Last update: 19 August 2022

Healthcare Companion Ltd – Privacy Policy

This Privacy Policy applies to the My Cancer Companion mobile application (the “App”). Please read this Privacy Policy carefully and contact us if you have any questions.

This Privacy Policy explains what personal data may be collected and processed about you when you download, register and use the App, and how we use that information. It includes a description of your data privacy rights.

The use of the App is optional, and if you do not want your personal data to be processed by us as described below, please do not download or register to use the App.

If you are using the App as part of a clinical study (a “Clinical Study”), our use of your personal data in connection with that study will be in accordance with the terms of the informed consent form you signed when agreeing to participate in the Clinical Study (the “Informed Consent Form”).

Data controller

Healthcare Companion Ltd with registered company number 13188770 and registered address at Finsgate, 5-7 Cranwood Street, London, England, EC1V 9EE (“Healthcare Companion Ltd”, “we”, “us” or “our”), will collect and process your personal data as controller.

Personal data

We may collect personally identifiable information, meaning any information relating to an identified or identifiable person, such as names, addresses, telephone numbers, email addresses only when voluntarily provided by you when you register or otherwise voluntarily submit information to us.

We also collect the following types of health information when you submit it through the App:

• information about cancer type and stage

• information about medication and treatments;

• information about your physical and mental wellbeing;

• information about appointments and healthcare providers.

How we will use your personal data and our legal basis for processing

We may use your personal data for the following purposes and our legal grounds for processing your personal data are that the processing is:

• Necessary for the performance of a contract between you and us, to provide you the App (for example, to allow you to register an account, use feature of the App and to provide technical support).

• Necessary for our legitimate business interests, including for product development and improvement, testing and security, quality assurance and administrative purposes.

• Necessary for scientific research purposes, to better understand treatment and outcomes for cancer.

• Necessary for compliance with our legal obligations or for the establishment, exercise or defence of legal claims or proceedings.

• With your consent, as provided through the Informed Consent Form for the purposes set out in the Informed Consent Form for each individual Study.

If you do not provide certain information to us, we may, in some circumstances, be unable to comply with our obligations or provide aspects of the App’s functionality to you.

Withdrawal of consent

If you have provided your consent for us to use your personal data as set out in an Informed Consent Form, you have the right to withdraw that consent as set out in the Informed Consent Form.

Data sharing

We may share your personal data with the following third parties:

• If you are participating in a Clinical Study, and as further set out in the Study Informed Consent Form, the information that you provide or make available through the App may be shared with healthcare professionals responsible for the Clinical Study, who may in turn share the information with other relevant individuals involved with your participation in the Clinical Study.

• With our affiliated companies and research partners to understand treatment and outcomes for cancer, product development and improvement, and training purposes in each case where permitted by law.

Where permitted by law, we may also share your personal data with the following third parties:

• We use third party contractors that perform services for, or with, Healthcare Companion Ltd and process personal data according to our instructions in relation to the App, for instance to understand treatment and outcomes of cancer, product development and improvement, and training purposes. These third party contractors are restricted from using the data for any purpose other than to provide services for, or with, Healthcare Companion Ltd.

• If we make a sale or transfer of assets or are otherwise involved in a merger or business/ asset transfer or company restructuring, we may transfer your personal data to one or more third parties as part of that transaction or restructuring.

• To the extent that we believe it is required by law or necessary to respond to valid legal process, we may also share your personal data with local or foreign government authorities, regulators, law enforcement authorities, courts and tribunals. For example, we may be required by pharmacovigilance laws to report adverse events to regulators.

• We also will share your personal data where we believe that it is necessary for the purpose of our own, or a third party’s legitimate interest relating to law enforcement, litigation, criminal investigation, protecting the safety of any person, or to prevent death or imminent bodily harm, provided that we deem that that interest is not overridden by your interests or fundamental rights and freedoms requiring the protection of your personal data.

Data location

Depending on your location, the App is hosted on servers based in locations including the UK, European Economic Area and United States. The information you provide may be accessible or transferred to our affiliates, vendors or suppliers in other countries, including countries outside the European Economic Area (“EEA”). The level of legal protection for personal data is not the same in all countries and may not provide the same level of protection as the data protection laws in the UK, EEA or of the country in which you live. In case of such a transfer, Healthcare Companion Ltd will take reasonable efforts and security measures in an effort to keep your information secure, and we implement measures such as Standard Contractual Clauses approved by the European Commission or the International Data Transfer Agreement approved by UK Parliament to ensure that any transferred personal data, remains protected and secure. You may contact us using the details set out in the “Information regarding your rights” section below if you have any questions about the methods we use to safeguard any personal data transferred outside of the UK and EEA.

Security of personal data

We take reasonable steps to protect your personal data from loss, misuse, unauthorised access, disclosure, alteration or destruction by using security precautions that provide for industry standard protection. However, no data transmission over the Internet can be guaranteed to be completely secure. As a result, to the extent permitted under applicable law, we make no warranty, express or implied, concerning the security or integrity of any personal data.

Certain features of the App may allow for you to post content to or chat or otherwise interact with, other users of the App. When using those features, please ensure that you do not submit any personal data that you do not want to be seen, collected or used by other users.

Retention and erasure of personal data

You may request deletion of your data by clicking “Request to delete account” option on your profile page, or contacting us using the details set out in the “Information regarding your rights” section below.

We will retain your information only for the period necessary to fulfil the purposes outlined in this Privacy Policy, or the period to which you have consented (including in the Informed Consent Form), unless a longer retention period is required by law. We may also delete your information where it is not required by us.

We may retain your personal data for research purposes to better understand treatment and outcomes for cancer, product development and improvement, and training purposes, we may retain your personal data for as long as is necessary for such purposes, which may be indefinitely. We may also anonymise your personal data (so that it can no longer be associated with you) for research to understand treatment and outcomes for cancer, product development and improvement, and training purposes, and that anonymised data may also be held indefinitely.

Information regarding your rights

Subject to applicable law, you may have the right to access your personal data, to have it rectified, erased or transferred to other organisations at your request. You also have the right to object or to restrict some processing.

If you have any questions, requests or complaints about how we process your personal data, simply write to our Data Protection Officer using the email address: support@mycancercompanion.com You can also write to us at the following address:

Finsgate, 5-7 Cranwood Street, London, England, EC1V 9EE.

If you live in the UK or EU and have any comments or complaints regarding the way your personal data is being handled, you have the right to contact the supervisory authority in the country where you live, to lodge a complaint.

Updates to this Privacy Policy

We may update this Privacy Policy from time to time. If we make a significant change to this Privacy Policy (meaning any change that significantly affects your rights), we will notify you by email or publish a temporary notice on the website and/or a pop-up in the App.