Last update: 28 June 2022
App Privacy Policy
florio® STUDY App
This product allows you to record and display data related to the FREEDOM study. It includes the mobile application florio STUDY App (the "App") and it also provides a web-based dashboard through which your physician can monitor your data. This App Privacy Policy complements the general information provided in the context of the study consent and obtaining the general study data consent.
We process your personal data listed below, including sensitive health data, to the extent you make them available to us via the App:
· information listed in the study description for which you have provided your consent;
· specific for the App: information on activity automatically collected through the App or a fitbit wearable; we use the Thryve Health SDK, a product of mHealth Pioneers GmbH, Körtestrasse 10, 10967 Berlin, a data protection-certified spin-off of the Fraunhofer Institute for Computer Graphics, for the automatic collection, storage and subsequent processing of your activity and health data collected through other sources/devices/services you use (e.g. smartphones, smartwatches, fitness trackers and other digital health services). Such data may include vital data (e.g. heart rate) and activity data (e.g. steps taken, covered distance, activity duration, activity types with start and end time such as walking, running, biking). It will be imported based on the App access to the respective source/device/service. Your data is processed exclusively on our behalf and in accordance with the requirements of Art. 28 GDPR. mHealth Pioneers GmbH has no access to other data stored in the App. All personal information is stored fully encrypted only.
We process your data for the following purposes and on the following legal bases:
· to provide the App to the extent necessary for the performance of the contract which we have concluded with you based on the terms of use for the App;
· to provide customer support, respond to your questions or requests for information and communicate with you to the extent this is necessary, for the purposes of our legitimate interest in ensuring efficient and user-friendly communication with the users;
· to improve the App's security to the extent this is necessary, for the purposes of our legitimate interest in protecting the App and the information processed in the App against risks, including the loss of data or unauthorised access to data;
· data collected through Thryve to provide additional information which may be relevant for the assessment of your health on the basis of your explicit consent given to us.
We also process your data, including sensitive health data, for the purpose of the study on the basis of your consent as set out in the study description and as confirmed with your study data consent.
We will not use your personal data for marketing purposes.
Your data will not be shared with any third parties without your prior consent unless this is expressly agreed in the study contract and encompassed by the general study data consent. Apart from this, your data is shared with Florio GmbH, Wilhelm-Wagenfeld-Straße 22, 80807 Munich/Germany, who acts as a processor on the basis of a data processing agreement and provides the App.
The App is hosted on servers in Germany, which means that your data are stored in Germany.
We take reasonable steps to protect your data from loss, misuse, unauthorised access, disclosure, alteration or destruction by taking security precautions that provide for industry‑standard protection. However, data transmission over the internet cannot be guaranteed to be completely secure. The App is regularly tested by external security experts, who probe our systems for vulnerabilities, and confirm that defences against malicious attack or accidental data loss are as strong as possible.
We will store your data only for the period necessary to fulfil the purposes of the study as outlined in the general study description.
We reserve the right to make changes to the App Privacy Policy in the future. In case of material changes (e.g., in particular, any changes that materially affect your rights), we will notify you. The App Privacy Policy in the respective applicable version can be accessed and viewed on our App at any time.
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