Optimise BP is the trading
name for Optimise Health Ltd (“we”, “us”, “our”). We are a company registered in England and Wales
with
company number 11404473 and having its registered office at Halifax House, 30-34 George Street,
Hull,
Humberside, United Kingdom, HU1 3AJ.
Optimise Health Ltd is committed to respecting and protecting your privacy. Please take time to read
and
digest how this Privacy Policy applies to you according to the different situations explained below
and
highlighted throughout this Privacy Policy:
What data do we collect and how is it used?
You may give us information about you by entering information on our app or website, allowing us
access
to data about you held by third parties, filling in forms, or by
corresponding with us by phone, e-mail or otherwise. You may also give us information, and we may
collect and process information, about you resulting from any interactions you undertake or services
you
request or source from us. We may conduct evaluation or research
on usage of the app or aspects of hypertension management. This will be on anonymised or
pseudonymised data and is in order to improve the product and ensure that OptimiseBP is
benefiting users and the NHS.
It will be clear at the time what personal information we are requesting from you. If you do not
provide
the personal information necessary or withdraw your consent for the processing of your personal
information, where this information is necessary for us to provide the relevant Services to you, we
will
not be able to provide these Services to you. You don't have to provide data and can simply
choose
to stop using our app or website or our additional services. You will be free to refuse to participate in research that requires identifiable
personal information.
Each time you use our app or website we may automatically collect the following information:
-
technical information, including (but not limited to) the type of device you use, a unique
device
identifier, mobile network information, your mobile operating system, and time zone setting;
-
information either accessed through your device or stored on your device which you have
explicitly
consented to sharing, and the providence of that data including the device used to collect that
data, time, date; and
- details of your use of our app or website and services.
We will collect, create and retain the following information to set up your account and security
profile,
and administer and maintain your account, including for any technical updates to or technical
support
for the application:
-
Your basic account profile information, including your name, physical address, email address,
telephone number, date of birth, and gender,
-
Details of any support queries that you raise about technical issues you are experiencing with
the
application for which your email will be required to process your query;
- The username and password which you use to login to the application;
-
Any other data that you choose to provide us with, other than through the usual functionality of
the
application.
The main categories of information that we will collect from you during the functioning of the
software
include:
- Blood pressure readings
- Blood pressure medication you are taking
- Side effects you may be experiencing
- Information about your blood tests
- Your NHS number
We may, on occasion, ask for information connected with research into the functioning
of the app or other aspects of hypertension management, as described above.
General information about how your personal information will be treated
We collect, use and
share your personal details obtained through your use of the website or the application as
follows:
-
Certain information through the use of cookies that are automatically stored on your device when
you
visit our website
-
To provide you with the services of the software including any communication on updates to our
software.
-
To enable us to look into and resolve queries and complaints relating to your use of our
services.
-
Where we need to improve and enhance the quality of our services through details of your use of
our
app, website and services.
-
Our third party service providers who help us to provide the application and website to you - we
will impose appropriate obligations to protect the security and privacy of your information;
-
Our professional advisors including our lawyers and accountants (and those of any prospective
purchasers of our business – see below) when required for them to provide us (or prospective
purchasers of our business) with professional advice - we will impose appropriate obligations to
protect the security and privacy of your information;
-
The police, local authorities, Her Majesty’s Revenue and Customs (HMRC), the courts and any
other
government or regulatory authority based in any jurisdiction if they ask us to do so for a legitimate reason or if we choose to provide it because we think it appropriate to protect our business, staff, premises and users, or if we are obliged to do so, such as by court order;
-
Where we re-organise, re-structure, sell or transfer our business we will transfer your personal
information to the new incumbent of the business for them to continue to use it in the same ways
as
we have prior to the transfer.
- We will not share your information with any third parties, except if it is required as part
of research, and in accordance with these terms and
conditions.
International transfers of your information.
-
Information submitted through the website and the application are stored in secure servers and
data
centres.
- Your personal medical information is stored solely in England.
-
Information which you supply through our support portal, on which you should never include any
personal medical information, may be stored by the suppliers and advisers we engage to help us
run
and deliver our business, in servers or data centres located outside the EU. Naturally, we
expect
our suppliers to take information security as seriously as we do so we put appropriate measures
in
place requiring suppliers to treat the information to EU standards for the protection of your
personal information. Even so, any transfer of information to other countries in this way could
result in that information being available to the government and other authorities in those
countries under their laws.
-
We take all steps reasonably necessary to ensure that your data is treated securely through
strict
procedures and security features to prevent unauthorised access to your personal information
Updates to this privacy policy
We regularly review the ways we use your information, and in
doing so, we may change what kind of information we collect, how we store it, who we share it with
and
how we act on it.
Consequently, we may need to change this privacy policy from time to time so
please check the privacy policy when returning to this site. If we have already captured or you have
already provided your information through the website or the application, we will notify you of
those
changes and where appropriate provide for you to review your preferences accordingly.
Security
We will help keep your information safe, secure and private. The data that is entered,
transmitted and stored is encrypted to prevent any unauthorised use of the data.
Data in transmission is protected by industry standard measures including encryption to provide a high level of security for your personal healthcare information.
Decision making and profiling
Automated decision making means making a decision solely by
automated means without any human involvement and profiling means automated processing of personal
data
to evaluate personal data about an individual.
By agreeing to this privacy statement, you consent
to any automated decision making and profiling that is required for the proper functioning of this
OptimiseBP product.
OptimiseBP takes information about your medication, blood pressure readings,
blood
tests and side effects to make automated recommendations to manage your blood pressure, carrying out
instructions set by your clinician.
Although you are able to withdraw consent for this automated
decision making, we will be unable to continue to provide you with our services helping you manage
your
blood pressure.
We would then suggest you contact your clinician for continuing management. At any point during
your
use
of OptimiseBP, you should consider the output from the product as recommendations and you can
always
request human intervention or challenge a decision by contacting your clinician. If you feel at
any
time
that the protocols and recommendations are incorrect, as well as contacting your clinician, we
would
ask
you to let us know by emailing [email protected].
Your
information rights
Optimise Health Ltd is the DATA CONTROLLER for the data that we process
in accordance with this privacy policy. This term is a legal phrase used to describe a person or
entity that controls the way data is used and processed.
The General Data Protection
Regulation gives you a number of rights as a data subject. These rights are listed below:
-
You have the right to know how we will use your personal information. This is described in
our
Privacy Policy.
-
You have the right to be provided with a copy of your record (the information we hold about
you). This is known as a Subject Access Request. This information is available to you
through
the App, but if you wish to check our full records, please use our address as shown at the
top
of this privacy policy or email us at [email protected]
-
You have the right to object to us making use of your information for any specific purpose.
This
is addressed by the use of consent boxes when signing up. You can remove your consent by
emailing us at [email protected]. We will monitor this email account
and
ensure that your wishes and changes are respected.
-
You have the right to rectify any information which you believe is inaccurate. If you
believe
that we have made an error, or you are unable to make a correction, please email us at [email protected]
-
You have the right to request that we erase personal data about you that we hold, which is
also
known as the right to be forgotten. This is not an absolute right, and depending on the
legal
basis that applies, we may have overriding legitimate grounds to continue to hold and
process
the data. If you would like to make a request for us to erase personal data that we hold
about
you, email us at [email protected].
-
You have the right to object to any automated profiling and decision making. Our system uses
data provided by Clinician Users and Patient Users to make recommendations of medication
dosage
adjustments. However, where this automated profiling and decision making is necessary for us
to
provide the relevant Services to you, we may not be able to continue to provide these
Services
to you.
We are registered under the Data Protection Act 2018 with the Information Commissioner’s Office
(the
UK data protection authority). Our registration number is A8503459 and can be viewed online
at www.ico.org.uk. You can
also
find useful access guidance and information about your data protection rights on this
website.
You can make a complaint to the ICO at any time about the way we use your information. However,
we
hope that you would first consider raising with us any issue or complaint you have about how we
handle your personal information. Your trust is extremely important to us, and we will always do
our
very best to promptly resolve any problems you may have in this regard.