Respect for the privacy of Personal Information about you is very important to us. We use and share Personal Information that you provide only in ways that we tell you about, and we secure Personal Information that you provide to prevent it from being used and shared for other purposes.
1 Collection of Personal Information and Non-Personal Information
How Personal Information is Collected in your Digital Health Wallet (“Tento Wallet”): You control whether Personal Information is collected from you. For example, Personal Information is collected from you with your prior consent if you choose to upload it to your Tento Wallet (please see description of Tento Wallet below) and share it with our site using the QR code functionality or if you include Personal Information in a question or inquiry to us via the “Contact Us” page of our website.
Kinds of Personal Information that are Collected: Different kinds of Personal Information may be collected about you through your use of the Site. The kinds of Personal Information which may be collected through the usage of your Tento Wallet, are as follows:
- Basic identifiers such as first name, last name, title, date of birth, contact information such as your email address and telephone number, and other identifiers that you may include within or upload to your own Site app profile (hereinafter, your Tento Wallet) or that you otherwise choose to make available through your use of the Site; Basic identifiers are kept in your Tento Wallet on a permanent basis and can be removed by uninstalling the application from your device. Any identifier shared by QR code is retained for a period no longer than ten (10) minutes, so as to be made available to the organisation that you selected to share your QR code with.
- Additional Profile information that you may choose to include in your Tento Wallet, such as your preferences, feedback and survey responses; and
- Sensitive Personal Information that you choose to include in your Tento Wallet, which may include information about race and ethnicity and health information, such as diagnostic test results and medical records.
How Non-Personal Information is Collected:
- When using your Tento Wallet, Non-Personal information is only shared with our operations team when contacting us via the “Contact Us” page of your application.
- When using or navigating the site, you control whether Non-Personal Information is collected from you. For example, when you use or navigate the Site, information about your browser type may be collected if you set your browser settings to enable collection of such information.
Kinds of Non-Personal Information that are Collected:
- Technical data shared by your Tento Wallet, include: OS version, device model, device operating system, system version, Tento Wallet application version.
- When using or navigating the site, technical data collected include: your internet protocol (IP) address, browser type and version, device type, time zone setting and location, browser plug-in types and versions, crash reports, operating system and platform and other technology on the devices you use to access the Site
2 Uses and Disclosures of Personal Information and Non-Personal Information; Purposes of Using and Disclosing Personal Information and Non-Personal Information
Uses and Disclosures of Personal Information; Purposes of Using and Disclosing Personal Information. You control uses and disclosures of Personal Information on the Site as follows:
- If you have a Tento Wallet, you decide how you wish to use Personal Information in the Tento Wallet utilizing its functions and capabilities. The purpose of your use of Personal Information in this way is so that you may utilize and take advantage of the Tento Wallet that we offer;
- You decide how Personal Information is disclosed and to whom it is disclosed. For example, if you contact us with a question, you may choose to disclose certain Personal Information about yourself to us so that we can identify and respond to you. You may disclose Personal Information in this way for the purpose of allowing us to communicate with you; and
- If you have a Tento Wallet, you choose with whom you share your Personal Information. As an example, you may choose to share Personal Information in your Tento Wallet with your employer or with a business you choose. You may share Personal Information in this way as part of utilizing and taking advantage of the Tento Wallet and its features.
In limited instances, we may use and disclose Personal Information as follows:
- Through your Tento Wallet
- If you contact us with a question or concern about the Site, we may use the Personal Information you chose to share with us for the purpose of communicating with you about your question or concern;
- We may use Personal Information we’ve collected on the Site if we’re required to do so by applicable law or regulation or to comply with a legal obligation to which we are subject. We may also disclose such Personal Information to those authorized to receive it, as required by applicable law;
- Through our site
- We may use Personal Information you provide to us, such as your email address or other basic identifiers, to send you our newsletters, updates about us or our services or marketing materials if you have opted in to receive such communications from us; and
- We may disclose Personal Information we’ve collected on the Site to third-party service providers that we engage. We disclose Personal Information to such third-party service providers so that they may assist us in providing, managing and operating our Site.
Uses of Non-Personal Information; Purposes of Using Non-Personal Information.
You also control uses of Non-Personal Information as follows:
- You may set and adjust browser, operating system and device settings to allow or disable use of technical data such as location information and cookies. If you allow use of this information, it will serve the purpose of tracking certain interactions you’ve had with our Site (see “Cookies” section below for more details).
In limited instances, we may use and disclose Non-Personal Information as follows:
- We may use Non-Personal Information, which may consist of technical data (as described above), for web analytics purposes. For example, we may use such technical data for analyzing our website traffic and other metrics for purposes of evaluating the performance of our website.
- We may disclose Non-Personal Information, which may consist of technical data (as described above), to third-party service providers that we engage to assist us with the web analytics functions noted above.
3 Processing of Information with your consent
When you browse our website or contact us with questions, you provide your consent for us to process information that may include Personal Information.
4 Revoking Your Consent
In situations where you have provided explicit consent for the processing of Personal Information, you may revoke your consent at any time by contacting us at firstname.lastname@example.org. However, please be aware that if you revoke your consent, you may not be able to use our website or our other Site features which depend on processing of Personal Information.
5 Data Minimization
6 Information Security
We use commercially reasonable administrative, technical, physical and organizational security measures to maintain the security and integrity of our Site and Personal Information and Non-Personal Information that is processed through the Site. We implement measures to protect against loss, misuse, or improper access to information through generally accepted industry standard technologies and procedures. For example, we use authentication, anonymization and encryption technology to protect Personal Information in a User’s Tento Wallet. Please note that there are inherent risks in transmission of information over the Internet, and we cannot guarantee that unauthorized access or use of information will never occur. Please also note that features of our Site, such as a Tento Wallet, are designed to be interoperable with and allow for secure exchange of information with various other systems, but we cannot guarantee such interoperability with all systems and make no representation or warranty that unauthorized access to or use of information will never occur in connection with such exchange of information.
Cookies are small text files that are placed on your computer’s hard drive by your web browser when you visit any website. They allow information gathered on one web page to be stored until it is needed for use on another, allowing a website to provide you with a personalised experience and the website owner with statistics about how you use the website so that it can be improved.
Some cookies may last for a defined period of time, such as one day or until you close your browser. Others last indefinitely or until you delete them from your web browser.
Your web browser should allow you to delete any cookies you choose. It also should allow you to prevent or limit their use.
- to track how you use our website;
- to record whether you have seen specific messages we display on our website;
- to keep you signed in to our website;
- to record your answers to surveys and questionnaires on our site while you complete them; and
- to record the conversation thread during a live chat with our support team.
8 Third-Party Content
Our Site may include links to third-party content, including without limitation, links to third-party websites. We do not endorse or recommend such third-party content and we are not responsible for the privacy practices of the operators or publishers of such content. Please be aware that when you access links to a third party’s content via our Site, you are bound by the privacy policies and practices of that third party. We urge you to be aware of and read the privacy policies governing your use of any third-party content.
9 Location of Information Processing
In instances where you process Personal Information from your local device, processing of this Personal Information occurs where you or your device are located. In other situations where you control the disclosure of your Personal Information, once you disclose such Personal Information to a recipient (such as a clinic or lab that you choose), it may be further processed by those recipients wherever they are located. In situations where we process Personal Information or Non-Personal Information, processing of such information may occur in the United Kingdom (UK) where our cloud-based servers are located or at the locations of our offices, offices of our affiliates or at processing locations of our third-party data management contractors.
Depending on how you use the Site, your use of the Site may involve transfer of your Personal Information across borders from the country in which you are located to other countries around the world. To the extent we process your Personal Information, we may also transfer such Personal Information internationally. Accordingly, with respect to an international data transfer, your Personal Information may be subject to different protections depending on the laws and regulations of the country to which your Personal Information is transferred. In all cases in which we control your Personal Information, we will seek to apply reasonable safeguards for the protection of such Personal Information that is transferred internationally.
10 Third-Party Service Providers
11 Access to your personal information
At any time, you may access Personal Information which you control on the Site. For example, if you maintain Personal Information in your Tento Wallet, you may access such Personal Information in the Tento Wallet at any time.
In the limited cases in which we control and maintain your Personal Information, you may contact us to request access to such Personal Information at: email@example.com. After receiving the request, we may take steps to verify your identity and once verified we will respond to your access request within a reasonable timeframe.
12 Deletion of your Personal Information
At any time, you may delete Personal Information which you control on the Site. For example, if you maintain Personal Information in your Tento Wallet, you may delete such Personal Information in the Tento Wallet at any time. Please be aware that certain parts of the Site, such as the Tento Wallet, may include functions that allow you to backup your Personal Information using your own operating system or device, and in case you have backed up your Personal Information in this way, the backup copy will remain even if you have deleted Personal Information on the Site. In the limited cases in which we control and maintain your Personal Information, you may contact us to request deletion of such Personal Information at: firstname.lastname@example.org. After receiving the request, we may take steps to verify your identity and once verified we will respond to your deletion request within a reasonable timeframe. Please be aware that if we delete Personal Information, it may limit your ability to fully utilize the Site and related service we can provide to you.
13 Use of Site by children
14 Retention of Personal Information
For individuals in the EU: Ian Sherrington has been appointed as our representative in the EU for data protection matters, pursuant to Article 27 of the EU’s General Data Protection Regulation. Ian Sherrington can be contacted in addition to or instead of us on matters related to the processing of Personal Information. You may contact Ian Sherrington at the following address: Catharina van Rennesstraat 280, 2551 GV Den Haag, Netherlands. You may also contact Ian Sherrington by phone at +31 621 861158 or by email at GDPR@tentohealth.com.
As a data subject, you have the right to request from us access to, rectification of, erasure of, portability of and/or restriction of processing of your Personal Information. You also have the right to object to further processing of your Personal Information. To exercise any of these rights, please contact us at email@example.com. We will respond to your request in accordance with applicable law.
In the event we process your Personal Information based on your consent, you may withdraw your consent at any time (provided, however, such withdrawal will not affect the lawfulness of processing of your Personal Information that occurred before our receipt of your withdrawal). To withdraw consent for processing of your Personal Information, please contact us at firstname.lastname@example.org.
We may transfer Personal Information from the EU and/or UK to other countries and jurisdictions around the world. Please be aware that the European Commission determined that only certain countries/jurisdictions provide an adequate legal framework for the protection of Personal Information. For more information on the countries/jurisdictions that the European Commission has determined provide an adequate legal framework for protection of Personal Information, please visit: https://ec.europa.eu/info/law/law-topic/data-protection/international-dimension-data-protection/adequacy-decisions_en. To the extent Personal Information is transferred from the EU or UK to countries/jurisdictions that have not been deemed by the European Commission to provide an adequate legal framework for the protection of Personal Information, such Personal Information may be at greater risk once it is transferred to such countries/jurisdictions due to the absence of this adequacy determination by the European Commission. Nonetheless, we commit to protect Personal Information under our control by applying reasonable safeguards to Personal Information transferred to such countries/jurisdictions.
If you have a concern with the handling of your Personal Information, you may lodge a complaint with the applicable data protection authority (also known as “Supervisory Authority”) in the country in which you reside. For a list of Supervisory Authorities and their contact information, please visit: https://edpb.europa.eu/about-edpb/board/members_en. If you are located in the UK, you may contact the Information Commissioner’s Office (ICO) (ICO website: https://ico.org.uk/). If you have a concern, you may also contact us at email@example.com.
16 Questions; Concerns
This policy was updated 10th April 2021.