PRIVACY NOTICE

What is the purpose of this notice?

uMotif Limited and its affiliates, subsidiaries and related entities (“uMotif”, “We”, “Us”, “Our”) is committed to protecting the privacy and security of the personal information we collect about end customers and users of our services (“You/Your”).  We are also committed to processing personal information in a transparent manner.

The purpose of this privacy notice is to explain what personal data we collect about you and how we use it.

Please read this privacy notice carefully as it provides important information about how we handle your personal information and your rights.  If you have any questions about any aspect of this privacy notice you can contact us, including by phone, email, and post.

Postal address:

uMotif Limited
12 New Fetter Lane
London
EC4A 1JP
United Kingdom

Email addresses:

For general enquiries – contact@umotif.com

You can contact our Data Protection Officer in relation to the UK General Data Protection Regulation (UK GDPR) at dpo@umotif.com, or via our postal address.  Please mark the envelope ‘Data Protection Officer’.

We have appointed IT Governance Europe Limited to act as our EU representative.  If you wish to exercise your rights under the EU General Data Protection Regulation (EU GDPR), or have any queries in relation to your rights or general privacy matters, please email our Representative at eurep@itgovernance.eu.  Please ensure to include our company name (uMotif Limited) in any correspondence you send to our Representative.

We design, develop, operate and maintain software applications (the “App(s)”) to help people track their data.  Your data may be used as part of a research programme, (which could be a clinical trial, a research study, or other type of research project).

Where we run a research programme on behalf of the Sponsor (or their authorised delegate) using our Apps, and you sign up to that research programme, we will collect and process data as instructed by the Sponsor in a contract.

Our Apps, Sites and Services may contain links to and from the online properties of our customers, partner networks, advertisers and affiliates or other third parties.  If you follow a link to any of these online properties, please note that these online properties have their own privacy notices and that we cannot and do not accept any responsibility or liability for these notices.  Please check these notices carefully before you submit any personal data to these websites.  This notice describes how uMotif will make use of your data in relation to:

• our Apps once you have downloaded a copy of the App onto your mobile telephone or handheld device (“Device”);
• any of the services accessible through the Apps (our “Services”); and
• any of our websites including without limitations the uMotif website located at: umotif.com and all subdomains and paths (our “Sites”).

It also describes your data protection rights, as described in the “What rights do I have?” section.

We also work with partners to create branded Apps using our technology, which they independently make available to their customers (who may be for example, health professionals, research institutions and pharmaceutical companies).  

Where our partners run a research programme that independently uses our apps then you should consult the partners Privacy Notice for details relating to how they process your personal information.

What personal information do we collect?

We collect and process personal data about you when you interact with us and our Apps, Services and websites.  We may collect and process the following data about you:

• Information that you provide by filling in forms or surveys on our Site or Apps. This includes information you provide when you register on our Sites or Apps and open an account, post material or request further services. We may also ask you for information when you report a problem with our Sites, Apps or Services.
• Information relating to the research study you are participating in. The data we collect will vary depending on the nature and requirements of the specific research programme you are signing up to.  For this reason it is not possible to provide an exhaustive list, but some common examples of the data we might collect from participants may include the following.  The specific information to be collected will be provided on behalf of the Sponsor as you join the research programme (“Customer Data”):
  • Contact details such as name and email to facilitate registration onto the research programme
  • Age range
  • Gender
  • Ethnicity
  • Sexual Orientation
  • Health related information

Customer data belongs to the Sponsor and as such uMotif Limited will only process this data as defined in a formal contract between the interested parties.

• If you contact us, we may keep a record of that correspondence.
• When you visit our Sites or Apps or interact with our Services, we (and our other service providers) may use a variety of technologies that automatically or passively collect information about how our Services are accessed and used (“Usage Data”, “Resultant Data”). Usage/Resultant Data may include:
  • the type of mobile device you use (e.g are you using an Apple or a Samsung Device);
  • a unique device identifier (for example, your Device's IMEI number, the MAC address of the Device's wireless network interface or the mobile phone number used by the Device);
  • mobile network information (e.g are you on the 3 network or the Vodafone network?);
  • your mobile operating system (e.g. are you using an iphone or an Android?);
  • your IP address and HTTP referrer information (eg the page served, the time, referring URLs);
  • the type of mobile browser you use (e.g. are you using the Chrome or Safari browser?);
  • time zone setting (e.g. GMT, EST?);

Usage Data helps us understand our users better and tailor content to their needs and interest.  Usage Data is statistical data about our users' browsing actions and patterns, and does not identify any individual.  Please rest assured that we will treat Usage Data as personal data if we combine it with you as a specific and identifiable person.

What information do we receive from third parties?

Sometimes, we may receive information about you from third parties.  In particular, we may receive your name or email address from a healthcare professional, a hospital or care site, a study researcher or a project sponsor to invite you to use the uMotif services.  Any information received from third parties would be processed in the same manner as any data you enter into the uMotif services.

How do we use information collected by uMotif or received from 3rd parties, and what is the lawful basis for this use?

Where the UK and European data protection laws apply and where uMotif is the data controller, our laweful basis for collecting and using the personal information described in this privacy notice will depend on the type of personal information concerned and the specific context in which we collect or use it.  We process this personal data for the following purposes:

• Where you give us consent:
  • we place cookies and use similar technologies in accordance with our Cookies Policy (below) and the information provided to you when those technologies are used]
  • on other occasions where we ask you for consent, we will use the data for the purpose which we explain at that time
• To fulfil a contract, or take steps linked to a contract: this is relevant where you agree to participate in a research programme. This includes:
  • Creating a new account
  • sharing your data entered into our Apps with professional authorised users;
  • communicating with you about the research programme you have signed up to;
  • providing customer services and arranging the delivery or other provision of products, information or services related to the research programme you have signed up to;
• As required by uMotif to conduct our business and pursue our legitimate interests, in particular:
  • we will use your information to provide you with relevant information, products and/or services which you may request or which we may decide would fit your needs. For example, we may suggest ways in which you can better participate in a research programme;
  • we monitor use of our websites and online services, and use your information to help us monitor, improve and protect our products, content, services and websites, both online and offline and ensure that content from our Sites and Apps is presented in the most effective manner for you and for your computer;
  • we use information you provide to personalise our website, products or services for you and notify you about changes to our Sites, Apps or Services;
  • we may provide aggregate Resultant Data which does not identify you specifically with third parties , where such a third party is an integral part of a research programme as selected by a Sponsor. We may combine your Usage Data with those of other users of our products and services and share or provide this trend information in aggregated and anonymised form with third parties. For example, we may use your Usage Data as part of an aggregated number to assist a university, academic institution or a hospital with their medical research;
  • we may also use Resultant Data collected from you and combine it with information provided by our other users of our products and services to help us improve the design and delivery of our software tools, increasing the effectiveness for all users. Data will be analysed in an anonymous format by company employees and contractors to improve our products;
  • we monitor customer accounts to prevent, investigate and/or report fraud, terrorism, misrepresentation, security incidents or crime, in accordance with applicable law;
  • we use information you provide to investigate any complaints received from you or from others, about our website or our products or services;
  • we will use data in connection with legal claims, compliance, regulatory and investigative purposes as necessary (including disclosure of such information in connection with legal process or litigation); and
  • we use data of some individuals to invite them to take part in research studies;
• For purposes which are required by law:
  • where we need parental consent to provide online services to children (age determined by the territory of use laws). However, most of our websites are not designed for children.
  • In response to requests by government or law enforcement authorities conducting an investigation.

Where uMotif is acting as the data processor the lawful bases stated in this privacy notice may be modified by the instructions of the data controller, in which case such updates will be provided to you in a research programme specific just-in-time notice, issued at the point you join that programme.

Withdrawing consent or otherwise objecting to direct marketing

Wherever we rely on your consent, you will always be able to withdraw that consent, although we may have other legal grounds for processing your data for other purposes, such as those set out above.  In some cases, we are able to send you direct marketing without your consent, where we rely on our legitimate interests, when we do we will tell you what our legitimate interest is.

How we store your data and how long will you retain my data?

Our services are provided to research programmes globally.  User data is stored securely in a geographical location in the territory where you take part in a research programme.  Our current hosting service providers are located in the EU, USA, and China.

Where we process data due to you participating in a research programme on behalf of a Sponsor, we will store the data for as long as required by the specific research programme protocol or plan.

Where we process personal data for marketing purposes or with your consent, we process the data until you ask us to stop and for a short period after this (to allow us to implement your requests).  We also keep a record of the fact that you have asked us not to send you direct marketing or to process your data indefinitely so that we can respect your request in future.

Where we process personal data in connection with performing a contract, a project or research study, we keep the data for 6 years from your last interaction with us.

If you want to stop using your uMotif account, you can either deactivate or delete it.  Deactivating your account puts your account on hold but we do not delete any of your information unless required by the instructions of a research programme sponsor as defined in the contract with that sponsor.  Should you wish request specific actions relating to your data see the “What rights do I have?” section.

Who will we share this data with, where and when?

Our Apps and Services are designed to help you track your data, usually as part of a research project or study, or with a medical, health or other professional, who may be our partner.  Access to the Apps and Services may therefore be made available to you via one of our partners.

In registering to use the Apps and Services, you will have used a unique registration code.  This unique registration code links your uMotif account to one or more of our online properties or to online properties of our partners.  For example, your uMotif account may be linked to a specific database for a research programme or for a particular hospital or a doctor’s surgery.  Your data may be viewable by professional users of the online properties your account is linked to, which will be based on the access rights defined in a particular research programme protocol or plan (researchers, site managers, doctors, nurses, practice managers, dieticians etc.).  Your data will not be viewable by other patient users unless you elect otherwise.

It may also be possible for your clinicians or health professionals to add data to your account (for example, a diary note, or a new task) as well as view any data you have entered.  These actions will be controlled by the access rights defined in a particular research programme protocol or plan.  If you do not want your data to be viewed by anyone else, please email contact@uMotif.com - however you should be aware that this may affect how you and your clinicians and / or researchers use the Service, and approval to take the requested action will need to be sought from the Controller.

If you have access to the Apps and Services via a uMotif partner and that partner terminates its contractual relationship with uMotif, you may no longer have access to the Apps and Services via that partner.  Data uploaded whilst using the Apps and Services via the Partner may also no longer be accessible.  If you would like further information about whether you will have continued access to the Apps and Services following termination of our contractual relationship with the relevant partner, please contact contact@uMotif.com.

Personal data may be shared with government authorities and/or law enforcement officials if required for the purposes above, if mandated by law or if required for the legal protection of our legitimate interests in compliance with applicable laws.

Personal data will also be shared with third party service providers, who will process it on behalf of uMotif for the purposes identified above.  Such third parties include providers of website hosting, maintenance, call centre operations (if this is part of a specific research programme in which you are participating).

In the event that the business is sold or integrated with another business, your details will be disclosed to our advisers and any prospective purchaser’s adviser and will be passed to the new owners of the business.

Where information is transferred outside the UK, and where this is to a stakeholder or vendor in a country that is not subject to a UK adequacy regulation, data is adequately protected by an International Data Transfer Agreement (IDTA) or International Data Transfer Addendum to the new European Commission SCCs (Addendum), or a vendors Binding Corporate Rules.

Where information is transferred outside of the EEA, and where this is to a stakeholder or vendor in a country that is not subject to an EU adequacy decision by the EU Commission, data is adequately protected by EU Commission approved standard contractual clauses, or a vendor's Binding Corporate Rules.  

What rights do I have?

Your right of access

You have the right to ask us for a copy of your personal data.  There are some exemptions, which means you may not always receive all the information we process.

Your right to rectification

You have the right to ask us to rectify information you think is inaccurate.  You also have the right to ask us to complete information you think is incomplete.

Your right to erasure

You have a right to ask us to erase your personal information in certain circumstances.

Your right to restriction of processing

You have the right to ask us to restrict the processing of your information in certain circumstances.

Your right to object to processing

You have the right to object to processing if we are able to process your information because the process is in our legitimate interest or where we don’t have to process the data to meet a contractual or other legal requirement, or where we are using the data for direct marketing.

Your right to data portability

This only applies to information you have given us. You have the right to ask that we transfer the information you gave us from one organisation to another, or give it to you.  The right only applies if we are processing information based on your consent or under, or in talks about entering into a contract and the processing is automated.

These rights may be limited, for example if fulfilling your request would reveal personal data about another person, or if you ask us to delete information which we are required by law to keep or have compelling legitimate interests in keeping.

To exercise any of these rights, you can get in touch with us using the details set out at the start of this privacy notice.  If you have unresolved concerns, you have the right to complain to the UK or an EU data protection authority where you live, work or where you believe a breach may have occurred, see “How do I complain?”.

For registration into our Apps and Services the provision of information is required: if relevant data is not provided, then we will not be able to create a new account, register you into the research programme you are joining, or securely log you into an existing account.  All other provision of your information is optional based on the requirements of the research programme details provided by the Sponsor.  However, if you do not provide your information your experience in using our Apps and Services may be impaired and you may not receive the full benefit of using our Services with your healthcare professional or research team.

How do I complain?

If you have any concerns about our use of your personal information, you can make a complaint to us using any of the methods described at the start  of this privacy notice.

You can also complain to the ICO if you are unhappy with how we have used your data.

The ICO’s address:

Information Commissioner’s Office
Wycliffe House
Water Lane
Wilmslow
Cheshire
SK9 5AF

Helpline number: 0303 123 1113

ICO website: https://www.ico.org.uk

COOKIE POLICY

Introduction

This cookie notice is for users of the uMotif.com website.

It tells you what cookies are for and how uMotif use them.

Related links:

• Terms and conditions

What are cookies?

When you visit a website such as uMotif.com, the website stores data in small files on your computer, known as cookies.

Cookies are used to store information about you and your preferences, so that you don’t have to keep re-entering them, and improve your browsing experience.

How do we use cookies?

There are several different types of cookie:

Strictly necessary cookies

These cookies are essential to enable you to move around the website and use its features, such as accessing secure areas of the website.  Without these cookies, the services you have asked for cannot be provided.

Examples of how we use strictly necessary cookies include:

Session Cookies: A session cookie is stored in temporary memory and is not retained after the browser is closed.  Session cookies do not collect information from the user's computer, and contain only a session identifier which is not personally identifiable.

Authentication Cookies: If you register and authenticate (log in) to any of uMotif's services you may receive authentication cookies these are used to securely maintain a logged-in state to one or more of our services and will usually expire after a period for your safety.  They contain no personally identifiable information.

Performance cookies

These cookies collect information about how visitors use a website, for instance, which pages visitors go to most often, and if they get error messages from web pages.  These cookies don’t collect information that identifies a visitor.  All information these cookies collect is aggregated and therefore anonymous. It is only used to improve how a website works.

Examples of how we use functionality cookies include:

Preference Cookies

We may store non-personally identifiable preferences such as your preferred language choice so that we can display content in the correct language to you when you use our services.

Privacy

The information stored in cookies is not used to identify you personally and uMotif does not use cookies for any purpose other than those described here.

Third party cookies

Third party cookies are used by third-party applications which are deployed by uMotif.

uMotif use Google Analytics, a tool that helps website owners measure how users interact with website content. Google Analytics uses cookies to   remember what a user has done on previous pages/interactions with the website.  These cookies collect no personally identifying information and are used to:

• Distinguish unique users
• Remember the number and time of previous visits
• Determine the start and end of a session
• Remember traffic source information

How do I control cookies?

You can control cookie use in your browser settings.