The MigrateWell app was developed by researchers at Weill Cornell Medicine (WCM). The MigrateWell application environment is provided by Amazon Web Services and managed by WCM ITS Services. This Privacy Policy (“Policy”) applies to information you provide through your use of the MigrateWell app; This Policy does not apply to your Protected Health Information (“PHI”) used by WCM for treatment, healthcare or operational purposes, which is subject to special protections under the Health Insurance Portability and Accountability Act of 1996 (“HIPAA”). For more information about WCM’s Privacy Practices regarding your PHI and your rights under HIPAA, please refer to WCM’s Notice of Privacy Practices.
For information that is not PHI, this Policy describes how and why the MigrateWell mobile application (‘”MigrateWell,” “we”, “us” or “our”) might collect, store, use, and/or share ("process") your information.
Questions or concerns? Reading this Policy will help you understand your privacy rights and choices. If you do not agree with our policies and practices, please do not use this app. If you still have any questions or concerns, please contact us at sav4017@med.cornell.edu.
SUMMARY OF KEY POINTS
This summary provides key points from our Policy. You can find out more details about any of these topics by clicking the link following each key point to find more information on the section you are reviewing.
What personal information do we process? When you use MigrateWell, the application may collect personal information that you share with the research team and associated platforms to provide accurate and relevant information to you (the “Service”). This may include, for example, your email address, name, phone number, and other personal details you choose to provide. Our use of your information will depend on the choices you make, and the specific products and features you use.
Do we process any sensitive personal information? We may process sensitive personal information that you provide when necessary to provide the Service, with your consent or as otherwise permitted by applicable law.
Do we receive any information from third parties? We do not receive any information from third parties.
How do we process your information? We process your information to provide, improve, and administer the Study app and related services, communicate with you, for security and fraud prevention, and to comply with applicable laws. We may also process your information for other purposes with your consent, prior to doing so. We process your information only when we have a valid legal reason to do so.
Want to learn more about what we do with any information we collect? Review the privacy notice in full.
In what situations and with which parties do we share personal information? We may share information with authorized vendors under obligations of confidentiality, as required by applicable laws, and as otherwise directed by you.
How do we keep your information safe? We have organizational and technical processes and procedures in place to protect your personal information. For data protections and retention policies for the Weill Cornell ITS server, please visit its.weill.cornell.edu/policies/50002-privacy-of-the-weill-cornell-medicine-network-and-systems
What are your rights? Applicable privacy law may give you certain rights regarding your personal information. These rights are explained in more detail below and include those provided under relevant data protection and privacy regulations.
How do you exercise your rights? The easiest way to exercise your rights is by contacting sav4017@med.cornell.edu. We will consider and act upon any request in accordance with applicable data protection laws.
1. WHAT INFORMATION DO WE COLLECT?
Personal information you disclose to us
In Short: We collect personal information that you provide to us.
We collect personal information that you voluntarily provide to us when you register and use the MigrateWell app, or otherwise when you contact us.
Personal Information Provided by You. The personal information that we collect depends on the context of your interactions with us and MigrateWell app, the choices you make, and the products and features you use. The personal information we collect may include the following:
- email addresses
- passwords
- names
- usernames
Sensitive Information. When necessary to provide information and services to you, with your consent or as otherwise permitted by applicable law, we process the following categories of sensitive information:
▪ health data
2. HOW DO WE PROCESS YOUR INFORMATION?
In Short: We process your information to provide, improve, and administer MigrateWell app features, to communicate with you, for security and fraud prevention, and to comply with the law. We may also process your information for other purposes with your consent.
We process your personal information for a variety of reasons, depending on how you interact with MigrateWell app. This includes:
- Facilitating account creation and authentication and otherwise manage user accounts. We may process your information so you can create and log in to your account, as well as keep your account in working order.
- Monitoring and analyzing health and fitness data. The app collects and processes information such as at-home blood pressure trends, heart rate profiles, physical activity, and symptom tracking. This data is used to detect patterns, build predictive models, and improve the accuracy of the app.
3. WHEN AND TO WHOM DO WE DISCLOSE YOUR PERSONAL INFORMATION?
In Short: We may share information in the event of specific situations described in this section and/or with the following third parties.
We disclose information with service providers and other third parties we work with. We may disclose information to external companies who perform business, technical, or professional services for the MigrateWell app. This also includes companies that help with fraud detection and operations.
We disclose information to comply with the law or to protect ourselves. For example, we may disclose all categories of information to respond to a court order or subpoena. We will disclose information if a government agency or regulatory body requests it. This includes U.S. and non-U.S. law enforcement or regulatory authorities.
We disclose aggregate or anonymous information. We may disclose aggregate, anonymous, or de-identified information that cannot reasonably be used to identify you or via scientific research papers regarding MigrateWell app.
We disclose information as permitted by law. We will not disclose your personal information for any other purpose unless you have authorized Us to do so.
4. HOW LONG DO WE KEEP YOUR INFORMATION?
In Short: We keep your information for as long as necessary to fulfill the purposes outlined in this privacy notice unless otherwise required by law.
We will only keep your personal information for as long as it is necessary for the purposes set out in this privacy notice, unless a longer retention period is required or permitted by law (such as tax, accounting, or other legal requirements). When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymize such information, or, if this is not possible (i.e. if your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.
5. HOW DO WE KEEP YOUR INFORMATION SAFE?
In Short: We aim to protect your personal information through a system of organizational and technical security measures.
We have implemented appropriate and reasonable technical and organizational security measures designed to protect the security of any personal information we process. For data protections and retention policies for the Weill Cornell ITS server, please visit its.weill.cornell.edu/policies/1102-privacy-of-the-network.
6. DO WE COLLECT INFORMATION FROM MINORS?
In Short: We do not knowingly collect data from or market to children under 18 years of age.
We do not knowingly collect data from/market to children under 18 years of age. By using the MigrateWell app, you must be at least 18 or the parent or guardian of a minor and are consenting to your minor dependent’s use of MigrateWell app. If we learn that personal information from users less than 18 years of age has been collected without proper permissions and authorization, we will deactivate the account and take reasonable measures to promptly delete such data from our records. If you become aware of any data that we may have unknowingly collected from children under the age of 18, please contact our team at sav4017@med.cornell.edu.
7. WHAT ARE YOUR PRIVACY RIGHTS?
In Short: You may review, change, or terminate your account at any time.
Access, correction, deletion. Depending on where you reside, you have the right to (1) request to know more about and access the personal information we collect, use, and disclose about you, (2) request deletion of your personal information, and (3) request correction of inaccurate personal information. To request access, correction, or deletion of your personal information, please contact sav4017@med.cornell.edu. We may verify your request by asking you to provide information related to your recent interactions with Us, such as your name, email address, or phone number. If We deny your request, you may appeal Our decision by contacting us at sav4017@med.cornell.edu. If you have concerns about the results of an appeal, you may contact the Attorney General in the state where you reside.
Nondiscrimination. We will not discriminate against you if you exercise your privacy rights.
Withdrawing your consent: We are relying on your consent to process your personal
information, you have the right to withdraw your consent at any time. You can withdraw your consent at any time by contacting us at sav4017@med.cornell.edu. However, please note that this will not affect the lawfulness of the processing before its withdrawal nor, when applicable law allows, will it affect the processing of your personal information conducted in reliance on lawful processing grounds other than consent.
Account Information
If you would at any time like to review or change the information in your account or terminate your account, you can:
▪ Log in to your account settings and update your user account.
Upon your request to terminate your account, we will deactivate or delete your account and information from our active databases. However, we may retain some information in our files to prevent fraud, troubleshoot problems, assist with any investigations, enforce our legal terms and/or comply with applicable legal requirements.
If you have questions or comments about your privacy rights, you may email us at sav4017@med.cornell.edu.
8. APPLICABLE LAW
The laws of the State of New York will govern this Privacy Policy without giving effect to any principles of conflict of law. By using our website, you agree to bring all claims and actions relating to or arising out of this website or your purchases exclusively in courts seated in or having jurisdiction over New York County in the State of New York in the United States.
9. DO WE MAKE UPDATES TO THIS NOTICE?
In Short: Yes, We will update this notice as necessary to stay compliant with relevant laws.
We may update this privacy notice from time to time. The updated version will be indicated by an updated "Revised" date and the updated version will be effective as soon as it is accessible. If we make material changes to this privacy notice, we may notify you either by prominently posting a notice of such changes or by directly sending you a notification. We encourage you to review this privacy notice frequently to be informed of how we are protecting your information.
10. HOW CAN YOU CONTACT US ABOUT THIS NOTICE?
If you have questions or comments about this notice, you may email us at sav4017@med.cornell.edu.
11. HOW CAN YOU REVIEW, UPDATE, OR DELETE THE DATA WE COLLECT FROM YOU?
Based on applicable laws, you may have the right to request access to the personal information we collect from you, change that information, or delete it. To request to review, update, or delete your personal information, please contact sav4017@med.cornell.edu.