ALTUS CARE PRIVACY POLICY

Last Updated: November 29, 2021

We reserve the right to modify this privacy policy at any time, so please review it frequently. If we decide to change this privacy policy in any material way, we will notify you here, by email, or through a notice on our platform. In all cases, your continued use of our platform constitutes acceptance of any such changes.

Acceptable Age

Our website and the services offered here are not directed at persons under the age of 18. We do not knowingly collect personal information from children under the age of 18. If a child under the age of 18 has provided us with personal information without its parent’s or guardian's consent, the parent or guardian must contact us immediately to withdraw consent.

Introduction

Area9 Innovation ApS (“Area9”, “we”, “us”) built the Altus Care Platform as a free application. The platform consists of a web based interface and an application (collectively the “Services”). When you use the Services, Area9 collects and processes certain personal data about you. When we collect or otherwise process personal data about you we act as data controller. What information we collect and how we use it depends on how you choose to use our Services. Below you will find more information about when, how and for what purpose we process your personal data:

General use of our website and app:

WHAT: If you accept our use of cookies on the website we will process information about your IP-address. For information about what cookies we use on our website, please see our cookie policy. We further collect information about the device and browser you use to access our Services and their interaction with our Services. We further collect information about how often and for how long you use or Services.

PURPOSE: to be able to maintain and improve our Services and optimize your experience when you visit our website or use our app including ensuring the functionality, generate user statistics, remember your user preferences etc.

LEGAL BASIS: our legitimate interests in generating useful and correct statistics about visitors’ use of our website and improve the operation of our website and marketing our services on social media, cf. GDPR article 6, para 1 litra f.

RETENTION PERIOD: your IP-address will be stored for 13 months after the cookie was placed on your device.

THIRD PARTY RECIPIENTS: We may use the following entities to store and process your personal information:

When you create a user account:

WHAT: when you create a user account, we require the following information about you: first and last name, e-mail address, date of birth, your country of residence and diagnosis. Furthermore, to have the full benefit of the Services offered by us, we may require information about your gender, weight, workplace, preferred language, treatment regimes, preferred medicine time, image- video-or audio files.  

PURPOSE: We use the information to provide the Services to you (whether you are a patient or a healthcare provider). We may also use the information to maintain, improve, personalize and/or measure the performance of the Services.

LEGAL BASIS FOR PROCESSING: the legal basis for processing information will be the express consent from you which is required pursuant to article 9 section 2, litra a) of the GDPR for our performance of the Services. Please note that you have the right to withdraw your consent at any time by notifying us at  gdpr@area9.dk. If you withdraw your consent, we will no longer be able to provide the Services to you.  

RETENTION PERIOD: We will keep the personal information that we collect from you when you create a user account for as long as your account is active or until you change or delete that information. If keeping your data or parts thereof lacks a meaningful purpose in providing Services to you, we will delete that data earlier. Data stored in our backup systems with our third-party hosting providers will be deleted as soon as practically possible after deletion, but in no event later than 6 months after deletion.

THIRD PARTY RECIPIENTS: if you are a patient your personal information will be shared with the healthcare provider(s) that you have consented to. If you are a healthcare provider we will make your personal information available for the patients on the platform. We may also transmit your information to our third party services providers in the provision of our Services. Such third party service providers are acting on behalf of us according to our instruction and they are under an obligation not to use your personal information for any other purpose.

When you use the Services:

WHAT: When you use the Services we further process information about you and your activities such as your treatment regime, related tasks and task status information, questionnaires and answers, communication with your healthcare provider(s) that you share via the Services.

PURPOSE: We use the information to provide the Services to you (whether you are a patient or a healthcare provider). We may also use the information to maintain, improve, personalize and/or measure the performance of the Services.

LEGAL BASIS FOR PROCESSING: the legal basis for processing information will be the express consent from you which is required pursuant to article 9 section 2, litra a) of the GDPR for our performance of the Services. Please note that you have the right to withdraw your consent at any time by notifying us at gdpr@area9.dk. If you withdraw your consent, we will no longer be able to provide the Services to you.  

RETENTION PERIOD: We will keep the personal information that we collect from you when you create a user account for as long as your account is active or until you change or delete that information. If keeping your data or parts thereof lacks a meaningful purpose in providing Services to you, we will delete that data earlier. Data stored in our backup systems with our third-party hosting providers will be deleted as soon as practically possible after deletion, but in no event later than 6 months after deletion.

THIRD PARTY RECIPIENTS: if you are a patient your personal information will be shared with the healthcare provider(s) that you have consented to. If you are a healthcare provider we will make your personal information available for the patients on the platform. We may also transmit your information to our third party services providers in the provision of our Services. Such third party service providers are acting on behalf of us according to our instruction and they are under an obligation not to use your personal information for any other purpose.

Transfer of personal data outside of EU/EEA

As part of our processing we may transfer personal data about you to third countries outside EU/EEA which do not ensure an adequate level of protection within the meaning of the GDPR including the U.S. If we do so, we will ensure that appropriate safeguards are in place as required by the GDPR such as standard contractual clauses with the recipient of personal data about you. A copy the appropriate safeguards taken by us will be available upon your request.

Your Rights as a data subject

You are entitled to certain rights regarding the personal data that we process about you. You may exercise these rights by contacting us on gdpr@area9.dk. Your rights include the following, but may be subject to certain conditions set out in the GDPR or other applicable data protection law:

Contacting Area9

If you have any complaint, questions, concerns, or comments, kindly reach out to us at gdpr@area9.dk and we will be happy to address them.

Alternatively, for Area9 Group’s representative on GDPR matters, please contact

Area9 Innovation ApS

Galionsvej 37

DK-1437 Copenhagen K

Cvr.nr. 36921897

Denmark

Email: gdpr@area9.dk 

Phone: +45 33110090

Contacting the supervisory authority (Datatilsynet)

If you disagree with or have complaints about our processing of your personal data, you have the right to lodge a complaint with Datatilsynet, the Danish supervisory authority for data protection.