Celiac AGY Clinical Study App

Version Date: December 2020

Introduction

Please read this Privacy Notice (the “Privacy Notice”) for the Celiac AGY Clinical Study app carefully before accepting it. Acceptance of this Privacy Notice will support secure communication between yourself and research staff for the Celiac AGY Clinical Study. BY ACCEPTING THIS PRIVACY NOTICE AND USING THE CELIAC AGY CLINICAL STUDY APP, YOU AFFIRM THAT YOU ARE OF LEGAL AGE TO ACCEPT THIS PRIVACY NOTICE, AND THAT YOU ARE AGREEING EITHER ON YOUR OWN BEHALF, OR ON BEHALF OF ANOTHER INDIVIDUAL FOR WHOM YOU HAVE ACTUAL AUTHORITY TO LEGALLY ACCEPT TO THIS PRIVACY NOTICE.

mmHg Inc., of 5-134, 11350 83 Ave, Clinical Sciences Building, University of Alberta, Edmonton AB, T6G 2G3, Canada, is the product owner, developer and controller of personal information transmitted through the Celiac AGY Clinical Study app.

MmHg Inc., of 5-134 Clinical Sciences Building, University of Alberta, Alberta, Canada, T6G 2G3, is the authorized distributor of the Celiac AGY Clinical Study app.

You may contact us at the addresses above or at agyceliac-support@mmhg.ca.

“You,” “your,” or the “user” in this Privacy Notice are referring to the individual using the Celiac AGY Clinical Study app. “mmHg,” “us,” “our,” or “we” in this Privacy Notice are referring to mmHg Inc.

mmHg recognizes the importance of data protection and privacy and is committed to protecting your personal information, including health-related information.

This Privacy Notice explains how we handle personal information including health-related information that you may provide to us through your use of the Celiac AGY Clinical Study app. This Privacy Notice does not apply to personal information collected by mmHg (including its subsidiaries and affiliates) via other methods, such as web sites, customer call centers; nor does this Privacy Notice apply to other third-party web sites.

YOUR USE OF THE CELIAC AGY CLINICAL STUDY APP CONSTITUTES, AND IS CONDITIONED UPON, YOUR ACCEPTANCE OF THIS PRIVACY NOTICE. IN CERTAIN EXCEPTIONAL CIRCUMSTANCES, MMHG’S DATA PROCESSORS MAY NEED TO ACCESS YOUR PERSONAL INFORMATION, INCLUDING HEALTH-RELATED INFORMATION. BY ACCEPTING, YOU EXPLICITLY ACKNOWLEDGE THAT THIS PRIVACY NOTICE WILL APPLY TO YOUR USE OF THE CELIAC AGY CLINICAL STUDY APP AND TO THE PROCESSING AND TRANSFER OF YOUR PERSONAL INFORMATION, INCLUDING HEALTH-RELATED INFORMATION, AS SET OUT IN THIS PRIVACY NOTICE.

The index and headings in this Privacy Notice are for your convenience only, and do not limit, define, or fully explain each section.

1. Background of the Celiac AGY Clinical Study app.

2. No medical advice.

3. Unauthorized third party products.

4. What does this Privacy Notice apply to?

5. What information does this Privacy Notice govern?

6. How is personal information handled?

7. How long does mmHg store personal information?

8. Does mmHg share personal information with third parties?

9. How does mmHg secure personal information?

10. Where does mmHg store and transfer personal information?

11. Will mmHg send me marketing material?

12. How does mmHg protect the privacy of children?

13. How may I access and/or correct my personal information?

14. What rights do I have over my personal information?

15. How do I delete my Celiac AGY Study system account?

16. How can I contact mmHg?

17. Changes to this Privacy Notice.

1. Background of the Celiac AGY Clinical Study app.

mmHg developed the Celiac AGY Clinical Study App, and shares the marketing authorizations/registrations with Vetanda Group Ltd. the sponsor of the Celiac AGY Study.

The Celiac AGY Study app was designed to support communication between patients/subjects and researchers of the Celiac AGY Study from the University of Alberta and University of Manitoba. The Celiac AGY Study app is part of a secure, cloud-based research communication system that may be used by study subjects and researchers, and mmHg to aid in the communication and logistics of the Celiac AGY Study. Use of the Celiac AGY Clinical Study app may require: internet access, data usage (charges may apply), certain software (fees may apply), and periodic updates, and the performance of the Celiac AGY Study app may be affected by these requirements.

2. No medical advice.

THE CELIAC AGY CLINICAL STUDY APP IS NOT INTENDED FOR THE DIAGNOSIS OF OR SCREENING OF ANY MEDICAL OR HEALTH CONDITION. USERS SHOULD BE AWARE THAT THE CELIAC AGY CLINICAL STUDY APP IS AN INFORMATION MANAGEMENT SERVICE CREATED TO SUPPORT RUNNING OF THE CELIAC AGY CLINICAL STUDY. INDIVIDUALS SHOULD ALWAYS CONSULT THEIR DOCTOR OR OTHER QUALIFIED HEALTH CARE PROFESSIONAL WITH ANY QUESTIONS THEY MAY HAVE REGARDING A MEDICAL CONDITION, INCLUDING ANY QUERIES OR CONCERNS ABOUT CELIAC DISEASE. YOU SHOULD NEVER DISREGARD PROFESSIONAL MEDICAL ADVICE OR DELAY IN SEEKING IT BECAUSE OF INFORMATION TRANSMITTED TO OR CONTAINED IN YOUR THE CELIAC AGY CLINICAL STUDY APP. You should follow customary guidelines set by Your doctor or other healthcare professional(s) when your celiac disease symptoms are present.

MMHG IS NOT A PROVIDER OF MEDICAL CARE AND MMHG IS NOT RESPONSIBLE FOR NOTIFYING AN INDIVIDUAL’S DOCTOR OR OTHER HEALTHCARE PROFESSIONAL(S) OF ANY CHANGES HEALTH STATUS.

The Celiac AGY Clinical Study app is designed to support communication and subject task management for the Celiac AGY Clinical Study. mmHg does not recommend or endorse any specific tests, products, procedures or opinions.

YOUR DECISION TO TAKE ACTION BASED ON ANY INFORMATION COMMUNICATED TO OR STORED ON THE CELIAC AGY CLINICAL STUDY APP OR ON ANY INFORMATION RECEIVED FROM MMHG EMPLOYEES, AGENTS, OR SUPPLIERS IS SOLELY AT YOUR OWN RISK.

3. Unauthorized third party products.

Please be aware that third parties may offer services, software, mobile apps, and blood pressure devices not authorized by mmHg and which they claim may be compatible with the Celiac AGY Clinical Study app. mmHg does not recommend using the Celiac AGY Clinical Study app with these unauthorized third party products, and is not responsible if you do. If you do use these third-party products or services, your use is subject to their respective privacy policies and terms of use. Where you do use such third-party products, services, software or apps and upload information in your Celiac AGY Clinical Study app, mmHg will receive and process such data, including if you have uploaded health-related information.

4. What does this Privacy Notice apply to?

This Privacy Notice applies only to the personal information you submit through the Celiac AGY Clinical Study app after enrolling in the Celiac AGY Clinical Study, and to the personal information, including health-related information, that we may receive from you or others (as explained in this notice) and stored within the Celiac AGY Clinical Study app and cloud systm. Data will be uploaded to the Celiac AGY Clinical Study cloud system when you use the Celiac AGY Clinical Study app to communicate with, or receive communication from, Celiac AGY Clinical Study researchers, or if data is entered manually, and through any customer services we provide that are connected to your use of the Celiac AGY Clinical Study app.

5. What information does this Privacy Notice govern?

This Privacy Notice covers the following information:

• Secure communications between yourself and the Celiac AGY Clinical study staff.
• Scheduled reminders for study activities.
• Information we receive about your mobile device, including information about your operating system and other troubleshooting and analytical data to help us provide the Celiac AGY Clinical Study app.

The Celiac AGY Clinical Study app communicates personal information and data directly to the Celiac AGY Clinical Study cloud system pursuant to this Privacy Notice.

6. How is personal information handled?

mmHg only collects personal information that is shared and inputted by users through the secure messaging feature, or via the study activities reminders tool.

Personal information

mmHg uses information entered by users in the following ways:

• to provide you with a Celiac AGY Clinical Study app account to give you access to and present your information, including health-related information, in an easy-to-use and effective manner, to allow you to communicate with researchers and support the Celiac AGY Clinical Study.
• to help us fix any issues with the Celiac AGY Clinical Study app, including where we respond to your questions or respond to your request for support, troubleshooting, or other any performance issues.
• if you are a parent or guardian, to enable you to support participation into the Celiac AGY Clinical Study for use by your child, and to allow you to manage their use of the Celiac AGY Clinical Study app.

Data Analysis

mmHg uses de-identified, pseudonymized, aggregated, and/or anonymized information for limited purposes. mmHg performs tasks as a data processor with this data analytics process, in particular, the processes related to de-identifying, pseudonymizing and/or anonymized information. This is information which mmHg securely holds and will not be used to identify you individually by your name or email address. The purposes for which mmHg will use this information are:

• to improve the quality, security and effectiveness of medical devices and systems and to allow for the development of innovative and effective treatment for and management of blood pressure and other cardiovascular diseases in the interests of public health.
• to create, access, retain, use, and disclose to our affiliated companies and to third-party researchers, healthcare entities or professionals or public health authorities for the purposes of scientific research, statistical purposes and analysis.
• to research, develop and test healthcare care and research systems and management.

7. How long does mmHg store personal information?

MmHg will store all information entered during the Celiac AGY Clinical Study for a minimum of 10 years. At the completion of the study, all data will be copied and transferred to the Celiac AGY Clinical Study management staff at the University of Alberta.

8. Does mmHg share personal information with third parties?

We share personal information with our third-party suppliers solely to provide, maintain, host, and support the Celiac AGY Clinical Study app. mmHg, which holds the marketing authorizations/registrations for the Celiac AGY Clinical Study app, will process personal information, including health-related information. mmHg acts as a data processor with the data analytics process, in particular, the processes related to de-identifying, pseudonymizing and/or anonymized information. Where we provide your personal information to third-party suppliers to assist us with the provision of your Celiac AGY Clinical Study app account, they are required to keep your personal information confidential and secure and to use your personal information to the minimum extent necessary.

mmHg may use third-party service providers to provide you with the Celiac AGY Clinical Study app. For example, we may use third-party service providers to report when the Celiac AGY Clinical Study app crashes or experiences certain errors so that we can support and improve the Celiac AGY Clinical Study app, and when these crashes or errors occur, the Celiac AGY Clinical Study app will send certain information about the incident to such third parties. The information sent to such third parties will not involve the use of your personal information.

We may share and You hereby consent to us sharing de-identified, pseudonymized, aggregated, and/or anonymized information with affiliated mmHg companies and with other third parties for the purposes relating to “Data Analysis” set out above. This is information which mmHg securely holds and will not be used to identify you individually by your name or email address.

9. How does mmHg secure personal information?

We have implemented administrative, technical, and physical safeguards to protect your personal information, including health-related information, from accidental or unlawful destruction, loss, alteration, unauthorized disclosure, or access, including through the use of cryptographic technologies. mmHg restricts access to personal information by its employees on a need to know basis. Please keep in mind that no internet or Wi-Fi transmission is 100% secure, so please exercise caution when uploading personal information, especially health-related information, to your Celiac AGY Clinical Study app account.

You are responsible for protecting against unauthorized access to your devices and your Celiac AGY Clinical app account. We recommend securing access to your mobile device by locking your mobile device, choosing a robust password that nobody else knows or can easily guess, and keeping your account information and password private. mmHg is not responsible for any lost, stolen, or compromised passwords or for any activity on your Celiac AGY Clinical App study account from unauthorized users where caused by you. If you think your Celiac AGY Clinical system account has been compromised, please contact us as soon as you are able at agyceliac-support @mmHg.ca.

10. Where does mmHg store and transfer personal information?

The personal information entered into the Celiac AGY Clinical Study system will be stored in the cloud on secure regional servers located in Canada (managed by Server Cloud Canada).

11. Will mmHg send me marketing material?

mmHg will not send you marketing material.

mmHg will not sell your personal information to third parties for direct marketing.

12. How does mmHg protect the privacy of children?

Each user is managed by researchers at the University of Alberta, which includes identifying to mmHg whether any child participants are recruited. For child participants the parent/guardian must consent to the child’s use of the Celiac AGY Clinical Study app. Upon such consent, a Celiac AGY Clinical Study app account will be created by study researchers for the parent/guardian for use by a child.

At any time, a parent/guardian may stop the collection of a child’s personal information, including health-related information, by requesting that mmHg delete the Celiac AGY Clinical Study app account used by a child by contacting us at agyceliac-support@mmhg.ca and the research team. This action will delete the account being used by the child but we retain aggregated and de-identified information and may need to retain certain personal information as required by law.

13. How may I access and/or correct my personal information?

You may correct your profile information by contacting Celiac AGY Clinical Study researchers directly.

14. What rights do I have over my personal information?

Depending on your place of residence, you may have the right to: (a) access the personal information we hold about you; (b) request we correct any inaccurate personal information we hold about you; (c) delete any personal information we hold about you; (d) restrict the processing of personal information we hold about you; (e) object to the processing of personal information we hold about you; and/or (f) receive any personal information you have provided to us on the basis of your consent upon discussion with your research team.

Children may also have the right to access the personal information held about them through the Celiac AGY Clinical Study app. Where we receive a request for access for a child’s personal information from the child’s parent/guardian, we may respond directly to the child’s parent/guardian. We will always seek to verify the identity of the person seeking access to a child’s information, whether it is from the child him/herself or from a parent or guardian.

To request the exercise of these rights, please contact us at agyceliac-support@mmhg.ca.

15. How do I delete my Celiac AGY Clinical Study system account?

If you would like to delete your Celiac AGY Clinical Study app account, please contact us at agyceliac-support@mmhg.ca and your research study team. Please be aware that if you delete your account, we will retain aggregated and de-identified information and may need to retain certain personal information as required by law.

Once your Celiac AGY Clinical Study app account and any associated personal information has been deleted, you will no longer have access to the Celiac AGY Clinical Study app account and deletion of your account is irreversible. You may not therefore be able to reactivate your Celiac AGY Clinical Study app account or retrieve any personal information, including health related information.

16. How can I contact mmHg?

If you have questions, comments, or complaints about our privacy practices, please contact us at agyceliac-support@mmhg.ca. Alternatively, you may send a letter to the following address:

Attn: Celiac AGY Support
MmHg Inc. 

5-134 Clinical Sciences Building, University of Alberta

Alberta, Canada, T6G 2G3

17. Changes to this Privacy Notice.

If we change our privacy practices, an updated version of this Privacy Notice will reflect those changes. You will be alerted to updates to this Privacy Notice by email or via the Celiac AGY Clinical Study app. You will be notified if there is a new version of this Privacy Notice and will be prompted to read and accept it so that you can continue to access and use your Celiac AGY Clinical Study app. Without prejudice to your rights under applicable law, we reserve the right to update and amend this Privacy Notice without prior notice to reflect technological advancements, legal and regulatory changes and good business practices to the extent that it does not change the privacy practices as set out in this Privacy Notice.

If you do not agree to the changes to the Privacy Notice, you should delete the Celiac AGY Clinical Study app from your device, or request deletion of your Celiac AGY Clinical Study app account by contacting us at agyceliac-support@mmhg.ca, or University of Alberta research study staff.

Doc ID: V1.2 Celiac AGY Clinical Study App Privacy Policy