ALGO+ App
ALGO+ App Privacy Policy (“Privacy Policy”)
Version 1, Effective 7 July 2023
This Privacy Policy applies to the use of the ALGO+ App. ALGO Quality LLP (“ALGO”) provides a platform and mobile application ALGO+ to enable, integrate and digitalise the management of clinical research and medical care for doctors and patients (collectively, the “App”). The doctor (“Investigator”) and/or institute (“Site) is responsible for the conduct of the clinical research and medical care. ALGO is a service provider to the Investigator and/or Site. At the direction of the doctor and/or institute, ALGO may process personal information submitted to the App or collected through the App.
The App was created by ALGO to be used by individuals who are participating in a clinical research (“Study”) conducted by a Investigator and/or Site. Prior to your participation, you will be required to review and sign an informed consent form (the “ICF”). The Investigator and Site is identified in the Study-specific ICF. You should refer to the Study-specific ICF for the details regarding your Study including the data that will be collected. ALGO is committed to applying the appropriate standards in the processing of personal information and data. This Privacy Policy explains how your data may be processed by ALGO in connection with the Study in which you are a clinical research participant. The Investigator and/or Site controls your personal information and data and is the data controller. ALGO process the personal information and data of trial participants in each Study through the App and is the data processor for the Investigator and/or Site.
This Privacy Policy is published on ALGO website: http://www.algoquality.com/ALGO+%20Privacy%20Policy.html.
BASIS FOR PROCESSING PERSONAL INFORMATION
ALGO processes your personal information obtained from the App to fulfil its contractual obligations to the specific Investigator and/or Site and to enable them to conduct the Study. ALGO hosts the digital platform used by the Investigator and/or Site to run the Study. ALGO may process your personal information (including but not limited to health data) and consent for the processing of your personal information and data.
You are not permitted to participate in the Study unless you have signed an ICF providing your informed consent for the collection and use of the information to be collected for the Study. You acknowledge and agree that the Investigator and/or Site of the Study are responsible for ensuring all appropriate and required monitoring of the Study including your medical care. If you have any questions regarding the Study, the ICF or the information collected through the App and during the Study, you will need to directly contact the Investigator and/or the Site identified in your Study ICF.
By downloading, accessing, viewing or otherwise using the App, you acknowledge that you expressly consent to the collection and use of your information by ALGO in accordance with this Privacy Policy, have read and understand this Privacy Policy; and understand how ALGO collect, use and process your personal information and data.
INFORMATION COLLECTION
ALGO collects and processes personal information from you when you register to use the App, respond to ALGO communication such as an email, or otherwise use the App in any manner. As required by the Investigator and/or Site, for each Study you may provide through the App (and ALGO may process) personal information that may include sensitive or special categories of data as defined in the General Data Protection Regulation (GDPR). Personal information processed will vary with each Study, but may include:
· Identity Data: For example, your name, date of birth, gender, ethnicity, and identification number.
· Contact Data: For example, your email address, telephone number and postal code.
· Health Data: For example, clinical data as part of the Study, and any other relevant information on your general health and your medical care.
· Data from your smartphone devices: Where applicable, your data is collected during your use of the App on your smartphone. This information is stored in a GDPR-compliant cloud infrastructure.
ALGO APP AND USER DATA
Investigator and/or Sites and their authorized users may enter information from or about their authorized users, employees, and clinical trial subjects (collectively, “User Data”), into the App.
ALGO is not responsible for the control of the Investigator and/or Site’s handling of the personal information and User Data collected in the App. Each Investigator and/or Site has its own policies regarding the use and disclosure of personal information and data. ALGO use of such data is subject to the written agreement for services between ALGO and the Investigator and/or Site, and it does not involve the sale of your data. ALGO’s primary responsibility under any such agreement is the obligation to keep User Data safe and secure. To learn about how your Investigator and/or Site handles your personal information and User Data, do contact them directly or read the Investigator and/or Site’s privacy statement.
ALGO has no control or ownership of the personal information and User Data. Please direct any questions regarding personal information and User Data to the Investigator and/or Site collecting your information under the Study through the App.
INFORMATION USE
ALGO host your personal information (including personal information and User Data) on ALGO systems (which may involve storing it on GDPR-compliant cloud infrastructure and delegating certain processes to sub-processors) so that the Investigator and/or Site can perform the Study with the information.
ALGO may anonymized and aggregate personal information for the purpose of the Study and for maintaining ALGO platform and services. Aggregated data is information that has been combined with that of other users and analysed or evaluated as a whole, such that no specific individual may be reasonably identified. Anonymized information is information that has been stripped of your identifiers, such as your name, contact information, and any other identifying data, such that you cannot reasonably be identified or re-identified as an individual. ALGO may use this anonymized and aggregated information to conduct diagnostic testing to ensure that the App is working correctly from time to time or to investigate any issues arising from the usage or performance of the App in relation to a Study.
HOW AND WHEN ALGO SHARE INFORMATION WITH THIRD PARTIES
ALGO may share information with the Investigator and/or Site and this may include your personal information and User Data with service providers who assist ALGO in its business operations. ALGO may also share information where required by law or to satisfy any applicable law, regulation, government request, or other legal process. ALGO may also share information with third parties, including government agencies, to protect the the App and to enforce ALGO’s Terms of Use. ALGO also reserve the right to share the information that ALGO collect within its organisation in the event of a merger, consolidation, sale of its assets, or other change in its business, subject to our agreements within the Investigator, Site and your ICF.
UPDATING YOUR INFORMATION
The Investigator and/or Site controls your information. In order to exercise your relevant rights, contact the Investigator and/or Site directly. The App does not allow you to update certain information collected. Any ability to update your information can only be permitted and performed by the Investigator and/or Site and not by ALGO. ALGO can only intervened to update certain information collected at the direction of the Investigator and/or Site. You may request an update to your information by contacting the Investigator and Site as specified in the ICF.
Users of the App may update their information and exercise rights to data erasure, data portability, object to or restrict processing, and exercise an access request by contacting the Investigator and/or Site as the data controller.
INFORMATION SECURITY
ALGO has in place physical, electronic and organizational procedures to safeguard and secure the personal information and User Data stored on its systems. ALGO deploys encryption, firewalls, access controls, and other procedures to protect data from loss, misuse, unauthorized access, disclosure, alteration, and destruction. Access to ALGO facilities is controlled via a combination of technical and physical controls. ALGO maintains a disaster recovery plan and system back up plan in the event that its systems are damaged or destroyed. All employees receive training on security and are required annually to review and understand global data protection standards applicable to ALGO.
CHANGES/UPDATES
ALGO reserve the right to change, modify, add or remove portions of this App Privacy Policy at any time, without prior notice. Any updated version of this Privacy Policy will be maintained in the “Privacy Policy Section” in the app store. Changes take effect on the date that appears on the revised App Privacy Policy. If you use the App following a change in this App Privacy Policy, your continued use will be understood to signal that you accept and agree to be bound by the changes. ALGO recommend that you review this App Privacy Policy regularly. All changes will comply with applicable law and your ICF.
GENERAL DATA PROTECTION REGULATION PRIVACY TERMS
If ALGO process your personal data in the European Economic Area (EEA) or the United Kingdom (UK), or intentionally market the App to you as an individual if you reside in the EEA or UK, additional General Data Protection Regulation (GDPR) terms for how ALGO collect, process and use your personal data (as defined under GDPR) may apply.
CONTACT INFORMATION
If you have any questions or concerns regarding the way in which your personal information is processed and used by ALGO, please contact ALGO using the following details.
Email: privacy@algoquality.com
ALGO Quality LLP, 169 Jalan Jurong Kechil, #05-14, Singapore 598669