This privacy policy explains how Acurable Ltd (“Acurable”) uses any personal information we collect about you when you purchase and/or use our AcuPebble sensor and accompanying mobile or web applications.
We recognise that privacy is important, and have taken all necessary measures to ensure your information is protected. Acurable and all its associated websites and products are compliant with applicable local laws and regulations, including the General Data Protection Regulation (GDPR) in the EU and the Health Insurance Portability and Accountability Act of 1996 (HIPAA) in the USA.
Topics:
- Why we need your data
- What personal information do we collect about you?
- How will we use the personal information we collect about you?
- What non-personal information do we collect about you?
- How will we use the non-personal information we collect about you?
- What information do we collect about patients?
- How will we use the information we collect about patients?
- Opting out of data processing
- Data storage
- Retention and destruction of your data
- General communication
- Access to your information and correction
- Cookies
- Data security
- Accessibility
- Changes to our privacy policy
- How to contact us
Why we need your data
We need your data in order to:
- Set up and manage your account
- Get in contact with you
- Provide customer service
We only collect data that is necessary to provide the contracted service to you, and should the reason for this collection change, we will inform you immediately.
What personal information do we collect about you?
We collect information about you when a user account is created for you by an authorised administrator within your organisation.
The personal identifiable details we collect from users of our services include:
- Name
- Email address
- Job title
- Workplace name and address
- Telephone number
How will we use the personal information we collect about you?
We will use the personal information we collect about you to manage your account, provide the contracted service and respond to requests for customer service. Acurable Ltd will not share your information with any third parties.
What non-personal information do we collect about you?
Acurable also collects non-personal information, which is information that cannot be used to identify any individual. This information includes:
- Web application usage and activity information, collected using 3rd party cookies and services.
How will we use the non-personal information we collect about you?
We will use non-personal information for the following purposes:
- Web application usage and activity information will be used to analyse how our applications are used, and to improve your user experience.
What information do we collect about patients?
We collect information about patients when a new sleep study is created by an authorised user within your organisation. The information collected about patients does not include any personal identifiable details. Patient details collected to create a new sleep study include:
- Pseudo-anonymised ID
- Date of birth
- Sex
- Medical information relevant to the sleep study (only if requested by your organisation)
Additionally, when the patient conducts the sleep study, we collect the following information:
- Mobile application usage and activity information, collected using in-house systems and 3rd party SDKs.
How will we use the information we collect about patients?
We will use the patients information for the following purposes:
- Mobile application usage and activity information will be used to analyse how our applications are used, and to improve the user experience.
- Anonymised biosignals will be analysed to provide a patient diagnosis, or provided to researchers (with consent) for further analysis.
Opting out of data processing
You do have the right to object, withdraw consent or restrict your personal data. However, the data collected by this application is necessary to provide the contracted service. If you want to opt out of data processing, you will not be able to use the service. If you have any questions, please contact us at contact@acurable.com.
Data storage
Your data will be securely stored in your geographic region (US, European Union or UK depending on your selected region) in compliance with the applicable local laws and regulations (including HIPAA, GDPR and UK GDPR).
Retention and destruction of your data
Your data will be stored for the period specified in the service agreement between Acurable and the healthcare provider who contracted the service. When that agreed period expires, your data will be destroyed.
General communication
Data collected by this application will not be used to send you general communications or marketing materials. Consent for this will be obtained separately, and you may opt out at a later date.
Access to your information and correction
You have the right to request a copy of the personal information that we hold about you. If you would like a copy of some or all of your personal information, please email us at contact@acurable.com. We may make a small charge for this service. We want to make sure that your personal information is accurate and up to date. You may ask us to correct or remove information you think is inaccurate. As a registered user of the web application, you will also be able to correct your personal information directly by logging in and editing your user profile. Should you no longer wish to use the AcuPebble SA100 service, you can inform us and your data will be deleted. We will respond to all such requests as soon as possible, and no longer than 2 months after receipt of the request.
Cookies
Cookies are text files placed on your device to collect standard internet log information and visitor behaviour information. This information is used to track visitor use of the website or application and to compile statistical reports on website activity. For further information visit www.aboutcookies.org or www.allaboutcookies.org. You can set your browser not to accept cookies and the above websites tell you how to remove cookies from your browser. However in a few cases some of our website/application features may not function as a result.
Data security
We have put in place procedures to deal with any suspected data security breach and will notify you and any applicable regulator of a suspected breach where we are legally required to do so.
Accessibility Statement
Acurable is committed to ensuring digital accessibility for people with disabilities. You can read our full accessibility statement here.
Changes to our privacy policy
We keep our privacy policy under regular review and we will place any updates on this web page. This privacy policy was last updated on 29th October 2021.
How to contact us
Please contact us at contact@acurable.com if you have any questions about our privacy policy or information we hold about you. Acurable’s Data Protection Officer (DPO) can be contacted at dpo@acurable.com or by calling +34 91 4198023. If you have a complaint, you can also contact your national data protection authority, which is an independent regulator set up to uphold information rights. You can find their contact details at:
- Europe: https://edpb.europa.eu/about-edpb/about-edpb/members_en
- United Kingdom: https://ico.org.uk/global/contact-us
- United States: https://www.hhs.gov/ocr/about-us/contact-us