RSL Privacy Policy For PI-Enroll® App

Updated September 13, 2020

This Privacy Policy provides an overview of the privacy practices of Refuah Solutions Ltd. (“Refuah” or “RSL”, which is also referred to herein as “we”, “us”, or “our”).  
RSL recognizes and respects the privacy of users of the PI-Enroll Mobile App (the “App”).  This Privacy Policy informs you of our activities regarding the collection, use and disclosure of personal information we collect about users of the App. By using the App, you agree that you have read and understand our privacy practices and consent to us collecting, possessing, using, processing and disclosing your personal information in accordance with this Policy.  Please read the following description carefully before accessing and using the App:

 

1. Scope:

This Privacy Policy outlines our collection, possession, use, processing and disclosure of a user’s personal information associated with the use of the App. IT IS NOT NECESSARY TO ENTER ANY PERSONAL INFORMATION OR ANY PERSONAL HEALTH INFORMATION ABOUT A PATIENT IN ORDER TO ENROLL THAT PATIENT IN A CLINICAL TRIAL THAT IS DESCRIBED IN THE APP, AND WE REQUEST THAT YOU NEVER DO SO.  WE WILL PROMPTLY REMOVE ANY SUCH INFORMATION IF WE DISCOVER IT.

2. Data collection:
We will collect your personal information, usage data and analytics.

3. Use and disclosure: 
We may use, possess, process and disclose the personal information collected about you as described in this Policy.

4. Contact RSL:
If you have any questions about this Privacy Policy, please contact us at: info@refuahsolutions.com

Data Collection


We collect the following types of information about users of the App:


1. Personal information:

 

To facilitate study team and community-based practitioner communications, the App will require the input of your name, email address and cell phone number.  Patients will not be given access to this information. If agreed to, this information can be deleted at any time and for any reason at your request. However, deleting this information will negatively affect your ability to participate in study team and community-based practitioner communications.
 

We do not knowingly collect any additional personal identifiable information such as your full name or date of birth.
 

2. Usage and analytics data:When you access the App, we may automatically collect certain information including a non-personally identifiable random universally unique identifier (UUID). While the App does not automatically collect your device’s operating system information, information from the App Store downloads will contain it and, if requested, will be made available to us. To help us understand, improve and enhance user experiences, we may track in-app events (such as frequency of use of the App’s bulletin board) in a non-personally identifiable fashion to gather information and analyze your use of the App.
 

If you wish to stop all collection of information by the App, simply uninstall the App using the standard uninstall process for your device.
 


Information Use

 

We may use the information collected about you for the following general purposes:

1.    To provide, maintain and improve the App; to perform technical operations; to allow you to participate in or suggest additional features of the App; to customize your experience on the App; and to detect, prevent and address technical issues.
2.    Research and analytics: To analyze user interactions with the App, including monitoring and analyzing usage; and for other research and statistical purposes.
3.    Legal compliance: as permitted or required by law.

 


Disclosure of Information

We may disclose your personal information in the good faith belief that such action is necessary for any of the following purposes:


1. Purposes disclosed in this Policy: 
to fulfill the purposes of collecting, possessing, using and processing information as outlined in this Policy.

 

2. Legal requirements: 
to comply with a legal obligation; to protect and defend the rights, property or safety of Refuah; to prevent or investigate wrongdoing in connection with the App; to protect the personal safety of users of the App or the public; and to protect against legal liability. In such cases we reserve the right to raise or waive any legal objection or right available to us. 

 

3. Communication with Sponsors and Clinical Research Organizations:

information regarding your use of the App to assist you in enrolling one or more patients in a clinical trial may be disclosed to the Sponsor (or its Clinical Research Organization – a “CRO”) of that clinical trial (for example, in order to provide you with an access code or to provide the Sponsor (or its CRO) with statistical information regarding your use of the App to enroll patients in that clinical trial).

 

4. Research:

information that is aggregated, generalized, and de-identified (ie. information that could identify you having been removed) may be disclosed to the public or interested stakeholders, such as health researchers, physicians, and patients, to evaluate the reach and effectiveness of the App in addressing the value of apps in health care delivery, to improve the App, and for other statistical and analytical purposes. We may publish or present this information but will not include any information that could identify you.


Data Storage


All information collected by the App will be stored in cloud storage services. Industry standards and organizational measures will be used to protect and prevent unlawful processing, damage or use of personal information.

Security
 

We will take all steps reasonably necessary to treat your personal information securely and in accordance with this Privacy Policy.


The security of your personal information is important to us, but unfortunately the transmission of information over the Internet is not completely secure. While we strive to use commercially acceptable means to protect your personal information, we cannot guarantee the security of your information transmitted to our App. We will use security features and procedures to prevent unauthorized access to your personal information once we receive it.

Changes to this Privacy Policy
 

We may update this Privacy Policy from time to time. Any changes we may make to this Policy in the future will be posted on this page. The effective date of any changes to this Policy will be updated at the top of this Privacy Policy so that you can be fully informed about our privacy practices. Please review this Privacy Policy periodically for any changes and updates. Your continued use of the App after the effective date of any change or update constitutes your agreement with that change or update.

Contact
 

If you have any questions or comments about this Privacy Policy, please contact us by email at: info@refuahsolutions.com