Physitrack takes your privacy very seriously and treats all your personal data with great care. This document sets out Physitrack’s policy regarding privacy and security. It is recommended that you read this policy carefully. The capitalized words are defined in the Terms of Service.
1. Who is Physitrack?
Physitrack Ltd. is a company with limited liability established and existing under the laws of The United Kingdom, having its registered office at 65 Gresham Street, London EC2V 7NQ and active on the websites of Physitrack;
Physitrack has developed a platform used by healthcare providers to gather information from, and/or provide information to their patients. Physitrack is not a health care provider and does not screen Content posted by healthcare providers, nor does it select or screen specific exercise programs that are displayed to patients.
Physitrack as processor on behalf of healthcare providers
Physitrack will store and process your personal data on behalf of its customers, the healthcare providers. For this processing, the healthcare provider will act as the "data controller" within the meaning of the European Privacy Directive (1995/46) and the Data Protection Act 1998 and is responsible for the lawful processing of your personal data. Please refer to your healthcare provider for information on the way the healthcare provider will process your personal data. Whilst Physitrack takes the protection of personal data very seriously, Physitrack is not responsible for the compliance with applicable privacy laws by the healthcare provider.
Physitrack as controller
In certain circumstances Physitrack may also process your personal data for its own purposes, in which case Physitrack will be the “data controller” of your personal data and responsible for the lawful processing of this personal data. Physitrack is the controller for the processing of payments by healthcare providers, the processing of account information, the use of Intercom cookies as set out below (under 3) and the provision of aggregated information to authorised parties (with your consent).
2. What personal data does Physitrack collect and process?
In order to make use of the Service, it is necessary to create a personal Account. For this you are required to enter certain information about yourself. Your name, gender, e-mail address, phone number and country of residence are obligatory. For healthcare providers who register on behalf of an entity, information about that entity (name and contact details) are also required.
The information contained in your account is not visible to third parties. For patients, only the healthcare provider that has sent them an invitation to use the Service can see their Account information.
Use of the Service
By using the Service, the healthcare provider provides information about the exercise program of the patients and the patients provide information about their compliance with the exercise program and their experiences while doing the exercises. This information is private between the patient and the healthcare provider. Physitrack will store and process this information only on behalf of the healthcare provider. Physitrack will only use the patient information for its own purposes with the consent of the patient. After the patient has given his consent, Physitrack will anonymise the patient information and share it with authorised third parties.
If the patient is a minor, the parents or legal guardians of the patient will be asked to give their consent for the processing described above.
When using Physitrack, cookies are saved on your computer. Cookies are small pieces of information (in the form of text) that a server sends to your browser (such as Internet Explorer or Firefox) with the intention that the browser sends this information back to the server the next time a user makes use of the Service. Cookies cannot damage your computer or the files saved on it.
When you use the Service, first party cookies are saved on your computer. First party cookies are made by or for Physitrack and are stored on your computer by Physitrack and only Physitrack has access to these cookies. Such cookies are used by Physitrack, for example, to remember your login information.
In order to collect data on the usage of Physitrack’s website (the marketing website, not the platform used for access to the Service), Physitrack uses Google Analytics. Google Analytics stores a permanent cookie on your computer which is subsequently used to register your use of the website. This data is then analyzed by Google and the results are given to Physitrac. This enables Physitrack to get more insight in the way in which the website is used and, based on this information, to make adjustments to the website or the provided services.
You can configure your browser so that you do not receive any cookies the next time you use the Service. However, it is then possible that you will no longer be able to make full use of Physitrack.
4. For what purposes will Physitrack use personal data about you?
Physitrack may use your personal data for the following purposes:
- To allow the healthcare provider to use the Service, including the management of the home exercise programs for patients, the management of the patients’ compliance with the exercise program and the exchange of exercise program templates with other users of Physitrack.
- To allow the patient to use the Service, including the access to home exercise programs provided by the healthcare provider and monitoring the compliance and providing feedback to the healthcare provider.
- To process payments by healthcare providers.
- To communicate with you about the Service and/or other services of Physitrack;
- To configure Physitrack to your wishes and needs.
- For protection purposes and to generate anonymous statistical data.
Physitrack will only provide medical information to third parties if the healthcare provider has given its consent for the specific third party involved (for instance, an insurance company) and if such information is aggregated to make sure that the patient cannot be identified.
- if it is obliged to do so based on the Agreement with the healthcare provider;
- if it is obliged to do so on account of national or international laws, case law and/or regulations;
- if Physitrack considers it necessary to do so in defense of its own rights; or
- if you have given permission to do so.
Physitrack may post customer testimonials/comments/reviews on the Website, which may contain personal data of healthcare providers. Physitrack shall obtain the healthcare provider’s consent via email prior to posting the testimonial.
Physitrack uses third-party analytics services to help understand the usage of the Service by healthcare providers. No patient information is shared through these services.
In particular, we provide a limited amount of the personal data of the healthcare provider (such as your email address and sign-up date to Peaberry Software, Inc. (“Customer.io”) and utilize Customer.io to collect data for analytics purposes when you visit the Website or use the Service. Customer.io analyzes your use of our Website and/or Service and tracks our relationship so that Physitrack can improve its service to you. We may also use Customer.io as a medium for communications, either through email, or through messages within the Service.
Customer.io is a company that is based in the United States. Physitrack Limited and Customer.io have an EC Data Protection Agreement to protect the privacy of Physitrack's users.
Physitrack also uses sub-processors, as listed on https://support.physitrack.com/article/721-what-types-of-data-are-stored-by-physitrack to process your data. When personal data is processed by sub-processors, Physitrack has data processing agreements in place with these sub-processors.
5. How does Physitrack protect your personal data?
Physitrack takes appropriate technical and organizational measures to protect your (personal) data against loss or any form of unlawful use. Because of the medical nature of some of the personal data, Physitrack has incorporated a very high level of security.
To protect the confidentiality and integrity of your personal data, we:
- Have internal policies that keep your data private and confidential.
- Encrypt all communications between Physitrack and our users (http: via SSL, email via TLS).
- Encrypt all patient health information in our database ("at-rest").
- Limit information access inside our company to the absolute minimum necessary.
- Use an electronically and physically secured data center.
- Use a firewall which blocks access by attackers and unauthorized users.
- Automatically logoff healthcare providers after a certain period of inactivity.
- Require all of our users to choose strong passwords, and choose a new password every 90 days.
- Use a world-class CDN (content distribution network) which filters out possible attackers
- Use state-of-the art development and testing systems.
- Use best-in-class server management technologies.
6. Viewing, changing and deleting your personal data
If you wish to know what personal data Physitrack has collected about you or if you wish to change data that you cannot change yourself in your Account, then you can send your request to email@example.com. Physitrack will provide you with the personal data within 4 weeks.
Physitrack will retain your personal data for as long as your Account is active or as needed to provide the Service to you, to resolve disputes, enforce agreements or comply with any legal obligations. If you wish to delete your Account or request that Physitrack no longer uses your personal data, you can contact us at firstname.lastname@example.org.
7. Can this policy be changed?
It is possible for this policy to be amended in the future. Any changes to the policy will be mentioned on the Website, so it is recommended to regularly have a look at the Website.
If you have any questions, please do not hesitate to contact us via email@example.com.
Last modified: 24 May 2018 (clarification of stored data and sub-processors for GDPR)