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 capitalised 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 website 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 healthcare 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
In the case of patients, Physitrack will store and process your personal data on behalf of its customers, the healthcare providers. For this processing, your healthcare provider will have access to your personal data and act as the "data controller" within the meaning of the European Privacy Directive (1995/46) and the Data Protection Act 1998 and will be responsible to you 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 your healthcare provider’s compliance with applicable privacy laws.
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 and the use of Intercom cookies as set out below (under 3). Physitrack shall only act as a controller with regard to personal data of healthcare providers and shall never act as controller with regard to personal data of a medical nature.
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 you an invitation to use the Service and has been accepted by you can see your Account information.
Use of the Service
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 Physitrack. 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 verify your identity, respond to your enquiries and contact you when necessary.
– 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.
For a patient, Physitrack will only provide your medical information to a third party if you or your healthcare provider has given its consent for your medical information to be disclosed (for instance, to an insurance company) and, if such information can be aggregated, will use reasonable endeavours to de-identify the information.
- To any person that you authorise us to disclose your personal information to.
- To your organisation, if you are acting on behalf of an organisation.
- To government and regulatory authorities, as required or authorised by law.
- To our professional advisors.
- To your healthcare provider.
- If it is obliged or otherwise permitted to do so on account of national or international laws, case law and/or regulations including to government and regulatory authorities.
- If Physitrack considers it necessary to do so in defense of its own rights.
Physitrack may post customer testimonials/comments/reviews on the website, which may contain personal information. Physitrack shall obtain the the individual’s consent via email prior to posting the testimonial.
You can contact us at email@example.com if you do not wish to have your personal information used for any particular purpose. However, it is then possible that you may not be able to access or use all or part of the Service or our website. If Physitrack later advises you of an intended use or disclosure and you do not object to that use or disclosure or Physitrack is permitted or required by law to do so, Physitrack may do so.
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.
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, but cannot guarantee that data transmission over the Internet will be wholly secure. Physitrack is also unable to warrant the security of any information provided to us over the Internet. Because of the medical nature of some of the personal data provided through the Service, Physitrack uses reasonable endeavours to incorporate a high level of security.
To protect the confidentiality and integrity of your personal data, we:
- Encrypt all communications between Physitrack and our users (http: via SSL, email via TLS).
- Use reasonable endeavors to encrypt all appropriate patient health information in our database where practical to do so ("at-rest").
- Limit information access inside our company.
- 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 CDN (content distribution network) which filters out possible attackers
- Use up-to-date development and testing systems.
- Use up-to-date 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 firstname.lastname@example.org. Before Physitrack provides you with access to your personal information, Physitrack may require some proof of identity. To the extent permitted by law, Physitrack will use reasonable endeavours to provide you with your personal information within 4 weeks of your request. In some circumstances where Physitrack corrects or updates a record, Physitrack may still require the retention of the original record. 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 email@example.com.
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. Your continued use of the Service and this Website after any changes to this policy means that you consent to such changes.
8. Australian privacy rights
If you are an Australian resident, you acknowledge and consent that Australian Privacy Principle 8.1 will not apply to an overseas disclosure of your personal information in accordance with this policy including in relation to Intercom and Full Contact. In addition, if you have any requests or complaints about this policy, you may send these firstname.lastname@example.org. Physitrack may respond to your request within 4 weeks. If you are dissatisfied with the outcome, you may make a complaint to the Australian Information Commissioner at the Office of the Australian Information Commissioner via telephone to 1300 363 992 (if calling within Australia) or + 61 2 9284 9749 (if calling outside Australia) or online at www.oaic.gov.au.
If you have any questions, please do not hesitate to contact us via email@example.com. Last modified: April 2017 (switched from Intercom.io to Customer.io)