about your device and your App usage activity (see Sections 5 and 9 below).
When you access Healthentia Mobile-app, our servers may record data regarding your device and the network you are using to connect with INNOVATION SPRINT SRL, such as IP, date/time stamp, connection- and device-related information for fraud prevention, maintaining the security of our network and services, and the improvement of our services. Healthentia Mobile-app may temporarily use the exact location of your device, after your permission, to connect with medical devices such as scale, oximeter, blood pressure etc. through the Bluetooth protocol.
We may collect information about your activities from 3rd parties, such as activity data information, e.g., steps from device providers, or nutritional information from other services, in case you provide your consent to the relevant provider based on your preferences and your agreement to use your data from 3rd parties (you can visit the ACTIVITY TRACKING menu of the App for further details).
INNOVATION SPRINT SRL ensures that access of personal data by affiliated organizations in the context of patient care, and/or clinical studies is subject to the terms of this Policy and concerns exclusively the defined by INNOVATION SPRINT SRL purposes as described above. Disclosure of data to other 3rd parties is realized only for analytics purposes (as described in Section 9 below). For that reason and in any case, we adopt contractual agreements whereby the usage of specific technical safety measures is mandated, in order to safeguard that your personal data remain secure and is processed only for lawful purposes.
If you accept to be invited to cohorts and/or clinical studies by other affiliated parties (sponsors) acting as data controllers, you will also grant access to the data controllers of the study, who will provide you with additional privacy terms and obtain your consents accordingly.
INNOVATION SPRINT SRL is committed to protecting the security of your information and takes reasonable precautions to protect it. Once we receive your data transmission, we make all commercially reasonable efforts to ensure its security on our systems:
We implement and maintain appropriate technical and organizational measures to ensure a security level appropriate to protect personal data provided to us from accidental or unlawful destruction, loss, alteration, unauthorized disclosure, or access to personal information transmitted, stored or otherwise processed. We train all our employees meticulously to follow the principle of strict compliance with all legal requirements. Certain INNOVATION SPRINT SRL Services support the use of standard SSL encryption to protect data transmissions. Your personal information and data stored in our systems is protected by various physical, electronic and procedural safeguards. It is housed in a secure facility, and INNOVATION SPRINT SRL and our hosting partners restrict physical and network access to this facility to select trained staff. Your INNOVATION SPRINT SRL password is protected by encryption so that only you have access to it.
We regularly evaluate and review our technologies, facilities, procedures, and potential risks to maintain the security and privacy of our users’ data. In any case we will destroy or de-identify personal information once we no longer require it for our business purposes as explained herein, or as required by law.
INNOVATION SPRINT SRL is not responsible for any 3rd party’s actions or their security controls with respect to personal information they may collect or process via their websites, services or otherwise.
Healthentia Mobile-app does not use cookies. However, Healthentia Mobile-app collects (upon your consent during registration or using the e-consent App menu later-on) and stores via proper Application Programming Interfaces (APIs) towards 3rd parties, tracking data related to your behaviour, which are used in order to assess the App usability, offer you a better App experience and provide you personalized treatment adapted to your needs. These data include device identifiers, session duration and connection details, operating system, first launch of the App, App updates and version, geographical data, App scroll behaviour, use of App input forms/data fields.
During initial registration, you can accept or not the collection and storage of the afore mentioned analytics and statistical data (you can visit MY CONSENTS menu of the App, see consent option: Tracking my App usage for analytics and aggregated statistics). After registration, you can disable or re-enable the collection and storage of these data types through the MY CONSENTS toggle in the e-consents menu of Healthentia Mobile-app (this feature is provided in the context of cohort and/or clinical studies conducted by affiliated sponsors).
Data hosting of Healthentia Mobile-app tracking and analytics data is utilizing the services of Mixpanel (https://mixpanel.com/legal/gdpr-resources) and Firebase-Google (https://firebase.google.com/support/privacy).
Healthentia Mobile-app uses push notifications that are triggered from the system to inform the user about questionnaires or other news. User can anytime deactivate the push notifications from the iOS/Android device settings.
INNOVATION SPRINT SRL will not retain data longer than necessary to fulfil the purposes for which it was collected or as required by applicable laws and regulations. The data you provide us may be archived and stored periodically and will only be retained for as long as it is required for the purposes it was collected, unless the law requires us to retain them for a longer period, or delete it sooner, or unless you exercise the right to erasure (where it applies), when we do not need to retain it in connection with any reasons permitted or required by law. For the purposes of long-term research, and/or clinical studies conducted by affiliated sponsors and/or self-reporting of health-related data, data will be retained for maximum 10 years after last data collection.
We may need to transfer your information to other companies or service providers in countries outside the European Economic Area (EEA). The EEA consists of countries in the European Union, Switzerland, Iceland, Liechtenstein, and Norway: they are considered to have equivalent laws when it comes to data protection and privacy. This kind of data transfer may happen if our servers (i.e., where we store data) or our suppliers and service providers are based outside the EEA, or if you use our services and products while visiting countries outside this area. If INNOVATION SPRINT SRL sends your information to a country that is not in the EEA, we will make sure that your information is properly protected. We will always ensure that there is a proper legal agreement that covers the data transfer. In addition, if the country is not considered to have laws that are equivalent to EU data protection standards then we will ask the 3rd party to enter into a legal agreement that reflects those standards. In such cases, specific privacy notices are made available.
Data hosting of Healthentia is utilizing the services of Microsoft Azure in servers of European Union member states. Microsoft’s contractual commitments with regards to GDPR can be found in the Online Services Data Protection Addendum:
https://www.microsoftvolumelicensing.com/DocumentSearch.aspx?Mode=2&Keyword=DPA.
Data hosting of Healthentia Mobile-app tracking and analytics data is utilizing the services of Mixpanel and Firebase-Google, and their contractual commitments with regards to GDPR can be found in the Online Services Data Protection Addendums: https://mixpanel.com/legal/dpa/ and https://firebase.google.com/terms/data-processing-terms.
Video conferencing services are provided by «Vidyo Cloud Services» (the Vidyo cloud subscription service provides access to the Vidyo Cloud Applications enabling video collaboration among Subscriber’s Users using supported devices). A signed Data Processing Agreement has been signed between INNOVATION SPRINT SRL and Vidyo (Enghouse). No transfer of data outside the EU/EEA area takes place in this case.
INNOVATION SPRINT SRL ensures that you can under specific circumstances exercise all relevant rights in relation to your personal data, such as the right of access to your data, right to rectification, right to erasure, right to data portability, right to restriction of processing, right to object, right not be subject to automated decision making if human intervention is not taken under consideration and the necessity of the processing is not granted, and finally right of lodging a complaint towards the supervisory authority (https://www.dataprotectionauthority.be/citizen).
You can exercise your rights at any time by contacting us here: dpo@healthentia.com. An identification stage might be required before proceeding towards fulfilling your request. In this case, we will reply within one month or up to three after informing for the reasons of delay. However, if you still have doubts about the information provided by us upon exercising your rights you also have the right to lodge a complaint with a supervisory authority.
Use of the personal data collected is subject to the Privacy Policy in effect at the time such information is used. As INNOVATION SPRINT SRL evolves, we may need to update this Policy from time to time to keep pace with changes in the Service and laws applicable to us and to you; we will, however, always maintain our commitment to respect your privacy.
If we make material changes in the way we use personal data, we will notify you by posting an announcement on our website, and we may ask for your consent to such changes if required by the applicable law. If you disagree with any changes in this Policy and do not wish your information to be subject to the revised Policy, you will need to close your account (you can use the DELETE ACCOUNT option of the Healthentia Mobile-app menu).
Innovation Sprint SRL, Address: Clos Chapelle-aux-Champs 30, 1200 Brussels, Belgium, Tel: +32 2 880 62 90, TVA BE 0648786874).
If you have questions, comments or requests about this Policy and your Personal Data, please contact us by submitting a request at: dpo@healthentia.com.
The present Privacy Policy was reviewed on March 1st, 2025.