Our company is Vinehealth Digital Limited ("Vinehealth"); company number 11672175.
At Vinehealth, your privacy is important to us. This privacy statement explains what Personal Information Vinehealth ("Vinehealth", "we", "us", "our", “App”, “Services”) collects from you, through our products and how we use that information.
Vinehealth serves a number of groups of users in different ways. References to products in this statement include Vinehealth services, which are offered through our websites and app.
Please read product-specific details in this privacy statement, which provide additional information about some Vinehealth products.
This policy applies to any users of the Services of Vinehealth or its affiliates anywhere in the world, and to anyone else who contacts or otherwise submits information to Vinehealth, unless noted below.
1. Data Protection Principles
We are committed to complying with data protection law and principles, which means that your Personal Information will be:
Processed lawfully, fairly and in a transparent way;
Collected for specific, explicit and legitimate purposes stated in this policy and not used in any way that is incompatible with those purposes;
Adequate, relevant and limited to what is necessary for those purposes;
Accurate and, where necessary, kept up to date;
Kept for no longer than is necessary for those purposes; and
Accountability is one of the GDPR principles. Vinehealth must put in place appropriate technical and organisational measures to meet these requirements and review, update where necessary the measures that have been put into place. Being accountable is key to maintain trust with other parties and may help mitigate any enforcement action if the situation arises.
2. Collection of Personal Information
Vinehealth acts as the data controller for the information you provide or that is collected by Vinehealth or its affiliates. Vinehealth collects Personal Information to operate effectively as a business and to provide you, the user, with tailored services and products.
You have choices about the Personal Information we collect. When you are asked to provide Personal Information, you may decline. But if you choose not to provide Personal Information that is necessary in order for us to provide services to you, you may not be able to use that product.
We provide further information, below, on the types of Personal Information we obtain and how we use them, throughout your use of our service and products.
2.1 - Collection of Personal Information
Information you give to us:
We will collect and process the Personal Information from you that you give to us by filling in forms on our website or App or by corresponding with us by phone, email or otherwise. It includes information you provide when you register to use the site or App, subscribe to our service, search for a product, participate in discussion boards or other social media functions on or via the site or App, enter a competition, promotion or survey, submit a query, and when you report a problem with the site or App.
The (“Personal Information”) you give us may include your name, address, email address, phone number, date of birth, demographic information, personal description and photograph, login and password details. We may also collect sensitive personal information about your health. This is described in further detail below. All Personal Information is kept private and will not be shared without obtaining your prior consent.
When you are prompted to provide this express consent, we will clearly and unambiguously explain to you what Personal Information we will be sharing, with whom and for what purpose.
To interact fully with our services, we collect information about your existing medical conditions. We ask for details of your diagnosis, the course and cycle of treatment that you are currently on and the name and contact information of your healthcare provider(s) and other important contacts so that we can provide a more tailored experience.
We record information about the medications that you are taking and planned appointments so that you can log when you have taken medications and see a schedule of upcoming medications and appointments.
You will also be able to log information on your physical and mental health; the severity of your side-effects, the severity of your symptoms, mood, activity levels, sleep, nutrition and hydration. You can also input notes so that you can journal your overall experience electronically and share this with others if you choose.
You can also choose to import metrics on things such as your heart rate, blood pressure, temperature, weight, levels of activity either directly from wearable devices or via third party databases. Please note that when using third party devices or websites, those third parties' privacy policies will also apply.
We also collect information on ethnicity when you choose to provide it. Understanding ethnicity allows healthcare professionals and our commercial partners to better understand how life-saving cancer drugs affect different people and develop them to be more effective.
Any information about your health and ethnicity is classed as sensitive Personal Information and we ensure that additional safeguarding measures are in place to protect this information. Our lawful basis for processing this sensitive Personal Information is your consent. You can withdraw your consent at any time - for more information please email firstname.lastname@example.org.
Part of this information is necessary to complete your user registration and for you to use our App and Services (for more information on what we use your data for, see section 3) If you decline to provide this information during the registration process you will not be able to create an account on the App and use our Services.
Information we receive from other sources:
If you input an access code that you have received from a Patient, Caregiver, Charity or a Healthcare Provider when you download the Vinehealth app, we will be able to tell which third party has provided you with this code.
We will receive information from anyone that you give permission to enter information into the App on your behalf (such as a Caregiver or a Healthcare Provider) ("Permitted Third Party/Parties"). If you allow your Permitted Third Parties permission to edit your information, then they may give us information about your symptoms, medications and treatments. You can change your Permitted Third Parties under your settings in your account and change the permissions allocated to each Permitted Third Party.
If you are a Permitted Third Party, we may receive information about you from the patient. This information includes your name, telephone number, email address, relationship to the patient, job title and location.
If you decide to allow any third party wearable devices to connect with our Services, we will receive information about you such as your exercise, activity, heart rate, temperature, sleep, weight and blood pressure from these devices via Bluetooth.
2.2 - Engagement data, Cookies and other data collection technologies
When you begin to use our App or services, we monitor engagement and feature usage on our platform by recording every interaction you have with products you are registered on. This includes, but is not limited to, page visits, content viewed and logs made on our platform.
We also infer your location based on your IP address during registration and for opt-ins. In addition to IP address, our platform automatically collects data about your device, including the model, platform, locale code and UUID (universally unique identifier) every time you visit the Vinehealth website or app. This information may also be collected in combination with an identifier associated with your device to enable us to recognise your mobile browser or device when you return to the site or the App.
In addition to cookies, we may log information about your device, including the existence of cookies, your IP address and information about your browser. The purpose of this information collection is to diagnose service issues and to administer and track your usage of our platforms.
Information about your visit may include the full Uniform Resource Locators (URL), clickstream to, through and from the site, and any phone number used to call our customer service number or social media handle used to connect with our customer service team.
2.3 - Third party aggregate data
Our third parties may gather non-personal digital properties to enrich aggregate analytics, including Google Analytics.
All of Vinehealth’s third-party service providers and other entities in the group are required to take appropriate security measures to protect Personal Information in line with our policies. Vinehealth only allows service providers to process Personal Information for specified purposes and in accordance with Vinehealth’s instructions.
3. How Vinehealth uses your Personal Information
3.1 - To operate effectively as a business and to perform essential business operations, including developing and providing products optimised for patients and clinicians.
We are motivated to provide products which offer outstanding resources for people living with long-term health conditions ("patients"), including content and resources tailored to a user’s specific need, stage of disease, medications, appointments, location, current condition and treatment (as detailed in section 2). We will show you and/or a Permitted Third Party this information.
To enhance your enjoyment and productivity on our platform, we endeavour to identify and recommend the most relevant features through personalised notifications, based on your profile, medications, symptom tracking, health condition(s) and recent activities. To ensure your experience with our products is seamless, we continuously re-examine and iteratively optimise user journeys on our platform.
Vinehealth uses your Personal Information to identify you and notify you about changes to our service. We infer your location from your device IP address in order to geo-restrict certain content on our platform.
Product issues, identified by users and communicated through customer support, are effectively diagnosed and resolved using data collected from interactions on the platform. Decisions on product development and evaluations of product performance are based on aggregate analysis and business intelligence.
All our third-party service providers and other entities in the group are required to take appropriate security measures to protect your Personal Information in line with our policies. We only allow them to process your Personal Information for specified purposes and in accordance with our instructions.
In addition to the specific disclosures of Personal Information set out in this section, we may disclose your Personal Information where such disclosure is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person. We may also disclose your Personal Information where such disclosure is necessary for the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure.
We will disclose your Personal Information to third parties if Vinehealth Digital Limited or substantially all of its assets are acquired by a third party, in which case Personal Information held by it about its customers will be one of the transferred assets.
3.2 - To deliver communications of personal interest including product and content releases, motivational prompts and in response to product queries or support requests.
Communications sent by Vinehealth come in the form of emails to the email address provided by you during the registration process and through notifications delivered to your device. Vinehealth may send you communications relating to new and existing product and content releases and updates. We send such communications so that you are aware of changes we are making to the content or features of our products, or new releases, which could affect the usefulness of our core services to you.
Third party communications
We may ask you during registration whether you want to receive third party communications such as promotional material material related to other services outside of our platform. You, of course, have the right to opt out of such email communication at any time by using the unsubscribe link, found at the bottom of every email, or by updating your account setting in the app. Vinehealth will not send you communications unrelated to its core services, unless you specifically tell us you are interested in receiving them.
3.3 - Anonymised & aggregated information for commercial partners
The purpose of Vinehealth is to create a future in which people living with cancer are able to manage their care more effectively but also have access to better life-saving drugs; we want to further our partners knowledge of cancer and enable them to deliver better clinical care.
We can only achieve our purpose if we share anonymised and aggregated (non-personal) information about our users’ conditions with our strategic partners: oncologists, research institutions, pharmaceutical companies and other organisations in the medical sector. The information that we share with our strategic partners is fully anonymised and aggregated unless you are part of a Vinehealth Care Program (see section 3.4) or if you are part of a Clinical Trial or other projects with our partners. (see section 3.5).
We may also share with our commercial partners aggregated information that does not personally identify you, but which shows general trends, for example, the number of users of our service.
3.4 - To track and report your Vinehealth data and insights with your doctor or care provider within a Vinehealth Care Program, with your prior knowledge and consent
By signing up our platform as a member of a Vinehealth Care Program (“VCP”) you agree to share your Vinehealth data and insights with your doctor or care provider; we will provide useful insights and notifications to improve your care whilst at home and in the care setting. . Owners of a VCP include, but are not limited to, doctors, nurses, clinicians, academic institutions, and other care providers. Data and insights shared are limited to content on the platform that belongs to the Vinehealth Care Program. You have the right at any time to opt out of this sharing by sending a written request to email@example.com.
3.5 - To track and report your Vinehealth data and insights within a Vinehealth Clinical Trial Partnership, with your prior knowledge and consent
By signing up and agreeing to share your Vinehealth data and insights with a Vinehealth Clinical Trial Partner (“VCT”), we will provide useful insights and notifications to improve your care both at home and in the care setting whilst you are part of a clinical trial or other projects with our partners. Owners of a Vinehealth Clinical Trial Partnership include, but are not limited to: academic institutions, clinical research organisations and pharmaceutical companies. Data and insights shared are limited to content on the platform that belongs to the specific Clinical Trial Partner. You have the right at any time to opt out of this sharing by sending a written request to firstname.lastname@example.org.
4. Transparency and Choices
In this section, we have summarised the rights that you have under data protection law. The information we provide in this section is a brief summary of your rights under data protection law and you should still read the relevant laws and guidance from the regulatory authorities for a full explanation of these rights.
Your principal rights under data protection law are:
the right to be informed;
the right of access;
the right to rectification;
the right to erasure;
the right to restrict processing;
the right to data portability
the right to object; and
rights in relation to automated decision making and profiling.
You have the right to confirmation as to whether or not we hold or process your Personal Information and, where we do, access to the Personal Information, together with certain additional information. That additional information includes details of the purposes of the processing, the categories of Personal Information concerned and the recipients of the Personal Information. Providing the rights and freedoms of others are not affected, we will supply to you a copy of your Personal Information, or do one of the following:
We may ask you to verify your identity, or ask for more information about your request; or
Where we are legally permitted to do so, we may decline your request, but we will explain why if we do so.
You have the right to have any inaccurate Personal Information about you rectified and, taking into account the purposes of the processing, to have any incomplete Personal Information about you completed.
In some circumstances, you have the right to the erasure of your Personal Information without undue delay. Those circumstances include: the Personal Information are no longer necessary in relation to the purposes for which they were collected or otherwise processed; you withdraw consent to consent-based processing; you object to the processing under certain rules of applicable data protection law; the processing is for direct marketing purposes; and the Personal Information being unlawfully processed. However, there are exclusions of the right to erasure. The general exclusions include where processing is necessary, for example: for exercising the right of freedom of expression and information; for compliance with a legal obligation; or for the establishment, exercise or defence of legal claims.
You have the right to request that your Personal Information is no longer processed for example, due to the inaccuracy of the Personal Information or the reason for the Personal Information being processed.
If you have given additional consent for your Personal Information to be shared to a third party, including academic institutions, medical device companies and pharmaceutical companies, you have the right to withdraw this consent at any time. You have the right to request that your Personal Information be transferred to another party.
If you consider that our processing of your Personal Information infringes data protection laws, you have a legal right to lodge a complaint with a supervisory authority responsible for data protection. You may do so in the EU member state of your habitual residence, your place of work or the place of the alleged infringement.
To the extent that the legal basis for our processing of your Personal Information is consent, you have the right to withdraw that consent at any time. Withdrawal will not affect the lawfulness of processing before the withdrawal. If you opted in to third party marketing communications when you registered, you may opt-out at any time within the app, or by emailing email@example.com.
Lastly, you will not be subject to decisions that will have a significant impact on you based solely on automated decision-making.
You may exercise any of your rights in relation to your Personal Information by written notice to us or by any of the methods specified in section.
To contact us in relation to any of these requests, please use the email address firstname.lastname@example.org.
5. How long we keep your information
We will keep your Personal Information in our database for as long as you wish to remain on our database in order to receive the benefits of our services. You can edit or update your Personal Information at any time. We may also contact you periodically to prompt you to update your Personal Information. This prompt will give you an opportunity to notify us if you want us to remove you from our database. If you do not respond to these prompts we will take this to mean that you want to continue using Vinehealth.
Please note that if you have consented to a project of the type described in section 3 which has now concluded, we will only be able to delete the Personal Information stored in our databases. As described in section 3.3 Vinehealth may share anonymised and aggregated information with partners and therefore this cannot be removed. However, shared information is not Personal Information.
6. Information Security and International Transfers
Vinehealth is committed to protecting the security of Personal Information by endeavouring to ensure appropriate technologies and processes are maintained to avoid unauthorised access or disclosure. We utilise, for all data storage and processing purposes, Amazon Web Services ("AWS"), Google’s G Suite and Google Cloud. Specifically, all our AWS storage containers and databases are located in London (UK) (with possible transit through US/EU storage containers). All Personal Information collected by the Vinehealth app is encrypted to the highest possible degree both when it is stored in our databases and when it is being transmitted.
If you would like further information about privacy at Vinehealth, please contact us at email@example.com. In the UK, general information on protection of Personal Information, including your rights and freedoms under the General Data Protection Regulation, is available via the Information Commissioner’s Office (“ICO”). Their website address is www.ico.org.uk.