Data Privacy Framework (DPF)

AWS Partnership

Privacy Policy Statement

Welcome to the SUMMA Mobile application for iOS and Android Devices (the “Mobile App”).

The Mobile App is only available for sponsored clinical research initiatives. If you have downloaded the Mobile App from an online store, you acknowledge and agree that the Mobile App, any associated software, and any associated documentation (collectively, the “Digital Products and Software”) are operated by or on behalf of Precision Digital Health, Inc. (“PDH,” “we” or “us”).  Our services are used to support global research and therefore your privacy is important to us. We have established this PDH privacy policy (the “Privacy Policy”) to outline and identify the types of information we collect from you as a user of the Digital Products and Software.  This includes data usage, data sharing parties or 3rd parties accessing the data.  Our Privacy Policy is intended to outline the steps that PDH implements to protect and secure your personal data in accordance with the U.S. federal and state laws and other jurisdictions globally.

By using the software, you are acknowledging and agreeing to this Privacy Policy.  Please read the policy carefully and if you have any questions please contact: [email protected].

The use of PDH’s Digital Products and Software is voluntary to any user. By using and continued use of the software you have agreed to the privacy policy as well as the Terms of Use license agreement (“ToU”).  At any time, you do not agree with any of the terms please do not download or access the software for use.

If you are a participant in a study (or are otherwise using the Mobile App through or under the supervision of a doctor, clinic, or research institution), this PDH Privacy Policy Statement may not apply to you. Please consult with the supervising doctor, clinic, or research institution sponsoring the initiative to learn the privacy policy and practices that are applicable to your use of the Mobile App. We at PDH may not be informed and are not responsible for the privacy policies and practices of doctors, clinics, or research institutions that sponsor and administrate clinical research using the Mobile App.

Informed Consent

As a user of the system, you will have either digitally consented or signed a patient informed consent document to participate in sponsored clinical research.  Informed consent documents may contain additional restrictions that regulate the use and collection of data gathered on the Mobile App beyond the Terms of Use and Privacy Policy. The informed consent document applies only to applications containing the informed consent document and will not apply to other aspects of PDH’s Digital Software and Services without the informed consent document.

Protecting Personal/Protected Health Data Information

  1. Personal User Information

PDH may learn or acquire certain personal information about you required for the Mobile App Use, for example your full name or email address (“Personal Information”), if you voluntarily provide this Personal Information to us via the Software. We will not collect, store, analyze, disclose, or otherwise use this Personal Information except as necessary to: process data you have sent us; respond to your queries or requests; provide you with technical support or updates; act in a manner consistent with an informed consent document you signed related to clinical research or enforce the terms of this Privacy Policy, the Agreement, and any other policies or legal requirements governing the use of the PDH Mobile App. In submitting this Personal Information to us, you consent to our use of it for restricted use.

  1. Protected Health Information

Information collected by the Mobile App will be stored on the mobile device securely and transmitted to PDH securely.  This information will only be transmitted to us based on an active consent by you the user. If consent has been revoked by you, the user the data will cease to be collected.  Any information that may be considered protected health information (“PHI”) as that term is defined in the United States by the HIPAA Privacy Rule (see 45 CFR Part 160 and Subparts A and E of Part 164), and by similar jurisdictions of other countries. By consenting to transmit any such data to us, PDH will de-identify any identifying information from any personal information (the “De-Identifying”), so it no longer contains identifying or potential identifying information to a specific person.

  1. Legal Disclosure of Personal Information

Under certain circumstance where required by legal authority, PDH, may share your Personal Health Information and/or PHI obtained in a controlled, secure process if required to do so based on: (a) Legal or regulatory requirement to comply with a legal process served (b) protect or defend our legal rights; or, (c) prevent potential harm to the physical safety of any person using the Mobile App in a clinical research setting.

Use of Cookies

PDH Mobile App policy will only use cookies for application functionality for the intended use of the Mobile App.  The information will not be shared or used in any way outside of the scope of clinical research.  Your information will not be shared, transferred, or sold to any other 3rd party.  PDH software products will only use cookies to anonymously save system preferences for users on the same browser for a given computer.   At any time, a user has the right to reject the Software’s cookies and still use the Software. However, the user experience may be impacted.

Children

The Software is directed toward adults. If you are under the age of 18, you must obtain consent from a legal guardian to use the Mobile App software. PDH policy is not to collect any information knowingly from any user less than 18 years of age without the consent of a legal guardian.  If any individual has a concern that data may have been collected for a user less than 18 years of age without proper consent, please contact PDH at [email protected]. We will document an incident and remove any information collected from our systems.

Security

Any data that is collected and transferred to PDH should be kept secure from any abuses. All data transmitted through the Mobile App is transmitted in accordance with global industry standards for transmission security and is in compliance with data protection laws of the United States and other nations.

Please be aware that the transmission of information is at your own risk. We cannot guarantee the security of any transmission of information via the software. PDH will use reasonable efforts to secure the information transmitted to us, using the best industry practices and processes. PDH refutes any responsibility for breaches of privacy of information being transmitted to PDH while in transmission.

Governing Law

The Software is controlled and operated by PDH. By choosing to use the Software or otherwise provide information to PDH, you agree that any dispute over privacy or the terms contained in this Privacy Statement will be governed by the laws of the State of California. If you are accessing the Software from any location with regulations or laws governing personal data collection, use or disclosure that differ from United States laws or regulations, please note that through your continued use of the Software, which is governed by the laws of the State of California and the United States of America and this Privacy Statement, you are transferring personal information to the United States of America and you consent to that transfer and to the collection and processing of such information in the United States.

Privacy Policy Updates

Updates

PDH reserves the right to modify the Privacy Policy terms.  The Privacy Policy will be available on PDH’s website and/or as part of the Mobile App.

PDH agrees that changes will be limited to PDH may periodically change or modify the terms of this Privacy Statement; provided, however, that no such change or modification shall be in contravention of any right to privacy you have in any protected health information under the federal or state law of the United States or other national law. All such changes or modifications to this Privacy Statement will be posted on this web site and accessible via your internet connected, browser enabled iPad or iPhone device (the “iOS Product”). Accordingly, please check this web site from time to time for the most current version of our Privacy Statement. Your continued use of the Software after we have posted a change or modification to the Privacy Statement will constitute your acceptance of such changes or modifications.

Additional Information

If you have questions about this Privacy Statement or the Mobile App, please contact us at [email protected].

Privacy Settings
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