Privacy Notice - Curatio
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Privacy Notice

Privacy Notice for AbbVie Care Circle

 

Effective 09, 2018

 

Welcome to AbbVie Care Circle powered by Curatio! Like you, we are very concerned about protecting your privacy and complying with Canada’s Personal Information Protection and Electronic Documents Act (“PIPEDA”) and other applicable privacy laws. This Privacy Notice explains the Personal Information we collect and the specific ways we use, keep safe and disclose it. Our privacy practices are based on applicable privacy legislation as well as ten internationally recognized privacy principles.

 

Curatio is a Canadian company delivering AbbVie Care Circle on behalf of AbbVie Canada. Both of us are subject to Canadian privacy legislation and contractually bound to provide administrative, technical and physical safeguards to protect the Personal Information you provide when using AbbVie Care Circle.

 

How and when your Personal Information is shared with AbbVie Canada is described in this Privacy Notice.

 

In this Notice, when we say “we”, “us” and “our”, we are referring to Curatio a company registered in British Columbia. When we say “you” or “User” we are referring to the person using AbbVie Care Circle.

 

AbbVie Care Circle is a mobile health companion that provides peer-to-peer support and self-management tools (the “Services”) for patients of the HUMIRA drug. In the course of providing the Services, we may collect Personal Information. “Personal Information” means information about an identifiable individual such as name, email address, IP address, residential address and telephone number. Personal Information also encompasses more sensitive information such as gender, age, health status, family information, ID numbers and any other data assigned to an individual.

Collection of Personal Information will vary with how you use the Services. Other than the information we require to set up your account, you can decide how much personal information you want to provide and share with others.

 

Accountability

 

Curatio’s Privacy Officer is responsible for the creation, oversight and implementation of our privacy management program and procedures to protect Personal Information, for receiving your privacy-related questions and for providing you with information about our privacy practices.

You can contact our Privacy Officer at:

1200 – 555 West Hastings St.

Vancouver, BC Canada, V6B 4N6

Email: privacy@curatio.me

 

 

For information on AbbVie Canada’s privacy practices, please visit:

http://www.abbvie.ca/en/privacy/privacy-policy.html

 

Identifying purposes

Curatio collects, uses, and discloses Personal Information only for the purposes of providing you with our Services and for other purposes you consent to as a User. More specifically, AbbVie Care Circle collects, uses and discloses information (which may include Personal Information) to:

  • Create your account using your email address.
  • Match you to other Users in the app with similar conditions, interests and experiences or Users who are near you using any additional Personal Information you choose to provide.
  • Contact you for the purposes of product information, service updates, and notifications relating to the Services.
  • Monitor system usage, server and software performance, to improve system design, to create benchmarks and to conduct trending analyses.
  • Perform statistical analyses and generate anonymized data (that does not identify you) related to the use of the Services.
  • Assist you with technical support issues. Most technical issues can be resolved without a Curatio team member viewing your Personal Information.
  • Comply with any laws, regulations, court orders, subpoenas, or other legal process or investigation and to protect ourselves and other individuals from harm.
  • Bill, process and/or collect payment.

Where AbbVie Canada invites you to use an app powered by Curatio, your Personal Information, specifically your User name and email address, will be shared with AbbVie Canada for the purposes of:

  • Confirming you are a registered User of the program;
  • Communicating with an assigned care coach, wellness manager or facilitator; and
  • Participating in AbbVie Canada’s programs

 

Consent

Curatio takes a consent-based approach to the collection, use and disclosure of Personal Information. By giving us Personal Information when you use our Services, you consent to your information being collected, used, disclosed and stored by us, only as described in this Privacy Policy.

At any time and without penalty, you can withdraw your consent and close your AbbVie Care Circle account by contacting us at privacy@curatio.me

Before we contact you with general commercial information, we will ask for your consent. At any time, you can opt-out of most email communication from us by clicking on the unsubscribe link at the bottom of our emails. We may still contact you for administrative purposes, for example to notify you of a change to the Services, change to this Privacy Notice, or if there is a service interruption.

 

Limiting collection

Curatio limits the collection of Personal Information to only that required to fulfill the identified purposes. We will collect the minimum amount of information required to facilitate the Services, however, we provide you with the option of sharing additional information to enhance your use of the Services.

AbbVie Care Circle does not knowingly or intentionally collect Personal Information from Users who are under the age of thirteen (13).

You may have the ability to allow others access to your account (your “Network”). Note that by providing others access to your Network, you may also be providing access to any Personal Information in your Network. While Users must agree to our terms of use, we take no responsibility for any collection, use or disclosure of your Personal Information by other Users you invite.

You may choose from time to time to connect AbbVie Care Circle with other third-party service providers in order to utilize their services in conjunction with our Services. You will be subject to the terms of use and privacy policies of these third-party service providers. You are responsible for reviewing and agreeing to them. If you do not agree with their terms of use or privacy policies you should not use the services offered by such third-party service providers.

 

Who can see my Personal Information?

AbbVie Care Circle Users include staff of our sponsors, partners and affiliates, including AbbVie Canada you may see in a network include care coach, facilitator, nurse educator or group leader, such as a wellness care manager. You will always be able to identify these types of Users by their titles.

Please contact AbbVie Canada directly for information about their privacy practices.

The email address you provide during the account sign up process is not visible to other AbbVie Care Circle Users.

The User name (“Display Name”), age range, and location you provide during the account creation or edit profile process is visible to all Users by default. Other than this information, you can choose what additional Personal Information to provide when you use the Services.

Any interest and experience tags (where applicable) you select as well as your story will be visible to the whole community. This enables Users to find others with similar stories and interests.

The activities you track when using the Health Tools (where applicable), for example Symptom Tracker, are not visible to anyone other than you.

You have the choice to share any of your posts to only your circle or to the whole community.

 

Limiting use, disclosure and retention

Curatio will not use or disclose Personal Information for purposes other than the purposes identified in this Privacy Notice. We do not sell, rent or disclose your Personal Information to any third party without your consent.

We generate aggregated and de-identified data from your use of the Services, such that no individual can be uniquely identified or linked to the information. Aggregate/de-identified data is the property of Curatio and may be shared with third parties (e.g., partners, sponsors), including AbbVie Canada.

We may transfer any information we have about you in connection with a merger or sale involving all or part of our business or as part of a corporate reorganization or stock sale or other change in corporate control.

Under certain circumstances, Curatio will disclose your Personal Information:

  • When we are required our authorized by law to do so, for example if a court issues a subpoena;
  • When you have consented to the disclosure;
  • When the services we are providing to you require us to give your information to a third party your consent will be implied, unless you tell us otherwise; or
  • Where it is necessary to establish or collect amounts owed to us.

If you choose to withdraw from the Services, we will either make anonymous or securely destroy your Personal Information in our possession and control within 30 days unless we are required to retain such Personal Information longer to fulfill our obligations to you or to third parties.

When you provide an email address to invite individuals to AbbVie Care Circle, the email address is not retained after your invite is sent.

 

Location of services

We use service providers located outside of Canada to process and/or store Personal Information for us. Please note that Personal Information in the custody of these service providers may be subject to access by the law enforcement authorities of those jurisdictions in which the service providers are located.

Our Privacy Officer can provide further information about our policies and practices regarding service providers located outside of Canada and further information about how these service providers, collect, use, disclose or store personal information on Curatio’s behalf.

 

Accuracy

Curatio relies on you to ensure that the Personal Information you provide to us while using the Services is as accurate, complete and up-to-date as necessary for the purposes for which it is to be used. You are welcome to make changes, request deletion or corrections to Personal Information at any time by updating your profile and account settings or by contacting us at privacy@curatio.me

 

Safeguards

Curatio uses administrative, technical and physical safeguards to protect your Personal Information in accordance with applicable legal requirements and industry best practices. For more information, please contact our Privacy Officer.

When you use our Services, some data is cached in the memory of the device. Cached data is encrypted and kept on the device as long as you are logged in, even if the application is put in the background. The data is deleted from the device when you sign out of the app and does not persist. Be careful about leaving any apps with Personal Information open on your device, as other people can access them.

We will review and update our security policies and controls as technology changes to ensure ongoing security for your Personal Information, however please bear in mind that no internet or email transmission is ever fully secure or error free and no security system is impenetrable. We cannot fully guarantee the confidentiality of any information that you share with us.

 

Openness

Curatio makes clear and transparent notice of our privacy practices publicly available via this Privacy Notice.

We will advise you at the first reasonable opportunity upon discovering or being advised of an incident where your Personal Information is lost, stolen, accessed, used, disclosed, copied, modified, or disposed of by unauthorized persons or in an unauthorized manner.

 

Individual access

You own the information you submit to AbbVie Care Circle and can review, edit or remove it at any time. Upon written request, Curatio will also provide you with a list of entities (e.g. third party service providers) to whom we have disclosed your Personal information.

 

Cookies and other tracking technologies

We use cookies to improve your experience, to save you time, and to make it possible to navigate our website. We do not link the information we store in cookies to any personal information you submit while using our service or visiting our websites. You can remove cookies manually by following directions provided in your Internet browser’s “help” file. If you refuse cookies, you will not be able to use some or all of our service, since some cookies are essential to navigation.

Curatio may from time to time implement other third-party analytics services that also use cookies. We will ensure that no Personal Information is included in those cookies. If the use of cookies by any service provider differs materially from the practices already listed, we will revise this document accordingly and notify existing you of the change(s).

 

Device Tokens

In order for Curatio to communicate with you via our mobile applications, which you may choose to install on your mobile device, we save a “device token” on your device. We use the device token to provide you with notifications relating to the Services. The device token identifies your mobile device to us but cannot be used to identify you. We store the token in encrypted format and retain it only as long as necessary to provide you with the Services.

 

Additional features and information

Curatio may offer publicly accessible blogs and community forums. You should be aware that any information you provide in these areas may be read, collected and used by others who access them. We take no responsibility for any information which you post or publish on blogs or forums and you agree to indemnify and hold Curatio harmless for any loss, cost, complaint, damage, claim or liability whatsoever arising from any such post or publication.

With your consent, we may use your testimonial or comments about our Services on our website and in other materials. If at any time you want your name, testimonial or comment removed, please contact us at privacy@curatio.me

It’s important to guard your privacy when you are online. If our Services contain links to other websites, those websites are not governed by this Privacy Notice. Whether we have posted those links or other organizations or individuals have, you should read their privacy policies and make an informed decision about whether you want to use those websites or their services.

 

Changes to this Privacy Notice

We may update this Notice to reflect changes to our information practices but we will not reduce your rights under this Privacy Notice without your explicit consent. We’ll post any changes to this page and, if the changes are significant, we will provide a more prominent notice (including email notification of privacy notice changes for certain Services). We’ll also keep prior versions of this Privacy Notice in an archive for your review.

We encourage you to periodically review our Privacy Notice for the latest information on our privacy practices and to contact us if you have any questions or concerns.

 

Challenging compliance

Curatio’s Privacy Officer is responsible for receiving your privacy-related questions. You may send us your privacy-related questions or challenge our compliance with our Privacy Notice by submitting your concern to:

Privacy Officer

1200 – 555 West Hastings St.

Vancouver, BC Canada, V6B 4N6

Email: privacy@curatio.me

 

If our Privacy Officer is unable to resolve your concern, you may also write to the Information and Privacy Commissioner of British Columbia.

 

Adverse Events

AbbVie Canada is legally obligated to track unwanted, unintended or harmful events (“Adverse Events”) in relation to the use of a AbbVie Canada’s medicinal products. Curatio uses technology to identify potential Adverse Events in posts using key words and phrases provided by AbbVie Canada. Curatio will share your User name and a link to your post that includes a key word or phrase in order to enable AbbVie Canada to follow up with you and track the Adverse Event. For more information, please visit https://www.abbviecare.ca/