Web Portal/App for Doctors and Patients
Patient on the Go - Privacy Policy
Introduction
This policy (together with the applicable user terms) applies to your use of:
Our Patient on the Go mobile application software (App), once you have downloaded or streamed a copy of the App onto your mobile telephone or handheld device(Device);
Our Patient on the Go web portal at www.patientonthego.com (Web Portal); and
Any of the services accessible through the App or Portal (Services).
This policy sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us. Our App is not intended for children and we do not knowingly collect data relating to children. If we find such practices or informed by you, we will delete minor account in one week or asap. Please read the following carefully to understand our practices regarding your personal data and how we will treat it.
Important information and who we are
AVM Professionals Limited is the controller and is responsible for your personal data (referred to as "Patient on the Go", "we", "us" or "our" in this policy).
If you have any questions about this privacy policy, please contact us using the details set out below.
Contact details
Our full details are:
Full name of legal entity: AVM Professionals Limited, Leicestershire, UK
Email address: hello@patientonthego.com
We have a Data Protection Officer/Manager (Meghna Garg) who has oversight of data protection and can be contacted at the email meghna@patientonthego.com. In the subject line of your email please state: FAO Data Protection Manager.
Concerns and Complaints
We would like to deal with your concerns first, so do contact us in the first instance. However, you have the right to make a complaint at any time to the Information Commissioner's Office (ICO), the UK regulator for data protection issues.
Changes to the privacy policy and your duty to inform us of changes
We keep our privacy policy under regular review.
This version was last updated on [10/07/2024]. It may change and if it does, these changes will be posted on this page and, where appropriate, notified to you by SMS or by email or when you next start the App or log onto the Portal. The new policy may be displayed on-screen and you may be required to read and accept the changes to continue your use of the App, the Portal or the Services.
It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during our relationship with you.
Third party links
Our App and Portal may, from time to time, contain links to and from the websites of our partner networks, advertisers and affiliates. Please note that these websites and any services that may be accessible through them have their own privacy policies and that we do not accept any responsibility or liability for these policies or for any personal data that may be collected through these websites or services, such as Contact and Location Data. Please check these policies before you submit any personal data to these websites or use these services.
The data we may collect about you
Only minimum amount of the data necessary will be collected to provide the services according to GDPR
General personal data
We may collect, use, store and transfer different kinds of personal data about you as follows:
Identity Data.
Contact Data.
Device Data.
Content Data.
Profile Data.
Usage Data.
Marketing and Communications Data.
Doctor: If you are a doctor, we can process the following information about you:
Identity Data: first name, last name, maiden name, country of residence, medical council details and medical licence number.
Contact Data: billing address, email address and telephone numbers.
Financial Data: bank account and payment card details when you subscribe to our services.
Transaction Data: includes details about payments to and from you
Content Data: includes information stored on your Device.
Profile Data: includes your username and password
Usage Data: includes details of your use of any of our Apps or your visits to any of Our Sites including, but not limited to, traffic data and other communication data, whether this is required for our own billing purposes or otherwise and the resources that you access.
Marketing and Communications Data: includes your preferences in receiving marketing from us and our third parties and your communication preferences.
We explain these categories of data here.
We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific App feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy policy.
Special categories of personal data
Due to the nature of our Services, we shall collect special categories of personal data. Special categories of personal data under data protection laws such as the UK Data Protection Act2018 and the UK GDPR are sensitive data such as medical records and any other data relating your medical or health records. In addition, special categories of personal data include information that can reveal your gender, ethnic origin, data concerning a natural person’s sex life or sexual orientation, biometric and genetic data. We will not actively process these types of data; however, these types of data may be revealed in the documents that you upload as part of our Services to you.
Special categories of personal data will only be processed where you provide us with your explicit consent that is you consent to the upload of your information onto our app/Web Portal so that we can provide our Services to you. Processing in this context means the storage and management of your medical health information. We do not alter the content of any documents or information that you provide to us.
How is your personal data collected?
We will collect and process the following data about you:
Information you give us. This is information (including Identity, Contact, Financial, and Marketing and Communications Data) you give us by filling in forms on the App or the Web Portal, or by corresponding with us (for example, by email or chat). It includes information you provide, download or register the App, subscribe to any of our Services and when you report a problem with the App, the Web Portal or our Services. If you contact us, we will keep a record of that correspondence.
Information we collect about you and your device. Each time you use the App or the Web Portal we will automatically collect personal data including Device, Content and Usage Data. We collect this data using cookies and other similar technologies. Please see our cookie policy for further details.
Information we receive from other sources including third parties and publicly available sources. We will receive personal data about you from various third parties asset out below:
Device Data from the following parties:
Analytics providers [such as Google based outside the UK];
Identity and Contact Data from publicly available sources such as Companies House and the electoral register based inside the UK.
Cookies
We use cookies and/or other tracking technologies to distinguish you from other users of the App, Web Portal or the distribution platform (App Store/Google Play) and to remember your preferences. This helps us to provide you with a good experience when you use the App or the Web Portal and also allows us to improve the App and Web Portal. For detailed information on the cookies we use, the purposes for which we use them and how you can exercise your choices regarding our use of your cookies, see our cookie policy.
How we use your personal data
We will only use your personal data when the law allows us to do so. Most commonly we will use your personal data in the following circumstances:
Where you have consented before the processing.
Where we need to perform a contract, we are about to enter or have entered with you.
Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
Where we need to comply with a legal or regulatory obligation.
We will only send you direct marketing communications by email or text if we have your consent. You have the right to withdraw that consent at any time by contacting us.
We will get your express opt-in consent before we share your personal data with any third party for marketing purposes.
Condition for processing Special Categories of Data
Where we process Special Categories of Data as outlined above, we will obtain your explicit consent under data protections laws to legitimise the processing.
Disclosures of your personal data
When you consent to providing us with your personal data, we will also ask you for your consent to share your personal data with the third parties set out below for the purposes set out in the table [Purposes for which we will use your personal data]:
Purposes for which we will use your personal data
|
Purpose/activity |
Type of data |
Lawful basis for processing |
|
To install the App and register you as a new App/Web Portal user |
Identity Contact Financial Device |
Your consent |
|
To manage our relationship with you including notifying you of changes to the App, the Web Portal or any Services |
Identity Contact Financial Profile Marketing and Communications |
Your consent Performance of a contract with you Necessary for our legitimate interests (to keep records updated and to analyse how customers use our products/ Services) Necessary to comply with legal obligations (to inform you of any changes to our terms and conditions) |
|
To enable you to complete a survey |
Identity Contact Device Profile Marketing and Communications |
Your consent Performance of a contract with you Necessary for our legitimate interests (to analyse how customers use our products/Services and to develop them and grow our business) |
|
To administer and protect our business and the App/Web Portal including troubleshooting, data analysis and system testing |
Identity Contact Device |
Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security) |
|
To deliver content and advertisements to you To make recommendations to you about services which may interest you To monitor trends so we can improve the App/Web Portal |
Identity Contact Device Content Profile Usage Marketing and Communications Location |
Consent Necessary for our legitimate interests (to develop our products/Services and grow our business) |
External Third Parties as set out in the [Glossary].
Third parties to whom we may choose to sell, transfer or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy policy.
International transfers
Many of our external third parties are based outside the UK so their processing of your personal data will involve a transfer of data outside the UK.
Whenever we transfer your personal data out of the UK, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:
We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data.
Where we use certain service providers, we may use specific contracts approved by the UK which give personal data the same protection it has in the UK.
Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the UK.
Data security
All information you provide to us is stored on our secure servers. Any payment transactions [carried out by us or our chosen third-party provider of payment processing services] will be encrypted. Where we have given you (or where you have chosen) a password that enables you to use our Services, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.
Once we have received your information, we will use strict procedures and security features to try to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way.
Data are stored in MySQL database that is based in Google Cloud Platform. In general data in the application are protected by passwords, users’ authorization, data encryption. Database is protected with MYSQL injection and all Google Platform safety systems.
[We may collect and store personal data on your Device using [application data caches and browser web storage (including HTML5).
Our App and Web Portal enable a patient to share personal data with a named medical professional. Ensure when using them that you do not share any personal data that you do not want to be seen, collected or used by another user.
We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator when we are legally required to do so.
Data retention
Details of retention periods for different aspects of your personal data are available in our retention policy which you can request by contacting us. We will retain your information as long as necessary.
In some circumstances you can ask us to delete your data: see Your data subject rights below for further information.
In some circumstances we will anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.
In the event that you do not use the App for a period of [ 6 months] then we will treat the account as expired and your personal data may be deleted.
Your Data Subject Rights
Under certain circumstances you have the following rights under data protection laws in relation to your personal data.
Request access to your personal data: This is known as a "data subject access request" and enables you to receive a copy of the personal data we hold about you.
Request correction of your personal data: This enables you to have any incomplete or inaccurate information we hold about you corrected.
Request erasure of your personal data: This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. Note: We may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you at the time of your request.
Object to processing of your personal data: This is where we are processing your personal data based on a legitimate interest orthose of a third party and you may challenge this. However, we may been titled to continue processing your information based on our legitimate interests or where this is relevant to any legal claims. See also Marketing communications.
Request restriction of processing your personal information: This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the information's accuracy (b) where our use of the information is unlawful but you do not want us to erase it (c) where you need us to hold the information even if we no longer require it as you need it to establish, exercise or defend legal claims or (d) you have objected to our use of your information but we need to verify whether we have overriding legitimate grounds to use it.
Request transfer of your personal information ("data portability"): This is where in some circumstances we will provide to you or a third party you have chosen your personal data in a structured, commonly used, machine-readable format.
Right to withdraw consent: This is where we are relying on consent to process your personal data. This will not affect the lawfulness of any processing carried out before you withdraw your consent. Depending on the processing activity, if you withdraw your consent, we may not be able to provide certain services to you. We will advise you if this is the case at the time you withdraw your consent.
Automated decision making: This is where decisions are made about you by automated means. We do not carry out automated decision making.
Keeping personal information accurate and current
It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us. If you wish to update your personal data, please contact us.
Opt-Out Information
We are committed to protecting your privacy and providing you with clear choices regarding your personal data. Below, we explain how you can opt out of specific data processing activities:
For push notifications, you can turn them off in your device's notification settings for our app.
Non-Opt-Out Data Processing Activities
While we strive to give you control over your personal data, there are certain data processing activities that are essential for the functionality and security of our app, and thus, cannot be opted out of. Below, we explain these necessary processing activities and the reasons they cannot be disabled:
Essential Service Operations:
Description: These operations include the processing of data necessary for the app to function correctly and provide the core services. Why You Cannot opt Out: Without this data processing, the app would not be able to perform its basic functions, such as user authentication, maintaining session state, and providing the requested services.
Security and Fraud Prevention:
Description: This involves monitoring and analysing data to detect and prevent fraudulent activities, ensure account security, and protect against unauthorized access. Why You Cannot opt Out: Disabling this data processing would compromise the security of your data and the integrity of our services, making it vulnerable to security threats.
Compliance with Legal Obligations:
Description: We process certain data to comply with legal requirements, such as data retention laws, regulatory reporting, and responding to lawful requests from public authorities. Why You Cannot opt Out: Compliance with legal obligations is mandatory, and we must process this data to fulfil our legal responsibilities.
Internal Business Operations:
Description: This includes processing data for purposes such as auditing, data analysis, and research to improve the app's performance and functionality. Why You Cannot opt Out: These activities are critical for maintaining the app’s reliability, ensuring business continuity, and enhancing the user experience
Carrying out your data subject rights
You will not have to pay a fee to access your personal data or to exercise any of the other rights. However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal information or to exercise any of your other rights. This is a security measure to ensure that personal information is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
If you wish to exercise any of the rights set out above, please email us at hello@patientonthego.com.
Marketing communications
You also have the right to ask us not to continue to process your personal data for marketing purposes.
You can exercise any of these rights at any time by contacting us.
Risks Associated with the App
We use an algorithm to predict menstrual cycles, and there is a possibility that it may not always provide the correct period date
We use UK units for blood test results. If you have blood test results and want to record them in the app, please ensure you convert them to UK units, such as Hb 100 mg/Litre instead of 10.0 g/dl.
Bugs or glitches in the app can lead to incorrect data processing or loss of user data
Glossary
Lawful basis
Consent means processing your personal data where you have signified your agreement by a statement or clear opt-in to processing for a specific purpose. Consent will only be valid if it is a freely given, specific, informed and unambiguous indication of what you want. You can withdraw your consent at any time by contacting us.
Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.
Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.
Comply with a legal obligation means processing your personal data where it is necessary for compliance with a legal obligation that we are subject to.
Third parties
External third parties
Service providers [acting as processors] based outside the UK who provide IT and system administration services.
Professional advisers [acting as processors or joint controllers] including lawyers, bankers, auditors and insurers based outside the UK who provide [consultancy, banking, legal, insurance and accounting services].
Description of categories of personal data
Identity Data: first name, last name, maiden name, username or similar identifier, marital status, title, date of birth, gender, next of kin, country of residence and ethnicity.
Contact Data: billing address, email address and telephone numbers.
Financial Data: bank account and payment card details.
Transaction Data: includes details about payments to and from you.
Content Data: includes information stored on your Device, including medical information, allergies and whether or not you smoke.
Profile Data: includes [your username and password, your interests, preferences, feedback and survey responses].
Usage Data: includes details of your use of any of our Apps or your visits to any of Our Sites including, but not limited to, [traffic data [and other communication data],] whether this is required for our own billing purposes or otherwise [and the resources that you access].
Marketing and Communications Data: includes your preferences in receiving marketing from us and our third parties and your communication preferences.
"If you have any issues related to usage of the app please contact us at our support email address, admin@patientonthego.com. We value your feedback and aim to respond to any issues within 48 hours."
Feedback helps us to improve the application’s processing and make it more user-friendly. Based on user feedback, we have made changes to the login process, such as increasing the complexity of passwords.