Sensyne Health Group Limited, incorporated in England (company number 11240986) with its registered office at John Eccles House, Robert Robinson Avenue, Oxford Science Park, Oxford, OX4 4GP (“Sensyne”) is committed to protecting your personal data and is the data processor in relation to personal data processed in connection with the GDm-Health application (the “GDm-Health App”).  

GDm–Health is a remote mobile communication system to support patients with diabetes in pregnancy including gestational diabetes mellitus (GDM); a condition which results in high blood sugar levels in women who are pregnant.

The primary purpose of GDm-Health is to enable patients and clinicians to remotely monitor blood glucose (BG) levels and to provide a bi-directional communication system between the patient and their clinician.

The intended benefits of using GDm-Health are to improve the patient’s control of their blood glucose levels and thus reduce the number of visits to clinic alongside improving outcomes for mother and baby.

The data recorded in and generated by your use of the GDm-Health Application may be anonymised and used for medical research.

We may need to make changes to this policy from time to time. Where changes are required, we shall notify you and ensure that any processing of your personal data remains in accordance with applicable data protection laws.
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PERSONAL DATA PROCESSED BY SENSYNE

To provide and enable your use of the GDm-Health App Sensyne will collect and process certain personal data, including health data which will be inputted into the app by you. This includes:

• Confidential personal data (health records) e.g. Patient Name, DOB, Mobile Number, Postcode, Email Address, Ethnicity, Local Hospital Number, NHS Number, Estimated Date of Delivery.
• Patient history e.g. Type of Diabetes, Date of Diagnosis, Medications and Units
• Patient blood glucose readings e.g. blood glucose level, prandial tag for reading, medications taken, free text commentary
• Messages and notes from the midwife
• Anonymous activity and analytics
• GDm-Health holds patient identifiable information which is processed and stored on a third-party data centre, assessing all potential threats and vulnerabilities, calculating the risks and impacts is crucial to the patients’ interests.

In this Privacy Policy, we provide you with information about the collection, use, transfer and other processing of your personal data in connection with the GDm-Health App.

Please not that in addition to this Privacy policy, the collection and use of your personal data will be subject to any applicable privacy policies and disclosures of your Health Care Provider as the Controller.

Sensyne Health are data processors while the Health care provider are the data owners/controllers. Sensyne Health has an agreement with each customer that they will seek and obtain patient consent or will have another legal basis for processing personal data including special category data.

If you use third party apps,  products or services to measure data about your health that you then input into the GDm-Health App, your use of those apps, products and services will be subject to the applicable third party terms of use and privacy policies, and Sensyne will not have any responsibility for them or the information they provide.  

Each time you use one the GDm-Health App we will automatically collect personal data such as device and usage data.

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PURPOSES OF PROCESSING AND LEGAL BASIS

Our legal basis for processing your personal data as per Article 6 of GDPR, depends on the reason or reasons we collect and use your personal data, namely:

• your consent provided to your healthcare provider to the processing of personal data including special category data for one or more specific purposes; and
• to fulfil a legitimate interest that we have as a business, for example, by processing analytical data relating to your use of the GDm-Health App (such as data relating to how you interact with the GDm-Health App) to maintain and improve the GDm-Health App or using the data provided to keep you updated on Sensyne Health Products and Services*. *please note that you can always opt-out of this service by contacting dpo@sensynehealth.com. Opting out will not affect the usage of the app.

PERSONAL DATA SHARING

Data collected from patients using the app will be shared only with health care providers managing these patients. There is a Data Processing Agreement in place with each health care provider.

In order to be enable Sensyne to provide the GDm-Health App to you, Sensyne may disclose your personal data to its third-party processors.

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INTERNATIONAL TRANSFERS

Sensyne stores your personal data in the United Kingdom.

Sensyne may provide access to your personal data to third party processors located outside of the United Kingdom to support the delivery of the GDm-Health App to you. Some of these processors may be located in a jurisdiction, such as the United States, whose privacy laws may not be equivalent to the United Kingdom. We apply appropriate safeguards in respect of such transfers to protect your personal data in accordance with applicable data protection law (for example, we may use standard data protection contractual clauses to protect your personal data, and where we do, a copy of these clauses is available upon request by contacting us via the details below).

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RETENTION

Details of our retention periods for different aspects of your personal data are available in our retention policy which you can request by contacting us.
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YOUR RIGHTS

Under certain circumstances, you may have certain rights under applicable data protection law in respect of your personal data, including:

• to object or request the restriction of processing of your personal data; and
• to request access to, rectification of (e.g., if your personal data is out of date), erasure of, or portability of, your personal data.

Requests to exercising these rights can be made using the contact details below.

You have the right to make a complaint at any time to the Information Commissioner's Office (ICO), the UK supervisory authority for data protection issues.

Your rights will not be affected due to your decision to opt out or make a complaint and you will be treated as any other customer.

By using this app , you accept that you have read and understood the above terms of this GDm-Health Privacy Policy and agree to Sensyne processing your personal data under the legal basis stated above as required by Sensyne to enable the use of the GDm-Health App in accordance with the Terms of Use and as described in this GDm-Health Privacy Policy.  

You acknowledge that your consent is required to install and use the GDm-Health App.  You may withdraw your consent at any time but that will not affect the lawfulness of any processing carried out before you withdrew your consent. If you choose to withdraw your consent, you will no longer be able to use the GDm-Health App.

To do so please contact the Data Protection Officer on dpo@sensynehealth.com or Sensyne Health, John Eccles House, Robert Robinson Avenue, Oxford Science Park, Oxford, OX4 4GP.
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CONTACT US  

If you have further questions about this GDm-Health Privacy Policy, please contact:

The Data Protection Officer by email at dpo@sensynehealth.com or by post at Sensyne Health, John Eccles House, Robert Robinson Avenue, Oxford Science Park, Oxford, OX4 4GP.

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CHANGES TO PRIVACY POLICY

This Privacy Policy may change from time to time but not later than 12 months from the last update and the statement will be reflected on the app.

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Last updated 08 June 2020