We are Infohealth LTD. Our company number is 04004930 and our office address is Lynwood House, 373 – 375 Station Road, Harrow, HA1 2AW, ENGLAND. NowPatient Diabetes is committed to making sure you receive the service you expect while ensuring we protect your privacy. In this policy, you’ll find out exactly what information we collect from you and how we then use this to deliver our services. You will also find out about your rights.

We want to make sure that you understand what personal data we collect from you and how and why we use this information. The personal data that we process will depend on your level of interaction with us.

We collect some or all of the following information as part of the screening for eligibility to our research programme:

The amount of data we hold will depend on how we recruit you and how many questions you answered. We hold this data in HubSpot. We hold this information to keep you in the loop on any future research and other information that may be of interest.

If you consented to receive marketing from us we will hold this information on file until the point you may decide to opt-out. For further information on marketing preferences refer to the section under ‘Communication tools’ within this privacy policy.

If you request for your data to be deleted we will remove all data held with the exception to your contact details to ensure we do not communicate with you.

All items listed under ‘I am browsing your website’ also apply to you so we recommend you also review those.

We collect the following information as part of the screening for eligibility to our research programme and completion of the contractual NDA:

The amount of data we hold will depend on how we recruit you and how many questions you answered. We hold this data in HubSpot. We hold this information to provide you with access to the app, keep you in the loop on any future research and other information that may be of interest.

If you consented to receive marketing from us we will hold this information on file until the point you may decide to opt-out. For further information on marketing preferences refer to the section under ‘Communication tools’ within this privacy policy.

If you request for your data to be deleted we will remove all data held with the exception to the data held on the NDA, contact details and digital signature, which we keep for our legal obligations for 10 years.

We use TestFlight to give you access to the NowPatient Diabetes app. The data collected is your email address and your name.

All items listed under ‘I am browsing your website’ also apply to you so we recommend you also review those.

We will collect the following information for regulatory purposes as proof you are eligible for using the NowPatient Diabetes app, the NDA for our legal obligation and provide you with any support you may require:

If you request to leave the research programme and do not want to be contacted by us we will remove all data, with the exception to the data held on the NDA, contact details and digital signature, which we keep for our legal obligations for 10 years.

We collect personal data automatically, and manually from you, when you use the NowPatient Diabetes app. Your personal data is used for the app to function properly and to investigate future in-app features. Any use of tracking tools by the NowPatient Diabetes app or by the owners of third-party services used by the NowPatient Diabetes app serves the purpose of providing the service required to you, in addition to any other purposes as described in this privacy policy. Below provides a list of the sources of data used by the NowPatient Diabetes app, the data collected and why we hold it:

User Entered Data – Whilst using the NowPatient Diabetes app, you will provide data to us. This is stored in a secure, encrypted format on your device and by our data processor Back4App. This includes the food you ate and when you ate it, blood sugar readings, activity performed, and also the insulin treatment used at any time. We also process data about your exercise or dietary intentions. When you set up the NowPatient Diabetes app, you will have told us what type of insulin you use. This data is used to provide the main functionality of the app, and help you make decisions around managing your diabetes. We also pseudonymise the data and use it for the purposes of developing more intelligent in-app features, for example, improving the relevance of the What’s Ahead graph and for regulatory purposes for identifying usage and benefits of the app.

Apple HealthKit – If you give it the necessary permissions, the NowPatient Diabetes app accesses and stores your data from Apple HealthKit. This is stored in a secure, encrypted format on your device and by our data processor Back4App. We process and store the below information:

We store this for developing app features and complying with medical regulations. In the future we may store more data from Apple Health Kit, when this happens we will communicate the changes to you.

The lawful basis for processing this health data is based on your consent. You can withdraw your consent for processing at any time by contacting us on support@nowpatient.com

Back4App – User entered data and Apple HealthKit data is stored by our data processor Back4App. All data is transmitted from your device using the encrypted HTTPS protocol to ensure the safe transit of your data to Back4App. We have a signed Data Processing Agreement with them and rely on Standard Contractual Clauses when they transfer data outside of the EU. This means the EU considers that they offer a level of data protection at least equal to GDPR requirements.

TestFlight – We use TestFlight to give you access to the NowPatient Diabetes app and release new versions. The data collected is:

While the NowPatient Diabetes app is in beta phase we keep it for regulatory purposes in the case of removing non-target users and to improve the app experience. If you leave the research programme we will remove this data.

XCode – We use XCode to collect data about what happened on your device just before and during a crash. We use these so we can fix any issues with the NowPatient Diabetes app and improve your experience. We store this data for up to 3 months to allow adequate time to investigate and improve your experience.

The data collected is:

Firebase Crashlytics – We use Firebase Crashlytics to learn what happens when the app crashes or has performance problems. The data collected is:

We use this for regulatory purposes to ensure that the NowPatient Diabetes app continues to be safe to use.

Firebase Analytics is an analytics service provided by Google Inc. In order to understand Google’s use of Data, consult Google’s partner policy. This Application uses identifiers for mobile devices (Advertising Identifier for iOS, respectively) and technologies similar to cookies to run the Firebase Crashlytics service. Users may opt-out of certain Firebase features through applicable device settings, such as the device advertising settings for mobile phones.

Mixpanel – We use Mixpanel to learn how users are using the NowPatient Diabetes app. We have a view of what each of our individual users are looking at. The data collected is:

We use this for regulatory purposes to provide evidence of safety and benefits and for product development.

Mixpanel is an analytics tool. We have agreed to their Data Processing Agreement and rely on Standard Contractual Clauses when they transfer data outside of the EU. This means the EU considers that they offer a level of data protection at least equal to GDPR requirements.

If you have any concerns with how your data is being used or wish to opt-out please email us on support@nowpatient.com

HubSpot – we keep a store of these details for regulatory purposes, future app development and to provide you with any support you may require:

HubSpot transfers data outside of the EU. We ensure they are signed up to the US Privacy Shield, which means the EU considers that they offer a level of data protection at least equal to GDPR requirements.

Communication tools – we may use various tools to communicate with you to ensure you are provided with good service and you receive any support you may require. We will also use these tools to market to you if you have provided marketing consent. If you wish to opt-out of marketing consent at any time follow the unsubscribe link we make available in our communications. We ensure any tools we use that transfers data outside of the EU are considered by the EU as offering a level of data protection at least equal to GDPR requirements.

We may interview you in person or via video call for research purposes. The data we gather includes, but is not limited to, your experience with the NowPatient Diabetes app and feedback on features or designs of the app. Before we start the interview we will explain that we will record the conversation and provide details on why, as set out below:

“We’d like to check if you are OK that we record this conversation and keep a copy of the audio on file. We use the recording to provide evidence for what our users think about the app and potential new features for medical regulation purposes. The recording is stored up to 10 years and is audited annually by external regulators.”

We transfer the audio recording to a third-party cloud hosting system in the US. We ensure they are signed up to the US Privacy Shield, which means the EU considers that they offer a level of data protection at least equal to GDPR requirements.

From time to time, we may ask you to participate in surveys for research purposes, to get your feedback on your experience with the NowPatient Diabetes app and to help us measure its success. We ensure the survey tools we use offer a level of data protection at least equal to GDPR requirements, if outside of the EU.

We may request copies of your personal CGM data reports containing summarised details of your CGM data. This information will be used as part of our responsibilities as a medical device provider to determine and develop the ongoing safety and benefits of the NowPatient Diabetes app. Providing this information is optional and not a requirement to use the NowPatient Diabetes app.

We will pseudonymise the information provided to remove personal information that directly identifies you. We will then transfer the reports to a third-party cloud hosting system in the US for storage. We ensure they are signed up to the US Privacy Shield, which means the EU considers that they offer a level of data protection at least equal to GDPR requirements.

If you join our Slack Channel community, we use Slack as a data processor, which means it is NowPatient Diabetes, not Slack who controls your data. They are US-based but are signed up to US Privacy Shield, which means the EU considers that they offer a level of data protection at least equal to GDPR requirements.

When you join Slack, other users in the Channel will be able to see your contact details as well as any discussion data that you add to the channel. This data is stored for 10 years for regulatory purposes.

All items listed under ‘I am browsing your website’ also apply to you so we recommend you also review those.

We will collect the following information for regulatory purposes as proof you are eligible for using the NowPatient Diabetes app, for future app development and to provide you with any support you may require:

We collect personal data automatically, and manually from you when you use the NowPatient Diabetes app. Your personal data is used for regulatory purposes, for the app to function properly and future app development. Any use of tracking tools by the NowPatient Diabetes app or by the owners of third-party services used by the NowPatient Diabetes app serves the purpose of providing the service required to you, in addition to any other purposes as described in this privacy policy.

If you have deleted the NowPatient Diabetes app, request for your information to be deleted and no longer wish to hear from us we will remove all data, with the exception to your contact details to ensure we no longer communicate with you.

Below provides a list of the sources of data used by the NowPatient Diabetes app, the data collected and why we hold it:

HubSpot – we keep a store of these details for regulatory purposes, future app development and to provide you with any support you may require:

HubSpot transfers data outside of the EU. We ensure they are signed up to the US Privacy Shield, which means the EU considers that they offer a level of data protection at least equal to GDPR requirements.

If you have downloaded the NowPatient Diabetes app in the AppStore but we currently do not support your personal setup, we will keep a copy of any details you provide where you’ve requested contact with future developments that support the details you’ve provided.

If we support your personal setup and you are using the NowPatient Diabetes app, the following data sources also apply to you: User Entered Data, Apple HealthKit, Back4App, XCode, Mixpanel and Communication tools. You can find details of the data collected and why we hold it under the section “I qualified for the research programme and I am using the NowPatient Diabetes app.”

I have investor interest in NowPatient Diabetes or have been contacted about investing in NowPatient Diabetes

If you have expressed interest in investing in NowPatient Diabetes or have been contacted about investing in NowPatient Diabetes, we will store a copy of the following contact details:

We hold this information to keep you updated on investment opportunities. You can opt-out of investment contact from us at any time by emailing support@nowpatient.com

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Facebook uses cookies to track visitors to our business page. These cookies are set even if you do not have a Facebook account. They will track your Internet activities on and off Facebook. Despite the fact that only Facebook has access to the data from these cookies, not us, by creating and maintaining a Facebook business page, we are deemed responsible for the cookies being set. We have no way to prevent these cookies being used. We want to be as transparent as possible so you are aware of the way your data is being used by Facebook. For more information on Facebook’s data policies please refer to https://www.facebook.com/about/privacy/

We use AppsFlyer to learn how users find our app. We have a view of NowPatient Diabetes media users have seen, if the user interacted with the media, and whether that resulted in the NowPatient Diabetes app being installed. We cannot specifically identify you. The data collected is:

The AppsFlyer iOS SDK may use identifiers for mobile devices (Advertising Identifier for iOS) to identify you. Users may opt-out of certain AppsFlyer features through applicable device settings, such as the device advertising settings for mobile phones.

AppsFlyer iOS SDK transfers data outside the EU. We ensure they are signed up the the US Privacy Shield, which means the EU considers that they offer a level of data protection at least equal to GDPR requirements.

We carry out something called ‘profiling’ so we can understand the needs, behaviours and socio-demographic characteristics of our user base. This helps us make sure that we‘re offering the right research programme and services to the right people. Profiling also means we can tailor our offerings to you, enhancing your potential benefits. Profiling is also used to personalise features within the NowPatient Diabetes app to enhance your experience of the app by making features more personally relevant. The profiling we do is a combination of manual and automated.

Some of the data that we collect may be transferred to and stored at a destination outside the European Economic Area (‘EEA’). We take all steps reasonably necessary to ensure that your data is treated in accordance with this privacy policy and applicable privacy laws.

As a data subject you have certain rights under certain circumstances, your rights are listed below:

If you want to exercise any of these rights, please contact us and we will investigate the matter and respond to you within one month. Sometimes we may tell you that we need to a longer period of time to deal with your request and we will let you know if that is the case and explain why.

If, at any time, you feel that we haven’t processed your data fairly or you’re not satisfied with how we’ve handled your personal information, you can contact the Information Commissioner’s Office, who will look into this for you. For full details about how to share any concerns you may have, visit www.ico.org.uk/make-a-complaint

Our ICO registration number is ZA075677.

If you’d like to contact us about your data protection, please email support@nowpatient.com

Any changes we may make to our privacy policy in the future will be posted on this page – we recommend that you check back regularly. If the change is significant we will take steps to notify you. The version number and date released will always be listed below:

Version: 1.01

Latest update: 04 April 2024