Last updated: July 4, 2023
Pal, operating under the official name Amie Technologies B.V. (hereinafter referred to as “amie”, “Pal”, “we,” “us,” and “our”) is a digital care app, aiming to help individuals with life-limiting illnesses and their family caregivers to deliver better at-home care.
If you have any queries or objections about any of the ways we use your personal data, please contact us.
1. Personal Information we collect
We are committed to the GDPR principle of data minimisation, and only collect the personal data that we need to be able to provide our services to you. We collect personal information when you provide it to us, when you use our Website, App or Services, and when other sources provide it to us, as further described below.
A. Information You Provide to Us
Your Communications with Us: We collect personal information from you such as email or phone number when you request information about our Services, register for our newsletter, subscribe to our service, participate in discussion boards or other social media functions on or via Pal, enter a survey, submit a query, or otherwise communicate with us. We also collect the contents of messages or attachments that you may send to us, as well as other information you choose to provide, and that may be associated with your communications.
App entries: We collect personal information and details about yourself, as an App user, and a Care Recipient profile that you share with us through the App. By creating an account, and automatically creating a Care Recipient profile as an extension, and voluntarily adding personal details of anybody other than yourself, you are confirming that you have received their authorisation and permission to share their personal information with us.
Personal information of you or the Care Recipient may include name, gender, country of residence, date of birth, diagnosis, prognosis, relationship to the Care Recipient and personal profile photos. We also collect any entries that you may add on the App, including but not limited to symptoms, their severity and notes, tasks, their details and notes, as well as other information you choose to provide, and that may be associated with your account on the App.
You may also at any time share your App entries with other users, by inviting them to your Care Team, by way of sharing the Care Recipient’s Unique ID with any App user. In doing so, you confirm that you have received authorisation and permission from the Care Recipient and other users in the Care Team to share the Care Recipient’s personal information with them. They will be able to access and view your app entries and will be able to invite and provide access to other users.
Any health information, including but not limited to diagnosis, prognosis and symptoms, is classed as sensitive personal data and we ensure safeguarding measures are in place to protect this information. Our lawful basis for processing this sensitive personal data is your consent. You can withdraw your consent at any time – for more information please see “Your rights” below.
Surveys: We may contact you to participate in surveys. If you decide to participate, you may be asked to provide certain information which may include personal information.
Interactive Features: We may offer interactive features such as forums, blogs, chat and messaging services, and social media pages. We and others who use our Website or Services may collect the information you submit or make available through these interactive features. Any content you provide via the public sections of these features will be considered “public” and is not subject to the privacy protections referenced herein. By using these interactive features, you understand that the personal information provided by you may be viewed and used by third parties for their own purposes.
Job Applications. We may post job openings and opportunities on the Website or Services. If you reply to one of these postings by submitting your application, CV and/or cover letter to us, we will collect and use your information to assess your qualifications.
B. Information Collected Automatically
We keep track of certain information about you when you visit and interact with our Website, App or Services. This information may include the full Uniform Resource Locators (URL), clickthrough and clickstream to, through and from the Sites (including date and time), your Internet protocol (IP) address, user settings, MAC address, cookie identifiers, mobile carrier, mobile advertising and other unique identifiers, details about your browser, operating system or device, location information (including inferred location based off of your IP address), Internet service provider, pages that you visit before, during and after using the Website or Services, information about the links you click, information about how you interact with the Website, App or Services, including the frequency and duration of your activities, page response times, download errors, page interaction information (such as scrolling, clicks, and mouse-overs), methods used to browse away from the page, and any phone number used to call our customer service number or social media handle used to connect with our team, and other information about how you use the Website, App or Services. Information we collect may be associated with accounts and other devices.
C. Information from Other Sources
We may obtain information about you from other sources, including through third-party services and organisations. For example, if you access our Website, App or Services through a third-party application, such as a social networking site or a third-party login service, we may collect information about you from that third party that you have made available via your privacy settings.
2. How we use your information
We use your personal information for a variety of purposes, including to:
Provide the Services or Requested Information, such as:
- Fulfilling our Services;
- Setting up and administering your account with us;
- Process the Care Recipient’s health data to allow you to log health information about the Care Recipient’s symptoms including severity, frequency, time, and notes;
- Identifying and communicating with you, including providing newsletters and marketing materials;
- Managing your information;
- Responding to questions, comments, and other requests;
- Providing access to certain areas, functionalities, and features of our Services; and
- Answering requests for customer or technical support.
Serve Administrative and Communication Purposes, such as:
- Pursuing legitimate interests, such as direct marketing, research and development (including marketing research), network and information security, and fraud prevention;
- Sending communications about new product features, promotions, Pal’s strategic partners, and other news about Pal;
- Measuring interest and engagement in our Services, including analysing your usage of the Services;
- Developing new products and services and improving the Services;
- Ensuring internal quality control and safety;
- Authenticating and verifying individual identities;
- Carrying out audits;
- Preventing and prosecuting potentially prohibited or illegal activities;
- Enforcing our agreements; and
- Complying with our legal obligations;
Marketing of Products and Services: We may use personal information to tailor and provide you with content and advertisements. If you have any questions about our marketing practices or if you would like to opt out of the use of your personal information for marketing purposes, you may contact us.
Consent: We may use personal information for other purposes that are clearly disclosed to you at the time you provide personal information or with your consent.
De-identified and Aggregated Information Use: We may use personal information and other data about you to create de-identified and/or aggregated information. De-identified and/or aggregated information is not personal information, and we may use and disclose such information in a number of ways, including research, internal analysis, analytics, and any other legally permissible purposes.
3. Disclosing your information to third parties
We may share your personal information with the following categories of third parties:
Service Providers: We may share any personal information we collect about you with our third-party service providers. The categories of service providers to whom we entrust personal information include service providers for: (i) the provision of the Services; (ii) the provision of information, products, and other services you have requested; (iii) marketing and advertising; (iv) customer service activities; and (v) the provision of IT and related services.
Currently, we use the following Service Providers for (i), (ii), (iv), and (v):
- Amazon Web Services
Business Partners: We may provide personal information to business partners to provide you with a product or service you have requested. We may also provide personal information to business partners with whom we jointly offer products or services.
Affiliates: We may share personal information with our affiliated entities.
Advertising Partners: We do not share your information, including personal information, to advertise any third party’s products or services via the Services. We may use and share your personal information with third-party advertising partners to market our own Services and grow our Services’ user base, such as to provide targeted marketing about our own Services via third-party services. If you prefer not to share your personal information with third-party advertising partners, you may follow the instructions below.
We may share your personal information with other third parties, including other users, in the following circumstances:
Disclosures to Protect Us or Others: We may access, preserve, and disclose any information we store in association with you to external parties if we, in good faith, believe doing so is required or appropriate to: (i) comply with law enforcement or national security requests and legal process, such as a court order or subpoena; (ii) protect your, our, or others’ rights, property, or safety; (iii) enforce our policies or contracts; (iv) collect amounts owed to us; or (v) assist with an investigation and prosecution of suspected or actual illegal activity.
Disclosure in the Event of Merger, Sale, or Other Asset Transfer: If we are involved in a merger, acquisition, financing due diligence, reorganisation, bankruptcy, receivership, purchase or sale of assets, or transition of service to another provider, then your information may be sold or transferred as part of such a transaction, as permitted by law and/or contract.
4. International Data Transfers
All information processed by us may be transferred, processed, and stored anywhere in the world, including but not limited to, the Netherlands, the United Kingdom, the United States or other countries, which may have data protection laws that are different from the laws where you live. We endeavour to safeguard your information consistent with the requirements of applicable laws.
5. Your Choices
General: You may have the right to object to or opt out of certain uses of your personal information. Where you have consented to the processing of your personal information, you may withdraw that consent at any time by contacting us as described below. Even if you opt out, we may still collect and use non-personal information regarding your activities on our Services and for other legal purposes as described above.
Mobile Devices: We may send you push notifications through our Apps. You may at any time opt out from receiving these types of communications by changing the settings on your mobile device. With your consent, we may also collect precise location information if you use our Apps. You may opt out of this collection by changing the settings on your mobile device.
6. Your Privacy Rights
Depending upon your location and in accordance with applicable laws, you may have the right to:
- Access personal information about you consistent with legal requirements. In addition, you may have the right in some cases to receive or have your electronic personal information transferred to another party.
- Request Correction of your personal information where it is inaccurate or incomplete.
- Request Deletion of your personal information, subject to certain exceptions prescribed by law.
- Request Restriction or Object to Processing of your personal information, including the right to opt in or opt out of the sale of your personal information to third parties.
- Not be Discriminated Against by us for exercising your privacy rights.
If you would like to exercise any of these rights, please contact us as set forth below. We will process such requests in accordance with applicable laws. To protect your privacy, we will take steps to verify your identity before fulfilling your request, such as by requiring you to submit your request via your account.
7. Data Retention
8. Security of your Information
By using the Services or providing personal information to us, you agree that we may communicate with you electronically regarding security, privacy, and administrative issues relating to your use of the Services. If we learn of a security system’s breach, we may attempt to notify you electronically by posting a notice on the Services, by mail or by sending an email to you.
9. Third-Party Websites/Applications
The Services may contain links to other websites/applications and other websites/applications may reference or link to our Services. These third-party services are not controlled by us. We encourage our users to read the privacy policies of each website and application with which they interact. We do not endorse, screen or approve, and are not responsible for, the privacy practices or content of such other websites or applications. Visiting these other websites or applications is at your own risk.
10. Children’s Information
The Services are not directed to children under 16 (or other ages as required by local law), and we do not knowingly collect personal information from children. If the Care Recipient profile of your Care Team belongs to a child who is under 16, by adding their personal information, you are confirming that you are their parent or sole guardian or have the legal authority to share their personal information with us.
If you learn that your child has provided us with personal information without your consent, you may contact us asset forth below. If we learn that we have collected a child’s personal information in violation of applicable law, we will promptly take steps to delete such information and terminate the child’s account.
11. Supervisory Authority
If you are located in the European Economic Area or the UK, you have the right to lodge a complaint with a supervisory authority if you believe our processing of your personal information violates applicable law.
13. Contact Us
Nara Moripen is the data controller of the personal data processed under this policy.