Privacy Policy
This privacy policy explains how we use your data to deliver our healthcare applications and services. We explain what information we collect when you visit our website or use our products, why we need certain information from you, what we do with it, and how we keep it secure.
patientMpower designs and develops services and applications for patients with chronic diseases, such as lung disease, kidney disease and cardiovascular disease. We empower users to manage their health at home and improve their health outcomes. Patient’s health data can be seen immediately by their care team in a secure patient data portal. Healthcare staff can then make informed decisions about the ongoing care needs of patients being monitored.
We are a company incorporated in Ireland under registration number 563516.
You can contact us at our main business address: patientMpower, 10/13 Thomas Street, The Digital Hub, Dublin 8, D08 PX8H, Ireland, or via www.patientmpower.com.
Our Data Protection Officer can be contacted via dataprotection@patientmpower.com, or by post at the address above. Our Data Protection Officer is Oisin Hayes.
We believe that making data more easily available to patients will improve healthcare, but we are also aware that data needs to be handled securely and transparently. We believe you should own your own data and should have the choice about who has access to your data or who you consent to view the data. patientMpower respects your right to data protection and to privacy. This Data Protection Notice explains how we collect, transfer, store, and use your data.
As part of our ethos of continuous improvement, this Data Protection Notice and any associated policies or procedures may be changed in the future. If we make changes we will provide notice of any proposed changes at least thirty (30) days before they come into effect. You are free to stop using our apps and services at any time but we would recommend that any decision be taken in consultation with your healthcare provider.
patientMpower provides smartphone applications and associated equipment and clinical patient management and reporting portals that enable clinicians to provide appropriate care through telemedicine and allow patients to manage and monitor their condition themselves without losing the necessary contact with and support of their healthcare providers.
We use your health and medical information to provide you with a healthcare service in the form of a diary for personal use or sharing your data with your healthcare provider for remote monitoring. We only capture data that is relevant for providing better delivery of care, improving our apps and services, and assessing remote patient monitoring.
patientMpower acts as a Data Processor on behalf of healthcare providers in the provision of our services and applications.
We act as a Data Controller for data logged by you in a personal health diary if you are using our services or applications in that way.
If you have consented to allowing your data to be included in research studies, we act as a Data Controller for that data for the purposes of creating anonymised data sets to be used in research.
We also act as a Data Controller in the context of processing of data for the purposes of product and service improvement and product research and development. However, data used for these purposes is de-identified and anonymised other than in exceptional circumstances.
When you use our services and apps, we collect information about your health. This information can be manually entered by you or be collected automatically from your smartphone and/or connected health device. Other health information may come from third parties, such as your healthcare provider or other health partners.
If you choose to use a Google account or other social media account to complete the sign-up process for one of our applications, we are authorised to collect, store, and use any information that you have agreed to let these sites or services share with us. This may include your name, email address, profile picture, or other details.
When you use our services or apps, you may have the option to link other third-party services with your account. Examples of these services may include Apple Health, Fitbit, etc. If you choose to do this, you are authorising patientMpower to collect, store, and use information that you agreed these sites may share with us through their API.
Please note that using third party services to facilitate login or to capture or provide data to the patientMpower application can identify to those services that you are a user of a telemedicine application. You should check the data protection or privacy terms of the service you are using to find out what that data may be used for by that third party service.
We obtain your personal data in one or more of the following ways:
The specific types of personal data we process about you may vary depending on the specific patientMpower app you are using or the specifics of the treatment regime being applied. Examples or descriptions of categories of data provided here are not exhaustive and are for information purposes. Supplemental information will be provided to users for specific application contexts where necessary.
Category | Example/Description | Source |
Identity Information |
| Directly Provided |
Demographic Information |
| Directly Provided |
Health Result Data |
| Directly Provided [may be obtained from third party apps] |
| Automatically recorded or Directly Provided | |
Health Condition & Symptom Data |
| Directly Provided |
Medication Information |
| Directly Provided |
Survey Responses |
| Directly Provided |
Healthcare provider submitted data |
| Authorised Third Party |
Location |
| Automatically recorded |
Activity Data |
| Automatically recorded |
Technical Data [This is indirectly personal data as it can be associated to an app user or device] |
| Automatically recorded |
Depending on the version of the patientMpower app you are using different permissions may be asked for to access features or functionality on your device or from 3rd party services.
Permission | Purpose |
Remote Push Notifications | This allows our app to send you push notifications using third party services (Mixpanel and Airship). The reason we need to do this is to send you prompts associated with your care and with the correct use of the app and any devices that might be connected with it (e.g. a spirometer). |
Access Bluetooth when in use | This is necessary to allow connection to Bluetooth enabled medical devices such as Pulse Oximeters, Spirometers, or Blood Pressure monitors. |
Apple HealthKit (Read & Write) | This allows patientMpower to read or write data to or from Apple Health and allows us to obtain data from other health devices connected to Apple Health (for example a Apple Health connected thermometer or smart watch). |
Google Fit | Some versions of our app enable users to connect to Google Fit to allow access to data from fitness trackers or smartwatches connected to Google Fit. This data is used to derive data about patient well being and quality of life as part of post-discharge treatment protocols defined by our clinical customers |
Fitbit | Some versions of our app enable users to connect to Fitbit. This allows access to data logged using a Fitbit smartwatch to provide data on patient health and key metrics related to their care. |
Location When In Use | In some versions of our app the user’s location is logged when they are using the app. This data is used for purposes including assessing air quality implications for patients with CF or lung transplant as part of clinical care. |
patientMpower processes Personal Information (PI) and Personal Health Information (PHI) as a necessary part of the operation of our services to support the delivery of patient care and, subject to appropriate consents, to support research activities by approved researchers.
Our applications are intended for use by persons 18 years of age or older, except where the use is prescribed by or recommended by an appropriately qualified healthcare professional.
We do not knowingly collect data from children under the age of 14 through our apps, except where the use of the application is prescribed or recommended by an appropriately qualified healthcare professional.
Telemedicine falls within the definition of an Information Society Service under EU law. Therefore, where a child under the age of 16 (or lower in other EU Member States) is consenting to the use of the application or service, this consent must be validated by an individual with parental authority.
If you discover that your child has been using our apps without your consent, or someone has been using the apps on behalf of your child without your consent, please contact us using the information below in the “Contacting Us” section or email dataprotection@patientmpower.com and we will take steps to delete the information from our databases. Additionally, you can delete information from the app directly.
Purpose | Legal Basis Relied On |
Provision of the Healthcare Service
|
|
Order Fulfilment |
|
Customer Service and Support |
|
Technical Support |
Explicit consent (where data relating to health is processed as part of the Technical Support purpose) |
Analysis of Application performance |
|
Research and Development for patientMpower |
|
Clinical research |
Whenever possible de-identified or anonymised data is used for clinical research with approved research partners. |
patientMpower makes use of several different categories of data processors to help us deliver our services.
Category | Details of Processors |
Application hosting | We use AWS hosting in the EU (Ireland) as our main hosting provider, with our US apps hosted by AWS in the US. Specific instances of patientMpower applications may, from time to time, be hosted in other environments due to specific requirements of clients. |
Website Hosting | Our website is hosted with WordPress |
Analytics | We use third party analytics services such as Mixpanel and Firebase in our apps to help track how users use our services so we can optimise and improve services and apps, as well as for testing, troubleshooting, and clinical safety purposes |
Logistics & Order Fulfilment | Depending on the application and the requirements of clients, patientMpower may engage 3rd party logistics operators to distribute additional devices necessary for the use of the application such as pulse oximeters or spirometers to patients. |
Back Office Systems | We use a variety of software systems such as Google Work and Atlassian for our administrative and operations processes. |
Compliance | We engage specialist third party service providers to assist us with Data Protection Compliance, Information Security management, and other related matters. |
Technical Support | We engage relevant third-party service providers to provide technical support to our users, both individuals and healthcare providers. |
Customer Service | We engage relevant third-party service providers to customer service and support to our users, both individuals and healthcare providers, such as Intercom and Hubspot. |
patientMpower may provide personal data to the following categories of recipient:
De-identified and anonymised data is provided to approved clinical research partners for the purposes of conducting research in respect of treatment and management of conditions. These studies are carried out under appropriate research conditions and are subject to independent ethics approval through our research partners.
patientMpower retains identifiable data for the duration of your treatment or use of the application plus any retention period that may be defined by:
We will also keep data which cannot directly or indirectly identify living individuals for analytics and research purposes to help improve our products and services.
We place great importance on the security of all personal data associated with our users. We have security measures in place to attempt to protect against the loss, misuse and alteration of personal information under our control.
patientMpower is designed with stringent security protocols. It uses state-of-the art electronic surveillance and multi-factor access control systems. All data transport between your app and our servers is encrypted. Data is encrypted in transit using HTTPS and TLSv.1.2, and encrypted at rest on AWS using AES 256 encryption.
We use a risk management process based on a Health Insurance Portability and Accountability Act (HIPAA) template. It allows us to conduct an accurate and thorough assessment of the potential risks and vulnerabilities to the confidentiality, integrity, and availability of electronic protected health information held by patientMpower, and also implement security measures sufficient to reduce risks and vulnerabilities to a reasonable and appropriate level to comply with HIPAA standards.
Periodic reviews of our security standards are carried out and our software development process has a checkpoint to identify new risks when we define / develop new features.
However, with any electronic transmission and storage of data comes risks and we cannot guarantee that our databases, or those of our third-party affiliates, will be 100% secure. There is also a risk of data being intercepted while being transferred over the internet.
In the event of a breach of data security, patientMpower will:
The operation of the patientMpower applications and services does require the processing of data for profiling and does make use of automated decision making to identify usage patterns in the app and ensure notifications are sent to users to remind them to record health data (e.g. take blood pressure) or to support prompts and alerts to help users use the application or associated measurement devices or medical equipment correctly (for example: alerting users if their spirometry test did not meet the required quality).
No decisions are taken based solely on automated decision making which would have a legal or equally significant impact on a user as these applications and services are used as part of a clinical treatment regime overseen by healthcare professionals.
Where patientMpower is acting as a Data Controller, you have rights under EU Data Protection law. These rights are:
To do any of these things, please email us at dataprotection@patientmpower.com. We’ll ask you for proof of identity. Data protection laws give us one month to get back to you. Under GDPR individuals also have rights to seek compensation for infringement of their data protection rights under the legislation.
You have the right to file a complaint to the Irish Data Protection Commission.
Their contact information can be found online at this link: https://dataprotection.ie/en/contact/how-contact-us
patientMpower complies with HIPAA through our application of an appropriate risk management framework in line with our business associate agreements entered into with clients who are US Healthcare providers and covered entities under HIPAA.
For the purposes of the United States COPPA rule, parental consent is required for the use of our applications or services by any person under the age of 13. We do not knowingly collect data from children under the age of 13.
Get valuable health insights by using our Bluetooth connected weighing scales to monitor body weight. Measured values will be transferred directly to the patientMpower application for healthcare professionals to review in real time.
Our Bluetooth enabled blood pressure monitor accurately measures patients’ blood pressure, measured values will be transferred directly to the patientMpower application for healthcare professionals to review in real time.
Our Bluetooth connected pulse oximeter measures arterial oxygen saturation and heart rate. Measured values will be transferred directly to the patientMpower application for healthcare professionals to review in real time.
Spirobank SMART spirometer - connects to patientMpower app via Bluetooth for seamless recording of pulmonary function. Measured values will be transferred directly to healthcare professionals to review in real time. Measures: