PRIVACY POLICY

  1. Introduction

INNOVATION SPRINT SPRL values the privacy of your personal data and your usage of our Service and Data.

The mission of INNOVATION SPRINT SPRL is to provide Services to Life Sciences, Clinical Research domain and to citizens. To achieve its mission, INNOVATION SPRINT SPRL 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 SPRL collects and processes your personal data through the Healthentia App and informs you about your rights in accordance with the General Data Protection Regulation of the EU 2016/679, also known as GDPR.

  1. Information collection and purpose of use

To achieve its mission, INNOVATION SPRINT SPRL makes features and functionalities available through our mobile application HEALTHENTIA (Healthentia App), and other information provided as part of the INNOVATION SPRINT SPRL services (“Services”) to enable data collection during Clinical Studies or long-term research activities conducted by INNOVATION SPRINT SPRL.

Healthentia is an eClinical solution that facilitates the clinical trial optimization, by accelerating the trial processes, reducing the failure rate, and validating drug/intervention efficacy and effectiveness with Real World Data insights. Healthentia eClinical solution is collecting data from patients and investigators by means of the Healthentia App. Collected data is used for the needs of clinical studies of sponsors as described in their separate privacy policies (when INNOVATION SPRINT SPRL acts as processor), while processing of data (also by means of Artificial Intelligence – A.I.) allows the provision of smart services to the patients, as well as the long-term research activities of INNOVATION SPRINT SPRL.

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 Healthentia App, we will process your data based on:

The consent is registered in Healthentia through the mobile app.

  1.  What is personal data

Personal data means any information relating to you, which allows us to identify you, such as your name, contact details and information about your access to our mobile app and other services and any information related to your health status.

Details of the Personal Data we (INNOVATION SPRINT SPRL) may collect, and why we collect it, follows in the next section.

  1. What types of personal data does INNOVATION SPRINT SPRL collect

Registering an account in HEALTHENTIA App is possible from the mobile application with the use of an Email. As initial step, we only collect the Email address, which is required for the registration purpose.

In general, we collect the information you provide:

Specifically, after logging in HEALTHENTIA App you can report outcomes (e.g. symptoms) and if you have paired a HEALTHENTIA compatible wearable device with your smartphone, we can also collect activity data (number of steps taken, distance covered, amount of calories burned, body weight, heart rate, sleep stages, active minutes, kcal, type of physical activities and related information), which is provided by 3rd parties, or the device sensors based on your preferences and your agreement to use your data from 3rd parties. 

INNOVATION SPRINT SPRL, as controller, may use collected data for long-term research, such as creating behavioural and lifestyle models.

If you accept to be contacted for participating in clinical studies conducted by sponsors/promoters (e.g. pharmaceutical industries, hospitals, investigators) through an explicit consent, your profile will be available in search queries of interested partners (e.g. investigators, pharmaceuticals) to receive invitation for future studies.

In addition, you can participate in a clinical study by using a code, or selecting a running study, or via Email invitation. If you are admitted to a study, which is managed by a 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 SPRL acting as processor. For these studies, you will be first asked to read additional terms from the data controller before you give your consent.

  1. Device information

When you access our mobile app, our servers may record data regarding your device and the network you are using to connect with INNOVATION SPRINT SPRL, 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.

  1. Information from third – parties

We may collect information about your activities on and off INNOVATION SPRINT SPRL from third-party partners, such as activity data information, e.g. steps from device providers, or nutritional information from other services, after of course your provide your consent to the relevant provider based on your preferences and your agreement to use your data from 3rd parties. 

  1. Is personal information disclosed to third – parties?

Regarding the abovementioned third-party partners of INNOVATION SPRINT SPRL, we ensure that any processing of the personal data we may disclose to them is subject to the terms of this policy and concerns exclusively the defined by INNOVATION SPRINT SPRL purposes as described above. For that reason, 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 the purposes defined by us, and not further in manner that is incompatible with our purposes, and in any case in compliance with the applicable law.

If you accept to be invited to clinical studies by other parties acting as controllers, you will also grant access to the controllers of the study, who will provide you with additional privacy terms and obtain your consent.

 

  1. Security measures

INNOVATION SPRINT SPRL 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 SPRL 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 SPRL and our hosting partners restrict physical and network access to this facility to select trained staff. Your INNOVATION SPRINT SPRL 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 SPRL is not responsible for any third party’s actions or their security controls with respect to personal information they may collect or process via their websites, services or otherwise.

  1. Cookies

Healthentia App does not use cookies, however, the application 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.

  1. Data Retention

INNOVATION SPRINT SPRL 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, sharing data with sponsors/promoters and for the self-reporting of health-related data, data will be retained for maximum 10 years after last data collection.

  1. International Transfers

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 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 third 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

  1. Your Rights

INNOVATION SPRINT SPRL 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, 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 right of lodging a complaint with a supervisory authority.

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.

  1. Changes to this Privacy Policy

Use of the information we collect now is subject to the Privacy Policy in effect at the time such information is used. As INNOVATION SPRINT SPRL 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 you; we will, however, always maintain our commitment to respect your privacy.

If we make material changes in the way we use Personal information, we will notify you by posting an announcement on our website, and we may ask for your consent to such changes if required by 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 following the above.

  1. How to contact us

Under the General Data Protection Regulation, INNOVATION SPRINT SPRL acts either as data controller or as data processor (Innovation Sprint SPRL, Address: Clos Chappele-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 Oct 30, 2020.