Corrona, LLC

Last updated: July 2020

Overview

In connection with its products and services, which include various registry studies, Corrona, LLC makes available for use a mobile application that provides registry studies the ability to engage patients, collect certain data from registry participants, and capture and distribute other information as part of a registry study (the “Corrona App”). Your use of the Corrona App is subject to this mobile application privacy policy (“Mobile Privacy Policy”). The purpose of this policy is to detail Corrona’s commitment to protecting and respecting your privacy and any information about you that is personally identifiable to you (“Personal Information”) that we may collect from you or other sources.

Please read this policy carefully as it details what information we collect from you when you use the Corrona App, how we may use this information, the security approaches we use to protect your information, and how you can access and request modification of certain information that we may store about you and any applicable rights you may have. Please note that this policy applies only to information collected via the Corrona App – it does not apply to information you voluntarily disclose to Corrona through other means or information that Corrona acquires through other sources. It also does not apply to any Personal Information collected on any third party website or application of which we have no influence or control. The use of other sites or applications or the submission of Personal Information to other third parties is at your own risk.

Medical Disclaimer: The information on the Corrona App is not intended or implied to be a substitute for professional medical advice, diagnosis or treatment. You are encouraged to confirm any information obtained from or through this mobile app with the principal investigator or the Independent Review Board (“IRB”), and review all information regarding any medical condition or treatment with your physician.

NEVER DISREGARD PROFESSIONAL MEDICAL ADVICE OR DELAY SEEKING MEDICAL TREATMENT BECAUSE OF SOMETHING YOU HAVE READ ON OR ACCESSED THROUGH THE CORRONA APP.

Your Acceptance of the Mobile Privacy Policy and Changes to It

By accessing, viewing or otherwise using the Corrona App, you expressly consent to the collection and use of your information by Corrona in accordance with this Mobile Privacy Policy. If you do not agree to this policy, you may not use the Corrona App. Corrona reserves the right to change, modify, add or remove portions of this Privacy Policy at any time, without prior notice. Changes take effect on the date that appears on the revised Mobile Privacy Policy. If you use the Corrona App following a change in this policy, your use will be understood to signal that you accept and agree to be bound by the changes. Accordingly, we recommend that you review regularly this Mobile Privacy Policy.

What Information We Collect

We collect and process Personal Information and other non-individually identifiable information from you when you register to use the Corrona App, respond to communication such as email, or otherwise use the Corrona App in any manner. To register for the Corrona App to participate in a registry study, you will be required to provide the following Personal Information: your first and last name, your email address and your telephone number.

We may collect and use mobile device identifiers, IP addresses and session identifiers to analyze trends, to administer the Corrona App, to track user activities, to infer user interests, and to otherwise gather information about individual users and market segments.

At this time, we do not use “cookies” to enhance your experience and gather information about visitors and visits to the Corrona App. Please refer to the “Do we use ‘cookies’?” section below for more information about cookies.

We may also collect and store certain other personally non-identifiable information. This information is collected passively using various technologies, and cannot presently be used to specifically identify you.

How We Use Your Information

We only use your Personal Information as permissible under the law. We may use the Personal Information and other data we collect from you when you register, respond to a survey or marketing communication, access or view the Corrona App, or use the Corrona App features in the following ways:

  • To verify and validate your identity
  • To better understand your needs and how we can improve the Corrona App
  • To administer a survey or other Corrona App feature
  • To troubleshoot problems with the Corrona App
  • To enforce the Corrona Terms of App, enforce our rights (including protecting our intellectual property), and to detect and protect against error, fraud and other unauthorized or illegal activities
  • To respond to any of your subsequent requests
  • To provide any legitimate business service

We may also de-identify and aggregate your Personal Information for our own purposes. Aggregate data is information that has been combined with that of other users and analyzed or evaluated as a whole, such that no specific individual may be reasonably identified. De-identified Information is information that has been stripped of your identifiers, such as your name, contact information, and any other identifying data, such that you cannot reasonably be identified as an individual.

Corrona reserves the right to share Personal Information in response to duly authorized information requests of any law enforcement agency, court, regulator, government authority or other third party, where we believe such disclosure is necessary to comply with a legal or regulatory obligation, to prevent the unauthorized or illegal use of the Corrona App, or to prevent or detect a crime.

Worldwide Transfer of Your Personal Information

Your Personal Information may be transferred to, stored, and processed in a country that is not regarded as ensuring an adequate level of protection for Personal Information. We have put in place appropriate safeguards (such as contractual commitments) in accordance with applicable legal requirements so that your Personal Information is adequately protected.

With that said, you understand and agree that if you are using the Corrona App from a country outside the United States and provide Personal Information to Corrona, you will be authorizing and consenting to the transfer of Personal Information about yourself to the United States. You further understand that the privacy laws of the United States may be different from and not as comprehensive or protective as those in your country, and you agree that the transfer of your Personal Information to the United States occurs with your consent. Personal Information collected on the Corrona App may be stored and processed in the United States or abroad.

How We Communicate with You

When you send email or other communications to Corrona, we may retain those communications in order to process your inquiries, respond to your requests, and improve the Corrona App, our registry studies and related products and services. When you send and receive messages, we may collect and maintain information associated with those messages.

We may also send you service-related announcements on rare occasions when it is necessary to do so. For instance, if the Corrona App is temporarily suspended for maintenance, we might send you an email or text. Generally, you may not opt-out of these communications, which are not promotional in nature. If you do not wish to receive them, you have the option to deactivate your account.

Based upon the Personal Information you provide us, we may send you a welcome email to verify your username and password. We will communicate with you in response to your inquiries, to provide the services you request and to manage your account. We will communicate with you by email or telephone, in accordance with your preference.

We May Disclose Your Personal Information to Certain Outside Parties

You understand and agree that we can disclose your Personal Information and other data to third parties, as follows:

  • To our subsidiaries or affiliates, strategic partners and to third parties we engage to provide services on our behalf, such as web site hosting companies or companies who send communications to you on our behalf. Our agreements with these third parties require them to protect this data and prohibit these parties from using your Personal Information for any other purpose.
  • To third parties who are involved in conducting our studies and trials, including investigators, clinical research organizations, IRBs, government regulatory agencies who may need access to Personal Information to ensure the studies are being conducted in accordance with law, and research institutions.
  • In the event of the sale or transfer of Corrona, of one or more of our business units or of some or all of our assets, or in the context of some other business acquisition transaction.
  • In response to a subpoena or court order, or a request from a law enforcement or other government agency; to establish or exercise our legal rights, or to defend against claims; or to protect the safety or security of the public or of users of the Corrona App or study participants.

Use of Cookies

Corrona does not currently use tracking cookies. Cookies are small data files that a site or its service provider transfers to your computer’s hard drive or mobile device through your Web browser that enables the site’s or service provider’s systems to recognize your browser and capture and remember certain information. Although cookies do identify a user’s device, cookies do not personally identify users.

Additionally, mobile device’s may use other tracking files which are similar to cookies. For example, iOS devices use Apple’s “identifier for advertisers” (IDFA and Android devices use Google’s Android ID. In the context of tracking within an App, the concept of a cookie will include an IDFA and an Android ID. We may, however, use secure cookies for session management, (“Session Cookies”), but Session Cookies do not collect or store Personal Information and are only temporary. Information gathered by Session Cookies is not retained after the browser is closed. In the future, if we choose to use tracking cookies, we will update this policy with information on the types we use and how we use them.

“Do Not Track”

Our Corrona App currently does not respond to “Do Not Track” (DNT) signals.

Safeguarding Your Personal Information

Corrona follows generally accepted industry security standards to safeguard and help prevent unauthorized access and maintain data security of Personal Information. However, no commercial method of information transfer over the Internet or electronic data storage is known to be 100% secure. As a result, we cannot guarantee the absolute security of any Personal Information submitted to or otherwise collected during your use of the Corrona App. Accordingly, you understand and agree that you transmit all data, including Personal Information, to us at your own risk.

Children’s Privacy

The Corrona App is not intended for use by, or designed to attract children (i.e., individuals under 18 years of age). We do not knowingly collect Personal Information of children other than as strictly permitted in relation to certain pediatric registry studies. If you have reason to believe that a child has improperly provided Personal Information to us through the Corrona App, please contact us, so that we can look into this matter and promptly take remedial action accordingly.

Retention of Your Personal Information

In accordance with our record retention policy, we will store your Personal Information for as long as we have a relationship with you or believe it is necessary to carry out the purposes for which we collected it, or to comply with applicable laws, rules or regulations. To request that your Personal Information be deleted from the Corrona App, please contact us as listed below.

Your Rights over Your Personal Information

You may have certain rights regarding Your Personal Information, subject to local law. These include the following:

  • Right to access your Personal Information.
  • Right to rectify the information we hold about you.
  • Right to erase your Personal Information.
  • Right to restrict our use of your Personal Information.
  • Right to object to our use of your Personal Information.
  • Right to receive your Personal Information in a usable electronic format and transmit it to a third party (right to data portability).
  • Right to lodge a complaint with your local data protection authority, if one exists in your country.

We encourage you to contact us to update or correct your Personal Information if it changes or if the Personal Information we hold about you is inaccurate. Please note that we will likely require additional information from you in order to honor your requests. If you have any other questions or comments in relation to your Personal Information, this Mobile Privacy Policy, please contact us as detailed below.

Contact Us

If you have any questions or concerns regarding your Personal Information or the way in which your Personal Information is used, please contact us via mail at:

Corrona, LLC
Privacy Office
Attn: Data Protection Officer
1440 Main Street, Suite 310
Waltham, MA 02451

or via email at privacy@corrona.org