EFFECTIVE DATE: 19 MAY 2020

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 controller in relation to personal data processed in connection with the CVm-Health application (the “CVm-Health App”).  

The CVm-Health App provides a remote way for users that are self-isolating at home, including those who suspect they have contracted or who are recovering from the COVID-19, to record and monitor their vital sign data, symptoms and certain other relevant data, in a form that may be readily shared by an individual with healthcare professionals or family members.  The CVm-Health App is intended to provide individuals with an electronic diary system to document, monitor and view their own vital sign and symptom observations.

To provide and enable your use of the CVm-Health App Sensyne processes and requires certain personal data, including about your health, from you.  In this privacy policy (“CVm-Health Privacy Policy”), we provide you with information about the collection, use, transfer, and other processing of your personal data in connection with the CVm-Health App.  

As the COVID-19 situation is evolving we may need to make changes to this policy.  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.  

You must be aged over 18 years old to use the CVm-Health App.
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PERSONAL DATA PROCESSED BY SENSYNE

In the course of providing the CVm-Health App, Sensyne will collect and process information that you input to the CVm-Health App.  This information may contain personal data, including identifiers, such as your email address or username, and information about your health.  If you use third party apps, products or services to measure data about your health that you then input into the CVm-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 the CVm-Health App we will automatically collect personal data such as device and usage data.  We collect this data using cookies and other similar technologies. Please see our cookie policy for further details.
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SHARING

The sharing functionality of the CVm-Health App enables you to share your personal data stored in the CVm-Health App with others (such as a family member or healthcare professional or organisation).  

In order to enable Sensyne to provide the CVm-Health App to you, Sensyne will disclose your personal data to its third-party processors, such as cloud hosting providers, who process that personal data on Sensyne’s behalf.  

In addition, we may share personal data:

• with your consent or pursuant to your instructions;
• among Sensyne’s corporate affiliates; and
• for legal purposes such as in connection with a substantial corporate transaction, such as a merger, consolidation, asset sale, or in the unlikely event of bankruptcy.  We also may disclose information to respond to subpoenas, court orders, legal process, law enforcement requests, legal claims or government inquiries, and to protect and defend the rights, interests, safety, and security of Sensyne, our affiliates, users, or the public.

PURPOSES OF PROCESSING AND LEGAL BASIS

Our legal basis for processing your personal data depends on the reason or reasons we collect and use your personal data, namely:  

• you consent to the processing of your personal data for the specific purposes you indicate in the consent form when you register to use the CVm-Health App;  
• you consent to the sharing of your personal data stored in the CVm-Health App with others (such as a family member or healthcare professional or organisation) by using the relevant functionality; or
• to fulfil a legitimate interest that we have as a business, for example, by processing analytical data relating to your use of the CVm-Health App (such as data relating to how you interact with the CVm-Health App) to maintain and improve the CVm-Health App.  

In order to enable Sensyne to provide the CVm-Health App to you, Sensyne will disclose your personal data to its third-party processors, such as cloud hosting providers, who process that personal data on Sensyne’s behalf.  
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INTERNATIONAL TRANSFERS

Sensyne stores your personal data in the United Kingdom for users based in the United Kingdom and in the United States for users based in the United States.  
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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 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.

You or your authorised representative may request to exercise these rights by contacting our Data Protection Officer using the contact details below.  [These rights are not absolute.  For example, we will not respond to a request if we cannot verify you as the requestor.  If you choose to exercise your rights, we will not provide a different quality or level of service unless those differences are related to your information or otherwise permitted by law.]  

If you are based in the United Kingdom, 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.
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WITHDRAWAL OF CONSENT

You may withdraw your consent to our processing of your personal data at any time but that will not affect the lawfulness of any processing carried out before you withdraw your consent.  To do so please contact the Data Protection Officer on dpo@sensynehealth.com.

If you withdraw your consent to Sensyne processing your personal data as required to enable Sensyne to provide the CVm-Health App to you, you will no longer be able to use the CVm-Health App.

If your withdraw your consent to Sensyne processing your personal data for medical research purposes, including anonymising your data and disclosing that anonymised data to third parties for medical research purposes, Sensyne will no longer process your personal data for medical research purposes, but Sensyne and other third parties may continue to use any anonymised data based on your personal data prior to the withdrawal of my consent since that anonymised data is not personal data.
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CONTACT US  

If you have further questions about this CVm-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.