Mobile app privacy policy for JANAMAPP

 

Policy version: May 2023

JANAMAPP (the app) is provided by University Hospitals of Leicester NHS trust, in collaboration with 2SN Healthcare Ltd (‘we’, ‘our’ or ‘us’).

We take your privacy very seriously. Please read this privacy policy carefully as it contains important information on how and why we collect, store, use and share any information relating to you (your information).

It also explains your rights in relation to your information and how to contact us or the relevant regulator in the event you have a complaint. Our collection, storage, use and sharing of your information is regulated by law, including under the UK General Data Protection Regulation (UK GDPR).

We are the controller of personal data obtained via the app, meaning we are the organisation legally responsible for deciding how and for what purposes it is used.

 

If you are aged under 16 you must not use the app as it is not designed for you. We do not intend to collect the personal data of anyone under 16. If you are aware that any personal data of anyone under 16 has been shared with the app, please let us know so that we can delete that data.

If you are aged over 16 you may use the app. This version of our privacy policy is primarily written for adults, including parents and guardians of child users.

The app is distributed only on UK app stores and is solely intended for use by people in the UK.

This privacy policy is divided into the following sections:

 

• What this policy applies to
• Personal data we collect about you
• Location services/data
• Use of the camera on your device for augmented reality
• How your information is collected
• How and why we use your information
• Potential Marketing
• Your rights
• Keeping your information secure
• How to complain
• Changes to this privacy policy
• How to contact us

If you are aged under 18, we recommend that you speak to an adult that you trust if you have any difficulties reaching an informed decision regarding the activation of any use of your data or our treatment of your data.

 

What this policy applies to

This privacy policy relates to your use of the app only.

The app links to websites or services owned and operated by certain trusted third parties to make additional products, information and services available to you. These other apps, websites or services may also gather information about you in accordance with their own separate privacy policies. For privacy information relating to these other apps, websites or services, please consult their privacy policies as appropriate.

 

Personal data we collect about you

The personal data we collect about you depends on the particular activities carried out through the app. We will collect and use the following personal data about you:

Category of data	In more detail
Identity and account data you input into the app Registration is mandatory in order to use the app	—your unique code to access the app for free —information to check and verify your identity, —information (unidentifiable) about your age (in years) and if this is your first pregnancy, —your account details, possibly a username or password where applicable, depending on the user —your replies to security questions
Data collected when you use specific functions in the app	—data you store online with us using the app including feedback regarding our services, comments etc including feedback of the App in the form of voice notes to be published to other users.
Data collected when you permit the collection of location data	—details of your location with a high degree of precision, see the section ‘Location services/data’ below
Other data the app collects automatically when you use it	—your activities on, and use of, the app which reveal your preferences, interests or manner of use of the app and the times of use

If you do not provide personal data we ask for where it is ‘required’ it will delay or prevent the app from providing services and functions to you.

We collect and use this personal data for the purposes described in the section ‘How and why we use your information’ below.

 

Location services/data

The app will request your consent to use location services to precisely identify your location each session (ie each time the app is opened or has been placed in the background. We require access to that data in order to improve services.

If you do not provide your consent, you may use the app but that will mean certain features may not be available. To withdraw your consent at any time please email us at info@janamapp.co.uk (that will not affect the lawfulness of our use of that data in reliance on the consent before it was withdrawn).

We will not process your location data other than to allow us to improve local services.

The location services in the app will not operate unless location services/data are generally enabled on your device. You may disable such functionality at any time by references to device settings.

 

Use of the camera or microphone on your device for feedback

Permission will be requested to use the camera or microphone on your device in order to enable the feedback features in the app.

Data gathered by the camera for such purposes remains under your control on the device and we do not have access to it.

 

How your information is collected

We do not collect personal identifiable data from you. We promote and practice data minimisation principles and only collect the minimal information required to allow app and service function.

Under data protection law, we can only use your information if we have a proper reason, eg:

 

• where you have given consent
• to comply with our legal and regulatory obligations
• for the performance of a contract with you or to take steps at your request before entering into a contract, or
• for our legitimate interests or those of a third party

A legitimate interest is when we have a business or commercial reason to use your personal data, so long as this is not overridden by your own rights and interests. We will carry out an assessment when relying on legitimate interests, to balance our interests against your own. You can obtain details of this assessment by contacting us (see ‘How to contact us’ below).

The table below explains what we use your information for and why.

What we use your information for	Our reasons
Create and manage your account with us	For our legitimate interests, ie to be as efficient as we can so we can deliver the best service to you
Providing the functionalities of the app to you	Depending on the circumstances: —to perform our contract with you or to take steps at your request before entering into a contract —for our legitimate interests, ie to be as efficient as we can so we can deliver the best service to you.
Conducting checks to identify you and verify your identity or otherwise to help prevent and detect fraud against you or us	To comply with our legal and regulatory obligations
To enforce legal rights or defend or undertake legal proceedings	Depending on the circumstances: —to comply with our legal and regulatory obligations —in other cases, for our legitimate interests, ie to protect our business, interests and rights
Communications with you not related to marketing, including about changes to our terms or policies or changes to the app or service or other important notices	Depending on the circumstances: —to comply with our legal and regulatory obligations —in other cases, for our legitimate interests, ie to provide the best service to you
Protect the security of systems and data used to provide the app and its services	To comply with our legal and regulatory obligations We may also use your information to ensure the security of systems and data to a standard that goes beyond our legal obligations, and in those cases our reasons are for our legitimate interests, ie to protect systems and data and to prevent and detect criminal activity that could be damaging for you and/or us
Operational reasons, such as improving efficiency, training and quality control or to provide support to you	For our legitimate interests, ie to be as efficient as we can so we can deliver the best service to you
Statistical analysis to help us understand our customer base	For our legitimate interests, ie to be as efficient as we can so we can deliver the best service to you
Updating and enhancing customer records	Depending on the circumstances: —to perform our contract with you or to take steps at your request before entering into a contract —to comply with our legal and regulatory obligations —where neither of the above apply, for our legitimate interests, eg making sure that we can keep in touch with our customers about existing orders and new products
Disclosures and other activities necessary to comply with legal and regulatory obligations, eg to record and demonstrate evidence of your consent to our use of your information where relevant and [insert]	To comply with our legal and regulatory obligations
Potential Marketing our services to existing and former customers	For our legitimate interests, ie to promote our business to existing and former customers See ‘Marketing’ below for further information.
To share your information with members of our group and third parties that will or may take control or ownership of some or all of our business (and professional advisors acting on our or their behalf) in connection with a significant corporate transaction or restructuring, including a merger, acquisition, asset sale, initial public offering or in the event of our insolvency In such cases, information will be anonymised where possible and only shared where necessary	Depending on the circumstances: —to comply with our legal and regulatory obligations —in other cases, for our legitimate interests, ie to protect, realise or grow the value in our business and assets

 

 

How and why we use your information—sharing

 

Healthcare or Medical Services Related Notifications

We may use your information to send you updates (by push notifications, telephone or post) about our [services], including new services, healthcare notifications or applicable medical services.

We have a legitimate interest in using your information for potential healthcare improvement purposes (see above ‘How and why we use your information’). This means we do not need your consent to send you important information. If we change our approach in the future so that consent is needed, we will ask for this separately and clearly.

You have the right to opt out of receiving communications at any time by:

 

• contacting us at info@janamapp.co.uk

We will always treat your information with the utmost respect and never sell OR share it with other organisations for marketing purposes.

For more information on your right to object at any time to your information being used for marketing purposes, see ‘Your rights’ below.

 

Your rights

You generally have the following rights, which you can usually exercise free of charge:

Access to a copy of your information	The right to be provided with a copy of your information A more detailed explanation of this right is available here
Correction (also known as rectification)	The right to require us to correct any mistakes in your information A more detailed explanation of this right is available here
Erasure (also known as the right to be forgotten)	The right to require us to delete your information—in certain situations A more detailed explanation of this right is available here
Restriction of use	The right to require us to restrict use of your information in certain circumstances, eg if you contest the accuracy of the data A more detailed explanation of this right is available here
Data portability	The right to receive the personal data you provided to us, in a structured, commonly used and machine-readable format and/or transmit that data to a third party—in certain situations A more detailed explanation of this right is available here
To object to use	The right to object: —at any time to your information being used for direct marketing (including profiling) —in certain other situations to our continued use of your information, eg where we use you personal data for our legitimate interests unless there are compelling legitimate grounds for the processing to continue or the processing is required for the establishment, exercise or defence of legal claims A more detailed explanation of this right is available here
Not to be subject to decisions without human involvement	The right not to be subject to a decision based solely on automated processing (including profiling) that produces legal effects concerning you or similarly significantly affects you We do not make any such decisions based on data collected by the app. A more detailed explanation of this right is available here
The right to withdraw consents	If you have provided us with a consent to use your information, you have a right to withdraw that consent easily at any time. You may withdraw consents by deleting the app, and informing us in writing accordingly.  Withdrawing a consent will not affect the lawfulness of our use of your information in reliance on that consent before it was withdrawn.

For further information on each of those rights, including the circumstances in which they do and do not apply, please contact us (see ‘How to contact us’ below). You may also find it helpful to refer to the guidance from the UK’s Information Commissioner on your rights under the UK GDPR.

If you would like to exercise any of those rights, please complete a request form—available on our website at https://janamapp.co.uk/contact.html or email us at info@janamapp.co.uk

 

• provide enough information to identify yourself and any additional identity information we may reasonably request from you, and
• let us know which right(s) you want to exercise and the information to which your request relates

 

Keeping your information secure

We have appropriate security measures to prevent personal data from being accidentally lost, or used or accessed unlawfully. We limit access to your information to those who have a genuine business need to access it. We continually test our systems and our server and data centre providers are ISO 27001 certified, which means we follow top industry standards for information security.

We also have procedures in place to deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected data security breach where we are legally required to do so.

If you want detailed guidance from Get Safe Online on how to protect your information and other information and your computers and devices against fraud, identity theft, viruses and many other online problems, please visit www.getsafeonline.org. Get Safe Online is supported by HM Government and leading businesses.

 

International Transfer of Data and non-identifiable Information

JanamAppn servers are based in the United Kingdom. We may transfer your non-indentifiable information outside the UK (or, if you are in the EEA, outside of the EEA), so we can to provide the app and services to you; to support the operation of our business, where this is in our legitimate interests and we have concluded these are not overridden by your rights or where we are legally required to do so.

We will put legal protections in place to safeguard personal data transfers in compliance with data protection laws.

We may transfer your personal information outside the UK / EEA. The data or encrypted software data we process may be processed in a number of locations. The location the processing takes place depends on a variety of factors and may include locations outside the United Kingdom and the European Economic Area. No matter where your data is collected, processed or stored, the same levels of security and data protection are maintained at all times. By providing us with your Personal (but non-identifiable) Information, you consent to your data being processed in locations that may be outside of the United Kingdom and the European Economic Area.

 

Notification of Breaches

We will comply with laws applicable to us in respect of any data breach. We do not process or store any identifiable personal data, reducing the risk further in the unlikely event of a breach.

 

How to complain

Please contact us if you have any queries or concerns about our use of your personal data (see below ‘How to contact us’). We hope we will be able to resolve any issues you may have.

You also have the right to lodge a complaint with the Information Commissioner.

The Information Commissioner can be contacted using the details at https://ico.org.uk/make-a-complaint or telephone: 0303 123 1113.

 

Changes to this privacy policy

We may change this privacy policy from time to time. When we make significant changes we will take steps to inform you, for example via the app or by other means, such as email.

 

How to contact us

You can contact us[ and/or our Data Protection Officer] by post, email or telephone if you have any questions about this privacy policy or the information we hold about you, to exercise a right under data protection law or to make a complaint.

We will normally reply to a request of any kind within 60 days of receiving the inquiry in writing on the below email address.

Our contact details are shown below:

Our contact details	Our Data Protection Officer’s contact details
info@janamapp.co.uk	Professor Angie Doshani. info@janamapp.co.uk