BreatheSuite is committed to maintaining your privacy and confidentiality and will keep your information safe and secure. Only authorized individuals will be permitted to access your information and whenever possible we will remove information that could identify you. Information about you will be stored in a secure manner in compliance with the Personal Information Protection & Electronic Documents Act (PIPEDA) in order to protect your confidentiality.
Personal Information Collection & Use
We will collect and use the following information:
- Personal Information & Personal Health Information - BreatheSuite will collect information that you enter upon registration and when you use the app. For instance, the inhaler usage data is recorded and stored, as well as name, age, weight and height that are requested during registration. This information is used to optimize the effectiveness of the app for you. Unless otherwise indicated, below is a list of information that is collected from you when you first sign up and overtime when using the app:
- Registration and authentication - BreatheSuite will capture information that you enter upon registration and when you are authenticated, such as your telephone number and email address. We also use ‘tokens’ to authenticate app users to verify users and know when a user is logged in;
- Mobile device type (Apple, Android) - to ensure you get the correct device details and are able to sync the BreatheSuite application appropriately;
- Height & weight - so that we may analyze your medication usage appropriately and for analytics to optimize the device overtime;
- Year of birth - so that we may understand your age and whether it has an effect on your medication usage or symptom management;
- Location - Once the ‘Location Setting’ is turned on the BreatheSuite App will have access to your location. We collect and use this information in order to determine whether a users’ location affects their inhaler use. For example, we may assess ‘rescue inhaler usage’ in order to understand whether there are certain areas or locations that cause our users to have increased symptoms that require them to use their inhaler more than usual. Unless you have provided consent to us to collect your identifying location information, BreatheSuite will anonymize the location data so that you will not be identified and will only retain the information for as long as is deemed necessary.
- Journal information - information that you add into your journal, such as frequency & type of symptoms you experience, sleep quality, your activity levels, and other asthma-related information, such as when your inhaler is flowing at an optimal rate and whether your asthma is well controlled, moderately controlled or not under control.
- Usability, inhaler technique, IP address and browser data - information captured about how often and how well you use the device so we can potentially make recommendations to you or your provider(s), if permission has been granted to do so, on how to improve your inhaler use over time. As well, the Google Play Store and Apple App Store will provide Usage Data;
- Adherence and prescription data - such as information about how frequently you take your medication, your dose and prescription name/brand and whether you take it on a regular basis as your doctor prescribed - to help us make recommendations to you or your provider(s) on how to improve your inhaler use over time.
- Push & Email Notifications - Overtime, this Application may send push notifications to you. Users may opt-out of receiving push notifications by visiting their BreatheSuite app settings, or mobile device settings such as the notification settings for mobile phones, and then change settings for this Application so that they no longer receive notifications. Users must be aware that disabling push notifications may negatively affect the utility of this Application. Using Amazon Web Services simple email notification services, such as emails relating to the app and your usage, may also be sent to you.
- Contact Information for Marketing Purposes - With your express consent when you enter your information on our contact list on the BreatheSuite website, we may send you marketing or business notifications.
- Hosting, Infrastructure Monitoring & Error Tracking - Breathesuite will track errors, such as when the app crashes or a feature doesn’t work well. We use this data to ensure that we improve the app functionality over time. Notably, every effort is made to use only anonymized error data, however there is a risk that identifiable data could inadvertently be captured.
Data Retention & Storage of Personal (Health) Information
For legal purposes, we will retain your data for the duration of time that you use the app and up to five years after you are no longer using the app.
DATA SHARING & RETENTION
Data may be shared or disclosed by BreatheSuite in the future, particularly in cases where we are required to disclose this information by law. For example, if we receive a subpoena or court order. Once the retention period expires, personal information shall be deleted. Therefore, any right to access, correction and other requests regarding your information cannot be enforced after expiration of the retention period.
BreatheSuite may anonymize data so that it may never be traced back to you. In such cases, we may retain this data beyond the data retention period outlined above. As well, anonymized data may be used and shared for other purposes not outlined in this policy.
DATA PROCESSING & DATA DISCLOSURE
Individuals' data will be stored and processed at an Amazon Web Services (AWS) datacenter. The data will be stored within an encrypted database or file storage. The transfer of data between systems will also use an encrypted connection.
Based on your location, data will primarily be stored and processed within the same country that you reside. Therefore, Canadian users will be provisioned to have the mobile app store and data processed in a datacenter located in Quebec, Canada. For users based in the US, data will be primarily stored and processed in Virginia, USA. Depending on your location, data transfers in the future may involve transferring your Data to a country other than your own. Your information will be saved on Amazon Web Services servers, which may result with your personal information being stored outside of Newfoundland and Labrador and, in limited circumstances, outside Canada. As a result, your personal information may be accessible to law enforcement, courts and regulatory authorities in accordance with the laws of these domestic and foreign jurisdictions.
If changes occur to our data transfers, you will be notified and your consent will be obtained. You are entitled to learn about the legal basis of Data transfers to a country outside of Canada. You may also inquire with BreatheSuite’s privacy officer at firstname.lastname@example.org.
SALE OF YOUR PERSONAL INFORMATION
For our purposes, the word “sale” means any “selling, renting, releasing, disclosing, disseminating, making available, transferring or otherwise communicating orally, in writing, or by electronic means, a consumer's anonymous or de-identified data by the business to another business or a third party, for monetary or other valuable consideration”.
This means that, for example, a sale can happen if the company is procured by another firm.
YOUR RIGHT TO OPT OUT OF THE SALE OF PERSONAL INFORMATION
If BreatheSuite sells the company and subsequently the PI/PHI in its possession, you will be notified and will have the right to opt out of the sale of your personal information. This means that whenever you request us to stop selling your data, we will abide by your request. Such requests can be made freely, at any time, simply by following the instructions below.
If you’d like to know more, or exercise your right to opt out, you can contact us for further information at email@example.com.
VOLUNTARY USE OF APP AND YOUR RIGHT TO WITHDRAW
Your use of the app is completely voluntary. You may stop using the app and delete it at any time or for any reason, without penalty. If you wish to stop using the app, any data that has already been analyzed will be maintained by BreatheSuite subject to our aforementioned retention policy. This is due to legal requirements to maintain records. We will not use your information for new purposes after you withdraw.
You have the right to do the following:
- Withdraw your consent at any time - You have the right to withdraw consent where you have previously given consent to the processing of your Personal Information.
- Terminate your use of services as outlined in the Terms of Service Agreement.
- Access your information - You have the right to learn if your Personal Information is being processed by BreatheSuite, obtain disclosure regarding certain aspects of the processing and obtain a copy of the Data undergoing processing.
- Verify and seek to ensure your information is accurate and complete - You have the right to verify the accuracy of your Personal information and ask for it to be updated or corrected. In certain cases you can make edits to your own information directly in the app, such as updating your prescription information.
- Have your personal information deleted or otherwise removed - You have the right, under certain circumstances, to obtain the erasure of your Data from BreatheSuite.
- Lodge a complaint and/or challenge compliance - You have the right to bring a claim before us by contacting our company and/or our privacy officer.
HOW TO EXERCISE YOUR RIGHTS
- Step 1: Submit a request to us by contacting us at firstname.lastname@example.org. *Helpful Hint: For us to respond to your request, please provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative;
- Step 2: We will review your request and get back to you if we have further questions/comments. *Helpful Hint: Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond.; and
- Step 3: We will respond to your request within 10 business days.
BREATHESUITE PRIVACY CONTACT INFORMATION
Phone: (709) 800-6533
OFFICE OF THE PRIVACY COMMISSIONER OF CANADA
BreatheSuite is available to answer any questions or concerns you may have. However, you may also contact the Office of the Privacy Commissioner of Canada at any time. For more information visit: https://www.priv.gc.ca/en/contact-the-opc/contact-the-information-centre/
9:00 a.m. to 4:00 p.m. EST
Office of the Privacy Commissioner of Canada
30 Victoria Street
Version 1.0 - dated September 2020