Privacy policy

PRIVACY / TRANSPARENCY NOTICE If you are a Clinician or a Research Organisation, please visit our Professional Access Privacy Notice at https://sanno.health/privacy-page-professionals. SANNO AND YOUR INFORMATION Sanno takes your privacy very seriously. We are registered with the Information Commissioner as a Data Controller and our registration number can be found by searching at https://ico.org.uk/ESDWebPages/Search. If you have any questions or wish to make a request in relation to your information, please contact our data protection lead on ariadna@sanno.health Sanno Ltd collects, use, stores and shares information about you on the basis of your consent. All of your personal data is processed and hosted in the UK and there is no personal data transferred abroad. HOW DOES SANNO COLLECT MY INFORMATION? We will collect information about you in the following ways; • Directly - When you provide it to us during your use of the Sanno App • Indirectly - Collection of cookies and analytics about how you use the Sanno App and the website (See Cookies section below) - If you are participating in a research study, the research or academic organisation may share data they hold about you so we can contact you about the study The information we collect will be stored on computer and electronic systems. The information includes • Personal Data; - basic details about you such as first name, last name, email address • Sensitive Personal Data - Information about your health and specific characteristics including diagnosis, pregnancy status, BMI, gender at birth, symptoms and any free text notes that you enter HOW DOES SANNO LTD USE MY INFORMATION? Sanno Ltd will use your information in the following ways; • To create and maintain an account for you within the Sanno App including managing passwords • To personalise your experience within the Sanno App, for example aligning the content you see with your particular diagnosis • Provide you with the ability to book an appointment with a specialist clinician or to share your Sanno App data with your existing clinician • To allow you to record and track symptoms, food, activity, mood, bowel movements, medication and sleep • Connecting the Sanno App with your wearable devices • To present you with Research and Reward opportunities (if you have consented to participate when you registered) To undertake some of these activities, your information will be shared internally across our teams. We will work to ensure that only the right people have your information and that they are only given the information they need. WHO DOES SANNO LTD SHARE MY INFORMATION WITH? Sanno Ltd works hard to ensure that only the right people have your information and that they are only given the information they need. Sharing Partners • Clinicians - If you are working with a clinician already and use an access code that they give you, this means that the clinician will be able to see all the data that you enter into the Sanno App including any free text notes that you write - If you select a clinician through the Sanno App, you will be asked if you wish to share any data you enter into the Sanno App and you can select whether this includes free text notes that you write or not • Actively Participating in Research (only if you have consented) - When Sanno partners with a research or academic body for a specific study, you can consent to participate in the study when you access the Sanno App. - Once the organisation access your data, they become responsible for it so it is important that you take care to carefully read their consent materials and ensure that you are happy to proceed - The research organisations can then send you a questionnaire to complete - The Research / Academic Body User can access the portal and view all participating Sanno App Users including their patient profile, questionnaire responses, tracking results, they can also write notes and choose to share them with you • Use of Anonymised Data for Research and Development - Sanno will use anonymous data to help develop the App or produce research or clinical insights. The data used for this type of research will not identify you as an individual Sanno App User and so does not require specific consent. Sanno Ltd Uses other companies to help us deliver some of our services such as; Email / File Storage System: Google App Development and Storage: Amazon Web Services Website Hosting and Development: Webflow Personal data will never be made available to organisations not involved in developing or supporting the App unless you have consented or we have let you know and giving you a chance to object (aside from in the examples listed in the section below). We have contracts in place with our suppliers that prevent them from using it in any other way that how we tell them to. These contracts also require them to maintain good standards of security to ensure your confidentiality. WILL SANNO LTD SHARE WITHOUT ASKING ME? Sometimes we will be required by law to share your information and will not always be able to discuss this with you directly. Examples might be; • Sharing with the police or tax authorities for the detection or prevention of crime • Where it is in the wider public interest – to keep the public safe for example • To safeguard children or vulnerable adults • Because the court has told us we must share. WHAT ARE MY INFORMATION RIGHTS? Data protection law provides you with a number of rights that Sanno Ltd is committed to supporting you with; Right to Access You have the right to obtain: • Confirmation that your information is being used, stored or shared by Sanno • A copy of information held about you • If you only require a particular part of your record, tell us and this can reduce the time it takes to provide it • We will respond to your request within one month of receipt or will tell you when it might take longer • We are required to validate your identity including the identity of someone making a request on your behalf Right to Object or Withdraw Consent We collect, use, store and share your information because we are permitted to by law; on the basis of consent, you have a right to withdraw that consent at any time. Our Data Protection Officer will be happy to speak with you about any concerns you have. Right to Correction If information about you is incorrect, you are entitled to request that we correct it. There may be occasions, where we are required by law to maintain the original information – our Data Protection Officer will talk to you about this, and you may request that the information is not used during this time We will respond to your request within one month of receipt or will tell you when it might take longer. Right to Portability You can ask us to send your information to another organisation on your behalf if you wish. Complaints You also have the right to make complaints and request investigations into the way your information is used. Please contact our Data Protection Officer or visit the link below for more information. For more detailed information on your rights visit https://ico.org.uk/for-the-public/ DOES SANNO LTD USE PROFILING OR AUTOMATED DECISION MAKING? Sanno Ltd does not undertake automated decision making in relation to your information. If you have consented to actively participate in research, Sanno will undertake searches and find eligible App Users based on certain tags (i.e. Crohn’s). Sanno will then invite relevant App Users to participate in the study. Our Data Protection Officer will be happy to speak to you about this if you have concerns or objections. HOW DOES SANNO LTD PROTECT MY INFORMATION? Sanno Ltd are committed to ensuring the security and confidentiality of your information. There are a number of ways we do this; • Staff receive regular training about protecting and using personal data • Policies are in place for staff to follow and are regularly reviewed • We check that only the minimum amount of data is shared or accessed • We use controlled access to systems, this helps to ensure that the right people are accessing data – people with a ‘need to know’ • We use encrypted emails and storage which would make it difficult for someone to ‘intercept’ your information • We report and manage incidents to make sure we learn from them and improve • We put in place contracts that require providers and suppliers to protect your data as well HOW LONG DOES SANNO LTD STORE MY INFORMATION? The personal data within your Sanno account within the Sanno will remain regardless of whether you appear to be an “active” User. This is because you may use the Sanno App more at certain times and may not use it for some time. We want to make sure that you can return to the App and see your previous records for comparison. You may close your account at any time, thus withdrawing consent. We will remove all data that can identify you and will retain only anonymised data to allow us to continue developing the Sanno App and to support innovation.