This mobile application and portal (“App’’) are operated by Imperial College London Diabetes Centre (“ICLDC”). For the purposes of this Privacy Policy, information (“Information”) is defined as data captured by ICLDC and held within your electronic medical record including personal and clinical data, statistical information, and other information collected via the App.

Overview

This Privacy Policy applies to your use of the App and any of the services accessible through it once you have downloaded the App onto your device(s). By downloading and registering to use this App, you are consenting to the processing of your personal data by ICLDC as described in this Privacy Policy. This includes the uploading of your health related data in connection with your diabetes care management through this App. Please do not download or use this App if you do not wish for your personal or health related data to be uploaded to this App.

ICLDC is aware that your privacy and the security of your personal data is an important concern and we therefore take the protection of your personal data very seriously. This policy sets out the basis on which any personal data you provide to us or that we collect from you will be processed and to inform you about our security measures (“Privacy Policy” or “Policy”).

This Policy discloses our information gathering and sharing practices. Your use of the App is governed by this Policy, and by using or accessing the App, you agree to be bound by its terms. Additional terms and conditions, if any, regarding the collection and use of your information may also be provided to you before you sign up for a particular program, activity or service.

How we collect Information about you

Statistical information relating to the use of the App and the portal, including but not limited to

• MAC address
• IP address
• Type of device
• Location of the device
• Operating system and version

Personal and medical information captured by direct input into the App

How we store your Information

The ICLDC App data is stored in a secure data facility, designed to protect against unauthorised access, use, or disclosure of the Information contained within it. Our stringent physical and electronic security measures are regularly reviewed to ensure compliance with our policies and to manage and enhance our capabilities.

ICLDC implements appropriate administrative, technical and physical safeguards reasonably required to protect the confidentiality, integrity and availability of the personal data processed by ICLDC. We will take all steps reasonably necessary to ensure your personal data is treated securely and in accordance with this Privacy Policy.

How we use your Information

We do not rent, sell or share personal information about you with other people or non-affiliated companies, except when we have your permission, where disclosure is required by law or under the following circumstances:

Your Information is used:

To avoid COVID-19, you should:

• As part of your treatment, including diagnoses and investigations
• To better manage your treatment plan and continuity of care
• For reporting and statistical analysis purposes
• To communicate with you and other relevant parties through phone, email, SMS, and/or App notifications
• For research
• For insurance and billing purposes
• For quality and training purposes
• For marketing purposes by us, to provide you with information on our services that we feel may be of interest to you.

Your Information is shared with:

• Other healthcare providers, including Mubadala affiliated companies
• Authorized third parties including but not limited to research institutes, patient satisfaction contractors, and ICLDC service providers
• Payers
• Regulatory entities
• Auditors

ICLDC may aggregate, anonymise or de-identify Information before use or sharing as appropriate to the need and in accordance with relevant confidentiality policies.

How to update your personal information

Because it is your account, you may verify the accuracy of and update your personal information by contacting ICLDC.

You are responsible for sharing your updated personal information with your trusted family members and friends, or with other individuals to whom you have provided your consent during the registration process, allowing them visibility of my medical data on their mobile device(s).

We do advise you to review the privacy statements and policies with whomever you share your information with so that you better understand how your personal health information is being viewed and managed.

Cookies

The App collects small bits of information from your device in order to track information, such as data about how you use the App and information about problems that might occur. This analytics data may be transmitted to allow us to optimize and simplify the App’s use. You can block cookies by activating the setting on your mobile browser that allows you to refuse the setting of all or some cookies. If you use your browser settings to block all cookies (including essential cookies), you may not be able to use either all or parts of the App. You can opt-out from use of cookies and similar technologies by contacting us at ICLDC.

How we protect children’s privacy

In light of the importance of protecting children’s privacy, we do not collect or process any information relating to an individual whom we know to be a minor (i.e. under 18 years old) without the prior, verifiable consent of his or her legal representative or guardian. Such legal representative or guardian has the right, upon request, to view the information provided by the child and/or to require that it be deleted. If you are a legal representative or guardian with any concerns regarding your child’s personal data, please contact ICLDC.

Notification of Changes to this Privacy Policy

From time to time, ICLDC may change its practices concerning how we use or disclose protected health information, or how we will implement patient rights concerning their Information. ICLDC reserves the right to change the terms of this notice and make the new notice provisions effective for all protected Information maintained by ICLDC. ICLDC will follow the terms and conditions of the notice that is currently in effect.

How to contact us

You can contact us about this Policy via email or telephone as follows:

PatientServices@icldc.ae

Tel: +971 2 4040 800

Tel: +971 3 7464 800