Preeclampsia Care App & Website - Privacy Policy

1. Background

We are governed by the Ghana Data Protection Act, 2012 (Act 843) which seeks to protect the privacy of the individual and personal data by regulating the processing of personal information. We also adhere to medical ethics standards and healthcare privacy best practices. This means we are responsible for deciding how we use the personal data and health information that we collect about you and, in accordance with the Data Protection Law and healthcare regulations, we will ensure that the personal data we hold about you is, at all times:

• used fairly, lawfully, and transparently;
• collected for limited, specific purposes only;
• adequate, relevant to and limited to what is necessary for those purposes;
• kept accurate and up-to-date;
• not kept for longer than is necessary; and
• held securely.

We shall be accountable for and able to demonstrate our compliance with our obligations under the Data Protection Law, and this Privacy Policy is one of the ways in which we do that.

We have appointed a Data Protection Lead to oversee compliance with this Privacy Policy and our data protection compliance activities.

2. Personal Data We Collect About You

Personal data means any information about an individual from which that person can be identified. We may collect, store, transfer and use various types of your personal data:

• Contact Data: When we want to communicate with you, or you with us, we use your email address, telephone numbers, social media handles/ usernames and location (country/ place of residence).
• User Data: We collect your usage and preference details related to your use of the services such as the toolkit, insights, guides, and feedback.
• Marketing and/or Communications Data: We retain your preferences in receiving educational messages, health updates, and communications from us and our healthcare partners, and your communication preferences.
• Technical Data: Certain data is automatically generated and collected by us when you use the Services such as your IP address, MAC address and other device identifiers; your clickstream to, through and from the Services (including date and time); pages you viewed or searched for; length of visits to certain pages; page interaction information (such as scrolling, clicks, and mouse-overs); methods used to browse away from the page.

Not all of the list above will necessarily apply to you - it depends on your use of the Services and your particular interaction and communications with us. Please refer to section 4. HOW AND WHY WE USE YOUR PERSONAL DATA below.

There are also “special categories” of more sensitive data about you such as details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientations, political opinions, trade union membership, information about your health and genetic and biometric data (“Special Category Data”) and personal data relating to criminal convictions and offences (“Criminal Offence Data”) which require a higher level of protection (collectively referred to in this Policy as “Sensitive Personal Data”). We do not regularly collect, use or store such Sensitive Personal Data but in some circumstances we may need to do so. Please refer to section 4. HOW AND WHY WE USE YOUR PERSONAL DATA below, and any other privacy notices which we may provide to you carefully, so that you are aware of and understand the ways in which we collect and use your Sensitive Personal Data.

3. How We Collect Your Personal Data

You provide us with your personal data when you:

• access or use the Services;
• create a Preeclampsia Care App account;
• use the app's features including the Toolkit, Insights, and Guide sections;
• submit feedback about the app and your experiences;
• request information or educational materials;
• complete surveys or provide us with your feedback; and
• otherwise interact or correspond with us (including via email, social media or telephone).

In connection with some elements of the Services, we may receive additional personal data about you from healthcare professionals or organizations with whom we partner, with your consent. We may also receive personal data as part of the legal processes we undertake to protect our Services and intellectual property.

We collect the Technical Data automatically as you interact with our Services by using cookies and other similar web technologies.

We also use third party tools to help us manage and analyse our social media presence, and report on comments, mentions and other content that is posted about us on social media platforms and other public channels and forums. These third parties’ activities, and their information collection and sharing practices, are subject to the terms of the relevant social media platform, channel or forum. We will use this information in accordance with this Privacy Policy.

We use a third party service, Google Analytics, to collect standard internet log information and details of visitor behaviour patterns. We do this to find out things such as the number of visitors to certain parts of the Services, which helps us improve the educational and health monitoring aspects of our app. This information is only used by us in a way which does not identify you. We do not make, and do not allow Google to make, any attempt to find out the identities of anyone visiting our website or link analytics data to your health information.

4. How and Why We Use Your Personal Data

We will only use your personal data where Data Protection Law allows us to. Data Protection Law says we can collect and use personal data on the following bases:

• it is necessary for us to be able to perform an agreement with you.
• it is necessary for our legitimate interests (and your interests and fundamental rights do not override those interests);
• if we have your consent (which you can withdraw at any time); or
• to comply with a legal obligation i.e. rules laid down by courts, statute or regulation.

Data Protection Law says we can only collect and use your Sensitive Personal Data where an additional basis applies: for reasons of substantial public interest, including when preventing or detecting unlawful acts or in connection with our regulatory and oversight functions in sport; in connection with legal claims; cases where you have made the data public yourself; or where you have given explicit consent.

Accordingly, we lawfully use your personal data in the following ways:

• Delivering the Services: We use the Registration Data, User Data and Contact Data so that we can deliver the Services to you in an effective, efficient and accurate way. Without it, we would not be able to deliver a tailored service to you or respond to issues with these Services that are identified by us or you, or ensure you get the most out of your experience. Therefore, we use this data on the basis that it is necessary for us to be able to perform our agreement with you (i.e. the terms and conditions of the relevant Services) and for our legitimate interests of delivering the Services in this way.
• Operating the Services: We use the Technical Data in order to operate and administer the Services including as necessary for testing, analysis, maintenance, support, reporting and hosting of data. Therefore, we use this data on the basis that it is necessary for our legitimate interests of operating the Services in this way. We also use Technical Data together with certain Identity Data and Contact Data to assist in security and fraud prevention, system integrity (such as preventing hacking, cheats and spam) and/or to facilitate our response to a legal process. Therefore, we use this data on the basis that it is necessary both for our legitimate interests in protecting the Services in this way and in order that we can comply with a legal obligation.
• Surveys and research: We may use Contact Data and relevant health information you choose to share in order to conduct medical research, improve our services, or contribute to scientific understanding of preeclampsia, always with appropriate consent and anonymization when required. We use this data on the basis that you have given your explicit consent, and if we want to use the personal data for any other purpose we will notify you and seek your consent at that time.
• Health communications: We use your Contact Data to inform you of relevant health information, educational content, research updates, and app improvements (including, if requested, by way of calendar notifications or health reminders) which may be of interest to you or benefit your health management. With your explicit consent, we may provide certain data to our healthcare partners. We give you the option of providing opt-in consent to receive different kinds of health-related communications from us or these third parties or deciding not to do so.

  OPT-ING OUT: You can withdraw your consent and opt-out of health communications from us at any time by following the instructions provided to you in the relevant communication. Alternatively, you may contact us at info@preeclampsiacareapp.org. We may still need to send important service emails to you from time to time, particularly if they relate to your care.

  If you have chosen to receive communications directly from a particular healthcare partner or medical organization, you will be consenting to us passing the data to them to use in accordance with their privacy policy, to which we provide links on our website, so you should contact them directly if you no longer wish to receive their communications.

• Case studies and testimonials: With your explicit consent, we may use your feedback, testimonials, or experiences to help improve our services or educate others about preeclampsia. We will always seek your specific consent for this purpose and provide you with information about our intended use of such information.
• Health-related purposes: In some situations, we might need to use your personal data to protect your vital health interests, such as providing critical health information to medical professionals in emergency situations where you've given us authority to do so. We also use personal data in connection with legal and regulatory matters such as maintenance of medical records, compliance with healthcare regulations, and responses to requests by government health authorities or law enforcement. We use this data on the basis that it is necessary both for our legitimate interests in protecting health information and so that we can comply with legal obligations related to healthcare data. For any health data sharing, we adhere to strict medical ethics and applicable healthcare privacy laws.

We will only use your personal data for the purposes for which we collected it as described above, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

What if you do not want to share your personal data?

Unless otherwise specified above, generally we collect your personal data on a voluntary basis. However, please note that if you decline to provide certain mandatory personal data, you may not be able to access certain Services and we may be unable to fully respond to any inquiries you make.

5. Disclosure of Your Personal Data

We may disclose or share your personal data in the following circumstances:

• Third Party Service Providers: We engage third party businesses to provide services to us or to you on our behalf, such as support for the internal operations of our Services (and related services), communications, data storage and delivering communications (including calendar notifications). Our service providers may access, receive, maintain or otherwise use personal data on our behalf. Our service providers only use your personal data in accordance with our strict instructions to provide the relevant services and are not permitted to use your personal data for their own purposes, unless authorised by us to do so. Where this is the case you will be notified by us and provided with their privacy policies so you can understand how they will treat your personal data.
• Educational content: With your explicit consent, we may use anonymized testimonials or feedback for educational purposes on our website, in medical publications, or in educational materials. In such cases, we will clearly notify you of the specific use, provide you with the opportunity to review the content before publication, and respect your decision if you choose not to participate.
• Legally Required: We may also disclose your personal data if we believe we are required to do so by law, or that doing so is reasonably necessary to comply with legal processes or in the event of a re-organisation of the legal or ownership structure of the Preeclampsia Care App.

Please read carefully any additional privacy notices which we may provide to you so that you are aware of and understand any other circumstances in which we may disclose or share your personal data which are specific to your use of the Services and/or your relationship with the Preeclampsia Care App.

Notwithstanding anything else in this Privacy Policy, we may share aggregate or de-identified information with third parties for research, marketing, analytics and other purposes, provided such information does not identify a particular individual and the individual cannot be re-identified.

6. Security of Your Personal Data

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed (a Data Security Breach). In addition, we limit access to your personal data to those employees, contractors and other third parties who have a business need to know. They will only use your personal data on our instructions and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected Data Security Breach and will notify you and any applicable regulator where we are legally required to do so.

Where we have given you or you have chosen a password which enables you to access certain Services, you are responsible for using reasonable care in keeping this password confidential.

7. Links to Other Sites

The Services may contain links to other websites, applications and environments that are not owned or controlled by us (the Other Sites). The owners and operators of those Other Sites are responsible for their collection and/or use of your personal data and you should check their respective privacy policies. Unless specifically referred to otherwise, this Privacy Policy applies to our Services only and not the Other Sites.

8. Data Retention

We will only keep your personal data for as long as necessary to fulfil the purposes we collected it for (see section 4. WHY WE USE YOUR PERSONAL DATA), including for the purposes of satisfying any accounting, reporting or other legal requirements, in accordance with our internal Data Retention Policy.

To determine the appropriate retention period, we review - in addition to the purposes of use and how we can achieve them - other relevant factors such as the nature and scope of the personal data, the potential risks to data subjects from a Data Security Breach, and the applicable legal requirements, for example the limitation period for which legal claims can be made in court.

For example, all non-activated Preeclampsia Care App accounts are deleted after 45 days. Health-related data that is no longer needed for your care or for legitimate research purposes will be securely deleted in accordance with medical ethics and applicable healthcare regulations. All non-authorised child accounts are deleted immediately if a parent withholds consent and after 21 days if a child's account is not verified.

9. Your Rights

Under Data Protection Law, you have certain rights (depending on the circumstances) in connection with your personal data, which include:

• Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal information we hold about you and to check that we are using it lawfully, provided always that this does not adversely affect the rights and freedoms of other people;
• Request correction of the personal data that we hold about you. Where any of the information we hold about you is incorrect or incomplete we will act promptly to rectify this, including where you have requested us to do so. Users of the Preeclampsia Care App website can update their information any time via their account preferences;
• Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to use it. You also have the right to ask us to delete or remove your personal data where you have exercised your right to object to our use (see below);
• Object to use of your personal data where we are relying on our legitimate interests (see above) and there is something about your particular situation which makes you want to object to our use on this ground;
• Withdraw your consent to our use of your personal data where we do so in reliance on your consent. Once we have received notification that you have withdrawn your consent, we will no longer use your personal data for the purpose or purposes you originally agreed to, unless we have another legitimate basis for doing so in law;
• Request the restriction of use of your personal data. This enables you to ask us to suspend the use of personal data about you, for example if you want us to establish its accuracy or the reason for using it; and
• Request the transfer of the personal data you have provided, on the basis of consent or for a contract with us, to you or a third party where technically feasible.

We are committed to respecting your rights. You may action your rights (as may be applicable) by contacting us using the details provided below (section 11. CONTACT US) and we will comply with your requests within a reasonable period unless we have a lawful reason not to do so. Requests should be made in writing and to ensure that personal data is dealt with carefully and confidentially we will require the requestor to provide verification of their identity and all applications must be accompanied by copies of at least two official documents, which show your name, date of birth and current address (for example, driving licence, birth/ adoption certificate, passport, recent utility bill).

In responding to such requests, we will explain the impact of any objections, restrictions or deletions requested.

We will not charge you a fee to exercise your rights unless your request is clearly unfounded or excessive, in which case we may charge you a reasonable fee. Alternatively, we may refuse to comply with the request in such circumstances.

Additionally, should you wish to permanently delete your preeclampsiacareapp.org account and your personal data, you may do this yourself by following the below instructions:

1. Log into your account and navigate to [https://users.preeclampsiacareapp.org/;
](https://users.preeclampsiacareapp.org/;)
2. Click 'Manage Profile' on the right hand side.
3. Click 'Delete Account'.
4. You will then be prompted to enter your password. Please then click 'Confirm Password'.
5. On the following page, please click 'Confirm'.

Please note that if you log back in to your account during the 21 day period the account will be reactivated.

You also have the right to make a complaint at any time to the Data Protection Commission (DPC), the Ghana data protection authority. The DPC's contact details as are follows:

10. Contact Us

If you have any questions about this Privacy Policy or how we handle your personal data, please contact us using the following contact details: