Privacy Policy
Safey Medical Devices Limited (collectively referred to in this privacy notice as we, us, and our) takes its data protection and privacy responsibilities seriously. This privacy notice (Notice) explains how we (as the data controller of your personal information for the purposes of data protection laws) collect, use and share personal information in connection with your use of the our mobile application app (Safey) and associated services (Services), including:
· What personal information we collect and when and why we use it;
· How we share personal information;
· Transferring personal information globally;
· Explaining more about direct marketing;
· How we protect and store personal information;
· Legal rights available to help manage your privacy; and
· How you can contact us for more support.
For the purposes of this Notice and applicable data protection laws, personal data (or personal information) means any information about an individual from which that individual can be identified. It does not include data where the identity has been removed (anonymous data).
We may amend this Notice from time to time to keep it up to date with legal requirements and the way we operate our business. Please regularly check these pages for the latest version of this Notice.
You might find external links to third party websites on through the App and in connection with our Services. This Notice does not apply to your use of a third party site and you should consult the privacy policies and other terms of use on such sites.
Clinical trials and research studies
In particular, please note that if you use the App and access our Services as part of a clinical trial or research project being led by a third party organisation (such as a pharmaceutical company or a university) then this Notice describes how we will use your personal information only, and not how the organisation running that clinical trial or research project will use your personal information.
In these circumstances, we will process your personal information on behalf of that third party organisation and share certain of your information with them based on the permissions you have provided to that third party organisation as part of your participation in the clinical trial or research study. For further information about how the third party running the trial or study in which you are involved will use your personal information, you should consult the relevant third party’s privacy policies and terms of participation.
What personal information we collect and when and why we use it
The personal information we collect and the purposes for which we use it will depend on who the information relates to. This Notice deals with our use of the personal information of registered users of the App (Users) as well as those third parties who are selected to receive notifications in respect of a User’s compliance with their medication dosage requirements (Notified Parties).
Where you are a User of the App
When we collect information
We collect information about you when you download and register with the App and access to the Services. You may update this information on an ongoing basis to reflect changes to your circumstances for the duration of your use of the App and access to the Services.
In certain circumstances we may obtain personal information about you and identified below directly from your Notified Parties.
Personal information we collect and use
We collect following information about you when you download and register with the App and access our Services:
· Your name
· Your email address
· Your gender
· Your height, weight, and other physical attributes
· Details of your prescribed medication(s) and associated health condition(s)
· Lung function test parameters
· Blood pressure readings
· Blood glucose readings
We request that you ensure all information you provide to us is accurate. If you become aware that any of the information is no longer accurate or if your circumstances change, you should contact us.
Location Permissions and Data:
Our Safey App uses Ble (Bluetooth Low Energy) to communicate with our Safey Devices. To access BLE we need permission for Location in Android. We do not store or use your location for any other purposes.
We do not access data protected by location permissions (e.g., ACCESS_FINE_LOCATION, ACCESS_COARSE_LOCATION, ACCESS_BACKGROUND_LOCATION) after it is no longer necessary to deliver current features or services in our app.
We never request location permissions from users for the sole purpose of advertising or analytics.
Our Apps request’s the minimum scope necessary (i.e., coarse and background) to provide the current feature requiring location and you should reasonably expect that the feature or service needs the level of location requested. Our Safey App uses Ble (Bluetooth Low Energy) to communicate with our Safey Devices. To access BLE we need permission for Location in Android. We do not store or use your location for any other purposes.
Our Background location is only used to provide features beneficial to you and is relevant to the core functionality of the app.
Why we use your personal information, and the legal basis for using your personal information
Once you have provided us with the information referred to above, we will use that information for the following purposes:
How we use your information
What is the legal basis for our use of your information
To create your App account and manage your use of your App account and access to the Services.
Our use of your personal information for this purpose is necessary to perform a contract which we have in place with you (in accordance with the terms and conditions of the App). To the extent that the creation and management of your account requires our use of any personal information which identifies any medical condition or your health status then we will only process that information where we have your consent to do so.
How we use your information
To create your App account and manage your use of your App account and access to the Services.
To communicate and interact with you in relation to your App account (for example, to let you know about changes to the App term and conditions, changes to the App and/or the Services, or changes to this Notice).
To contact you to remind you of your medication requirements and dosages (either through an App notification or by email or by other means that we think would be helpful to you).
To contact your Notified Parties to notify them of your medication requirements and your compliance with them (i.e. to inform those Notified Parties if you are missing required dosages of your medication for whatever reason).
To contact you to take part in market research surveys and obtain feedback on the App and our Services, and better understand how we can improve the App and our Services.
To carry out research and surveys for medical and statistical purposes. We will use anonymisation techniques and aggregated datasets (so that personal information can no longer be associated with you or any other individual) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.
To send marketing promotional materials to you by email in respect of our products and services which we believe may be of interest to you.
To respond to your queries and provide you technical support in relation to the App and our Services.
To enable us to monitor and improve the performance of our website and our services.
In order to enable us to comply with any legal or regulatory requirements.
For our business and accounting records.
What is the legal basis for our use of your information
Our use of your personal information for this purpose is necessary to perform a contract which we have in place with you (in accordance with the terms and conditions of the App). To the extent that the creation and management of your account requires our use of any personal information which identifies any medical condition or your health status then we will only process that information where we have your consent to do so.
Our use of your personal information is necessary for legitimate interests that we pursue.
Our use of your personal information for this purpose is necessary to perform a contract which we have in place with you (in accordance with the terms and conditions of the App).To the extent that creation and communication of these notifications requires our use of any personal information which identifies any medical condition or your health status then we will only process that information where we have your consent to do so.
Our use of your personal information for this purpose is necessary to perform a contract which we have in place with you (in accordance with the terms and conditions of the App). To the extent that creation and communication of these notifications requires our use of any personal information which identifies any medical condition or your health status then we will only process that information where we have your consent to do so.
Our use of your personal information is necessary for legitimate interests that we pursue.
Our anonymisation of your personal information is necessary for legitimate interests that we pursue. Our subsequent use of this anonymised and aggregated data is not subject to the terms of this Notice.
We will use your information in this way where you have provided your consent to us using the personal information. We will at all times respect your preferences in relation to any direct marketing activity which we undertake.
Our use of your personal information is necessary for legitimate interests that we pursue.
Our use of your personal information is necessary for legitimate interests that we pursue.
Our use of your personal information is necessary to comply with a relevant legal or regulatory obligation that we have.
Our use of your personal information is necessary for legitimate interests that we pursue.
To communicate and interact with you in relation to your App account (for example, to let you know about changes to the App term and conditions, changes to the App and/or the Services, or changes to this Notice).
Our use of your personal information is necessary for legitimate interests that we pursue.
To contact you to remind you of your medication requirements and dosages (either through an App notification or by email or by other means that we think would be helpful to you).
Our use of your personal information for this purpose is necessary to perform a contract which we have in place with you (in accordance with the terms and conditions of the App).To the extent that creation and communication of these notifications requires our use of any personal information which identifies any medical condition or your health status then we will only process that information where we have your consent to do so.
To contact your Notified Parties to notify them of your medication requirements and your compliance with them (i.e. to inform those Notified Parties if you are missing required dosages of your medication for whatever reason).
Our use of your personal information for this purpose is necessary to perform a contract which we have in place with you (in accordance with the terms and conditions of the App). To the extent that creation and communication of these notifications requires our use of any personal information which identifies any medical condition or your health status then we will only process that information where we have your consent to do so.
To contact you to take part in market research surveys and obtain feedback on the App and our Services, and better understand how we can improve the App and our Services.
Our use of your personal information is necessary for legitimate interests that we pursue.
To carry out research and surveys for medical and statistical purposes. We will use anonymisation techniques and aggregated datasets (so that personal information can no longer be associated with you or any other individual) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.
Our anonymisation of your personal information is necessary for legitimate interests that we pursue. Our subsequent use of this anonymised and aggregated data is not subject to the terms of this Notice.
To send marketing promotional materials to you by email in respect of our products and services which we believe may be of interest to you.
We will use your information in this way where you have provided your consent to us using the personal information. We will at all times respect your preferences in relation to any direct marketing activity which we undertake.
To respond to your queries and provide you technical support in relation to the App and our Services.
Our use of your personal information is necessary for legitimate interests that we pursue.
To enable us to monitor and improve the performance of our website and our services.
Our use of your personal information is necessary for legitimate interests that we pursue.
In order to enable us to comply with any legal or regulatory requirements.
Our use of your personal information is necessary to comply with a relevant legal or regulatory obligation that we have.
For our business and accounting records.
Our use of your personal information is necessary for legitimate interests that we pursue.
As indicated above, where we seek to use any of your personal information which identifies a medical condition or your health status we will only do so where we have your explicit consent to do so. You should note that if you do not provide your consent for us to use this information that we may not be able to provide our Services with the same accuracy or quality as we would if you did provide your consent to our use of that information.
Where you are a Notified Party
When we collect information
We collect information about you when you download and register with the App and access to the Services. You may update this information on an ongoing basis to reflect changes to your circumstances for the duration of your use of the App and access to the Services.
In certain circumstances we may obtain personal information about from directly from the User who has identified you as a Notified Party in connection with that User’s use of the App and the Services.
Personal information we collect and use
We collect following information about you when you download and register with the App and access our Services:
· Your name
· Your email address
· Your relationship with the relevant User(s) (i.e. friend, family member, guardian, clinician/other healthcare professional
· Details of your qualifications and job role (i.e. if you are a clinician/other healthcare professional, we may ask you for details of your qualification status).
We request that you ensure all information you provide to us is accurate. If you become aware that any of the information is no longer accurate or if your circumstances change, you should contact us.
Why we use your personal information, and the legal basis for using your personal information
Once you have provided us with the information referred to above, we will use that information for the following purposes:
How we use your information
What is the legal basis for our use of your information
How we use your information
To create your App account and manage your use of your App account and access to the Services
To communicate and interact with you in relation to your App account (for example, to let you know about changes to the App term and conditions, changes to the App and/or the Services, or changes to this Notice).
To contact you to notify the medication requirements of the User associated with your use of the App and the Services and the User's compliance with those medication requirements (i.e. to inform you if a user is missing required dosages of their medication for whatever reason).
To contact you to take part in market research surveys and obtain feedback on the App and our Services, and better understand how we can improve the App and our Services.
To send marketing promotional materials to you by email in respect of our products and services which we believe may be of interest to you.
To respond to your queries and provide you technical support in relation to the App and our Services.
To enable us to monitor and improve the performance of our website and our services.
In order to enable us to comply with any legal or regulatory requirements.
For our business and accounting records.
What is the legal basis for our use of your information
Our use of your personal information for this purpose is necessary to perform a contract which we have in place with you (in accordance with the terms and conditions of the App).
Our use of your personal information is necessary for legitimate interests that we pursue.
Our use of your personal information for this purpose is necessary to perform a contract which we have in place with you (in accordance with the terms and conditions of the App).
Our use of your personal information is necessary for legitimate interests that we pursue.
We will use your information in this way where you have provided your consent to us using the personal information. We will at all times respect your preferences in relation to any direct marketing activity which we undertake.
Our use of your personal information is necessary for legitimate interests that we pursue.
Our use of your personal information is necessary for legitimate interests that we pursue.
Our use of your personal information is necessary to comply with a relevant legal or regulatory obligation that we have.
Our use of your personal information is necessary for legitimate interests that we pursue.
To create your App account and manage your use of your App account and access to the Services
Our use of your personal information for this purpose is necessary to perform a contract which we have in place with you (in accordance with the terms and conditions of the App).
To communicate and interact with you in relation to your App account (for example, to let you know about changes to the App term and conditions, changes to the App and/or the Services, or changes to this Notice).
Our use of your personal information is necessary for legitimate interests that we pursue.
To contact you to notify the medication requirements of the User associated with your use of the App and the Services and the User's compliance with those medication requirements (i.e. to inform you if a user is missing required dosages of their medication for whatever reason).
Our use of your personal information for this purpose is necessary to perform a contract which we have in place with you (in accordance with the terms and conditions of the App).
To contact you to take part in market research surveys and obtain feedback on the App and our Services, and better understand how we can improve the App and our Services.
Our use of your personal information is necessary for legitimate interests that we pursue.
To send marketing promotional materials to you by email in respect of our products and services which we believe may be of interest to you.
We will use your information in this way where you have provided your consent to us using the personal information. We will at all times respect your preferences in relation to any direct marketing activity which we undertake.
To respond to your queries and provide you technical support in relation to the App and our Services.
Our use of your personal information is necessary for legitimate interests that we pursue.
To enable us to monitor and improve the performance of our website and our services.
Our use of your personal information is necessary for legitimate interests that we pursue.
In order to enable us to comply with any legal or regulatory requirements.
Our use of your personal information is necessary to comply with a relevant legal or regulatory obligation that we have.
For our business and accounting records.
Our use of your personal information is necessary for legitimate interests that we pursue.
How we share your personal information
When you use our App and/or our Services (whether as a User or a Notified Party) we may share your personal information with various of our partners, service providers, and regulators in the manner and for the purposes described below:
· with third parties who help manage our business and deliver services. These third parties have agreed to confidentiality restrictions and use any personal information we share with them or which they collect on our behalf solely for the purpose of providing the contracted service to us. These may include organisations who carry out market research or surveys on our behalf and vendors who help manage our IT and back office systems – for example Google (in relation to our use of the Firebase development platform) and Amazon Web Services (in relation to our hosting of the App and the personal information we process about you). As explained, we ensure that all such third parties are bound by terms of confidentiality and are not permitted to use for information for their own purposes, or to contact you for marketing purposes or for any other purposes not connected with the delivery of their services to us;
· where you are a User of the App and the Services, we will share certain of your information with your Notified Parties in order to fulfil the purposes described in this Notice;
· where you are a Notified Party, we will share certain of your information with the User(s) associated with your use of the App and the Services in order to fulfil the purposes described in this Notice;
· with our regulators, which may include the Information Commissioner, to comply with all applicable laws, regulations and rules, and requests of law enforcement, regulatory and other governmental agencies;
· we may share in aggregate, statistical form, non-personal information regarding the users of our App and our Services with our service providers and/or advertisers; and
· if, in the future, we sell or transfer some or all of our business or assets to a third party, we may disclose information to a potential or actual third party purchaser of our business or assets.
As explained above, please note that if you use the App and access our Services as part of a clinical trial or research project being led by a third party organisation (such as a pharmaceutical company or a university) then we will process your personal information on behalf of that third party organisation and share certain of your information with them based on the permissions you have provided to that third party organisation as part of your participation in the clinical trial or research study. For further information about how the third party running the trial or study in which you are involved will use your personal information, you should consult the relevant third party’s privacy policies and terms of participation.
Transferring personal information globally
We operate on a global basis. Accordingly, your personal information may be transferred and stored in countries outside the EU that are subject to different standards of data protection. We will take appropriate steps ensure that transfers of personal information are in accordance with applicable law and carefully managed to protect your privacy rights and interests and transfers are limited to countries which are recognized as providing an adequate level of legal protection or where we can be satisfied that alternative arrangement are in place to protect your privacy rights. To this end:
· where we transfer your personal information to third parties who help provide our products and services, we obtain contractual commitments from them to protect your personal information. Some of these assurances are well recognized certification schemes like the EU – US Privacy Shield for the protection of personal information transferred from within the EU to the United States; or
· where we receive requests for information from law enforcement or regulators, we carefully validate these requests before any personal information are disclosed.
You have a right to contact us for more information about the safeguards we have put in place (including a copy of relevant contractual commitments) to ensure the adequate protection of your personal information when this is transferred as mentioned above.
Explaining more about direct marketing
How we use personal information to keep you up to date with our products and services
We may use personal information to let you know about our products and services that we believe will be of interest to you. We may contact you by email or through other communication channels that we think you may find helpful. In all cases, we will respect your preferences for how you would like us to manage marketing activity with you.
How you can manage your marketing preferences
To protect privacy rights and to ensure you have control over how we manage marketing with you:
· we will take steps to limit direct marketing to a reasonable and proportionate level and only send you communications which we believe may be of interest or relevance to you;
· you can ask us to stop direct marketing at any time – you can ask us to stop sending email marketing, by following the ‘unsubscribe’ link you will find on all the email marketing messages we send you. Alternatively you can contact us using the contact details at the end of this Notice. Please specify whether you would like us to stop all forms of marketing or just a particular type; and
· as explained, we ensure that no third party with whom we share your personal information is permitted to contact you for marketing purposes unless you have specifically provided your consent for them to do so.
We recommend you routinely review the privacy notices and preference settings that may be available to you on the websites of our partners, and any social media platforms.
How we protect and store your information
Security
We have implemented and maintain appropriate technical and organisational security measures, policies and procedures designed to reduce the risk of accidental destruction or loss, or the unauthorised disclosure or access to such information appropriate to the nature of the information concerned. Measures we take include placing confidentiality requirements on our staff members and service providers, and destroying or permanently anonymising personal information if it is no longer needed for the purposes for which it was collected.
Storing your personal information
We will store your personal information for as long as is reasonably necessary for the purposes for which it was collected, as explained in this Notice. In some circumstances we may store your personal information for longer periods of time, for instance where we are required to do so in accordance with legal, regulatory, tax, accounting requirements. In specific circumstances we may store your personal information for longer periods of time so that we have an accurate record of your dealings with us in the event of any complaints or challenges, or if we reasonably believe there is a prospect of litigation relating to your personal information or dealings.
Legal rights available to help manage your privacy
Subject to certain exemptions, and in some cases dependent upon the processing activity we are undertaking, you have certain rights in relation to your personal information, as described below:
Right to accesspersonal information
You have a right to request that we provide you with a copy of your personal information that we hold and you have the right to be informed of: (a) the source of your personal information; (b) the purposes, legal basis and methods of processing; (c) the data controller’s identity; and (d) the entities or categories of entities to whom your personal information may be transferred.
Right to rectify or erasepersonal information
You have a right to request that we rectify inaccurate personal information. we may seek to verify the accuracy of the personal information before rectifying it.
You can also request that we erase your personal information in limited circumstances where:
· it is no longer needed for the purposes for which it was collected; or
· you have withdrawn your consent (where the data processing was based on consent); or
· following a successful right to object (see the Right to object to the processing of your personal information section below); or
· it has been processed unlawfully; or
· to comply with a legal obligation to which we are subject.
We are not required to comply with your request to erase personal information if the processing of your personal information is necessary:
· for compliance with a legal obligation; or
· for the establishment, exercise or defence of legal claims.
Right to restrict the processing of your personal information
You can ask us to restrict your personal information, but only where:
· its accuracy is contested, to allow us to verify its accuracy; or
· the processing is unlawful, but you do not want it erased; or
· it is no longer needed for the purposes for which it was collected, but we still need it to establish, exercise or defend legal claims; or
· you have exercised the right to object, and verification of overriding grounds is pending.
We can continue to use your personal information following a request for restriction where:
· we have your consent; or
· to establish, exercise or defend legal claims; or
· to protect the rights of another natural or legal person.
Right to transfer your personal information
You can ask us to provide your personal information to you in a structured, commonly used, machine-readable format, or you can ask to have it transferred directly to another data controller, but in each case only where:
· the processing is based on your consent or on the performance of a contract with you; and
· the processing is carried out by automated means.
Right to object to the processing of your personal information
You can object to any processing of your personal information which has our legitimate interests as its legal basis, if you believe your fundamental rights and freedoms outweigh our legitimate interests.
If you raise an objection, we have an opportunity to demonstrate that we have compelling legitimate interests which override your rights and freedoms.
Right to object to how we use your personal information for direct marketing purposes
You can request that we change the manner in which we contact you for marketing purposes.
Right to lodge a complaint with your local supervisory authority
You have a right to lodge a complaint with the Information Commissioner (www.ico.org.uk or by phone at 0303 123 1113) or if you have concerns about how we are processing your personal information.
We ask that you please attempt to resolve any issues with us first, although you have a right to contact the Information Commissioner at any time.
We may ask you for additional information to confirm your identity and for security purposes, before disclosing the personal information requested to you in response to any request raised by you. We reserve the right to charge a fee where permitted by law, for instance if your request is manifestly unfounded or excessive.
You can exercise your rights by contacting us. Subject to legal and other permissible considerations, we will make every reasonable effort to honour your request promptly or inform you if we require further information in order to fulfil your request.
We may not always be able to fully address your request, for example if it would impact the duty of confidentiality we owe to others, or if we are legally entitled to deal with the request in a different way.
Contact us
We can be contacted in the following ways:
Email: [email protected]
Postal Address: City View House, 5 Union Street, Manchester M12 4JD, UK
If you have any questions, concerns or complaints regarding our compliance with this Notice and the data protection laws, or if you wish to exercise your rights, we encourage you to first contact us. We will investigate and attempt to resolve complaints and disputes and will make every reasonable effort to honour your wish to exercise your rights as quickly as possible and in any event, within the timescales provided by data protection laws.
Mechanism to Submit Enquiries & Developer Contact
We can be contacted in the following ways:
Email: [email protected]
Postal Address: City View House, 5 Union Street, Manchester M12 4JD, UK
Data Deletion Policy
Contact Us if you would like to update your Personal Information, delete your account, change your preferences, or have any questions or concerns about your privacy, you may contact us at [email protected]. Please note that some information may remain in our records after the deletion of your account, including any information or records we are legally obligated to retain.
As we continue to innovate, we encourage anyone with ideas, concerns, or questions to contact us
Send us a message and we’ll get back to you within few business hours!
Safey Medical Devices Ltd.
City View House, 5 Union Street,
Manchester M12 4JD, UK
Safey Medical Devices Ltd.
11325 Random Hills Road,
Suite 360, Fairfax, VA 22030, USA
Safey Medical Devices Pvt Ltd.
Sawardari, Chakan MIDC – Phase 2, Pune, Maharashtra, India
