florio ITP App Privacy Policy

  1. About This Privacy Policy

This privacy policy (the “Policy”) explains how information about you is collected, used, and disclosed by Florio GmbH  ( “we”, “our”, or “us”).  This Privacy Policy applies to information we collect when you use the “florio ITP” mobile application (the “App”).

We may change this Privacy Policy at any time. If we make changes, we will notify you by revising the “last updated” date above. We may also use other reasonable means to notify you, including a link posted on the App or by sending a notice to the e-mail address that you provided to us. We encourage you to review the Privacy Policy whenever you access the App to stay informed about our information processing practices and the ways you can control your privacy.

  1. Information we Collect

Information you provide directly to us.

We collect information you give us. For example:

  • Data that you provide directly when you register for, or use, the App.  This data will vary, but typically consists of identifiers like your name, email address, and other similar contact data.  We also receive data from the communications you send to us, such as customer service inquiries, product reviews, and other feedback regarding the App.
  • User credentials. This data may include username, password, and similar security information used to create an account and authenticate users of the App.
  • Demographic data. We may collect information from you like your age, gender, country and/or state of residence, and language preference.
  • Other information collected through connected devices or services, including activity information.

Information we collect automatically.

We also automatically collect some information when you access or use our App, including:

  • Device data. This data could include type of device, operating system, and other software installed on the device, device settings, IP address including non-identifiable location (on city-level), device identifiers, and error reports.
  • Internet or other electronic network activity information. We may collect information about the features you access, your clicking habits, and the timing, frequency, and duration of your interactions through the App.

Health information

We collect health information that you enter when using the App or from connected services (e.g., Apple HealthKit). This includes, if you choose to provide it:

  • Treatment information (e.g., start/end date of treatment regimen, dose, date/time of medication taken, treatment type (incl. brand of product);
  • Information about bruises, petechiae, and bleeds (e.g., location on the body, time/date when noticed, severity, cause, notes, type of bleed (e.g., nosebleed, gum bleeds, blood in urine, etc.));
  • Information about platelet count (e.g. count, date/time, location where count taken);
  • information about your fatigue and mood, including date/time, and mood and fatigue level;
  • Information about your activity level;
  • Information about your next physician appointment (date/time, location); and
  • Information about how ITP and your treatment affects your daily routine (e.g. level/ effect of ITP on everyday life, time spent at hospital/with a physician including travel time, number of ITP-related hospital visits, difficulties following medication regime, impact of any food restrictions, other medications taken, etc.);

If you choose to connect the App to other services you use, such as Apple HealthKit, or to another device, such as a smartwatch or other wearable, we will receive information that you make available to us via the App according to the settings you select within the App and other connected service or device.  This information could include, depending on your settings, information collected and stored by the connected service or device (including information stored six months prior to connecting the service), such as your activity levels (steps taken, heart rate, calories burned, walks and runs, heart points, motion minutes, standing hours, stair-steps, basic energy consumption, energy consumption during exertion, duration of a workout, resting heart rate), nutrition information, and sleep pattern data.

We use this information to provide the features or services you request, including to allow you to log your health information and create reports that you may share with others (e.g. your physician), or to receive customer support.  We may also use your information to understand usage trends and statistics and to improve the App in accordance with the permissions you grant us within the App.  We also aggregate and anonymize information for other purposes described in this Privacy Policy.

We can only make the App available to you if you consent to the processing of your health data. If you do not want your health data to be processed for all outlined purposes, please do not sign-up for or use the App. You can withdraw your consent at any time without the lawfulness of processing your data prior to the withdrawal being affected, but you may no longer be able to use the App.

  1. How We Use Data

We may use the information we collect about you for the following purposes:

  • Provide and deliver the information or App you request or that we think will be of interest to you and send you confirmations, receipts, technical notices, updates, security alerts, and support and administrative messages, as needed for us to perform the contract we have with you based on the terms of use for the App.
  • To maintain, improve, and expand our App and for our other legitimate interests related to providing you the App, including for analytical purposes (employing Google Analytics, MixPanel, AppsFlyer), for example by monitoring and analyzing trends, usage, and activities in connection with our App, and to Personalize the App, content or features that match user profiles or interests or that are based on the information you provide or the actions you take;
  • To provide customer service, request feedback, and otherwise contact you about your use of the App (e.g., when we need additional information) for our legitimate interest in ensuring efficient and user-friendly communication with the users;
  • To detect, investigate, and prevent fraudulent transactions and other illegal activities, and protect our rights and property and the rights and property of others, including by enforcing our Terms of Use, and to resolve disputes, in furtherance of our legitimate interests in protecting the integrity of the App and our business; and
  • For any other purpose we disclosed to you at the time of collection, or for which we have otherwise obtained consent.

We also may use information that does not identify you for additional purposes.  For example, we use anonymized and aggregated data for medical, science and other related research purposes; to identify trends in the user community; for market research purposes; and for promotional and marketing purposes. For these and other purposes, we also share anonymized data with third parties, which process it for their own purposes.

  1. How We Share and Disclose Data

We may share information about you for certain business purposes. For example,

  • With vendors, consultants, and other service providers or volunteers who need access to such information to perform certain functions on our behalf, including Google Analytics, MixPanel, and AppFlyer for App usage monitoring to improve and expand our Service;
  • When we believe in good faith that we are lawfully authorized or required to do so or that doing so is reasonably necessary or appropriate to comply with the law or legal processes or respond to lawful requests, claims or legal authorities, including responding to lawful subpoenas, warrants, or court orders, or lawful requests by public authorities to meet national security or law enforcement requirements;
  • When we believe such disclosure is necessary to: protect the safety and security of our personnel, other individuals, or the App; prevent fraud, abuse, death or imminent bodily harm, or other unlawful or unauthorized activities; protect the rights or property of us or third parties, including enforcing the terms of our agreements; or to protect our own, or a third party’s legitimate interests relating to law enforcement, litigation, or criminal investigations;
  • In the event of a sale, merger, acquisition, reorganization, or similar event, or in contemplation of such an event (g., due diligence), your data may be among the transferred assets; and

We may also share your data for any other purpose as disclosed at the time of collection, or when we have otherwise obtained consent.  As noted above, data that does not identify you may be shared with third parties for additional purposes.

We do not, and will not without consent, sell your personal information to third parties. We do permit third parties to collect the information described above through our App and discloses such information with third parties for business purposes as described in this Privacy Policy. The information practices of these third parties are not covered by this Privacy Policy.

  1. Third-Party Products and Services

Our Sites may link or otherwise provide access to third-party websites and other products and services that are outside our control, including functionality powered by third parties outside of our control (collectively, “Third Party Products and Services”). This site also may make third-party information and other content available on or through the site (“Third Party Content”).

These Third Party Products and Services and Third Party Content are not under our control, and we are not responsible for the security or privacy of any personal information you share with them. You should exercise caution and review the applicable privacy policies of any Third Party Product and Service, including those you use in connection with the Sites, before providing them with your personal information.

  1. What Choices You Have And How You can Exercise Them

Subject to statutory provisions, including the corresponding local laws, you may have a number of rights in connection with our processing of your information. To exercise these rights, or if you have any questions, requests, or complaints about the processing of your information in relation to the App, please contact us at privacy@florio.com

  • Access: subject to the statutory provisions, you have the right to request access to your information processed by us and a portable copy of this data.
  • Transparency: subject to the statutory provisions, you have the right to request more information about our data processing practices.
  • Deletion: subject to the statutory provisions, you have the right, if there are justified grounds, to request the deletion of your data.
  • Rectification: subject to the statutory provisions, you have the right to have incorrect data rectified and to have incomplete personal data completed.
  • Right to object: subject to the statutory provisions, you have the right, on grounds relating to your particular situation, to object to, and in some cases request the restriction of, any processing of your data for the purposes of legitimate interests pursued by us or a third party.

We will respond to requests in accordance with local laws.  If you become aware of changes or inaccuracies in your information, you should inform us of such changes so that the information may be updated or corrected. We may verify your request by seeking additional information from you and/or by requiring you to confirm a link or confirmation code sent to contact information on file for your account.  You may be entitled, in accordance with applicable law, to submit a request through an authorized agent.  In addition to other remedies, you are also entitled to file a complaint with an appropriate data privacy regulator.

We will not discriminate against you for exercising your rights and choices, although some of the functionality and features available on the Service may change or no longer be available to you.  Any difference in the App is related to the value provided.

  1. Security, Storage and Transfer of Data

Your data privacy is important to us. We try to strive to protect the information we maintain; however, we cannot ensure or warrant the security of any information that you transmit to us by 100%.

We will store your data for the period necessary to fulfil the purposes outlined in this App Privacy Policy unless we delete it sooner. After expiry of the corresponding storage period, we will delete your data in line with our data protection policies and procedures, unless statutory retention obligations (in particular due to commercial and tax law provisions) preclude this or a prolonged storage is necessary in the specific individual case for the purposes of our legitimate interests (interest in fulfilling our legal obligations and the necessity of processing data for the establishment, exercise or defence of legal claims).

Your information may be stored in the European Economic Area (EEA) and in other countries outside the country where you reside. We may also transfer your information to vendors, consultants, and other service providers or volunteers in countries that may not provide the equivalent level of legal protection for personal data but where we have taken security measures in order to protect your data, including, with respect to transfers from the EEA to other countries, by implementing the standard contractual clauses adopted by the European Commission. If you have any questions about these and other security measures we use for the data transfer, please contact Florio at privacy@florio.com.

  1. Children and Parents

We do not knowingly collect or sell any information from children, as defined by applicable law, without parental consent or as otherwise permitted by applicable law.

Consistent with applicable law, for minors who are between the ages of 13 years old and 18 years old, you may request and obtain removal of content or information you post on the Services by emailing privacy@florio.com. However, requesting removal of posted content does not guarantee complete removal of the content; for example when another third party reposts the minor’s content.

  1. Do-Not-Track Signals

Some mobile and web browsers transmit “do-not-track” signals. Because of differences in how web browsers incorporate and activate this feature, it is not always clear whether users intend for these signals to be transmitted, or whether they even are aware of them. We currently do not take action in response to these signals.

  1. How to Contact Us

Florio GmbH is responsible for your information, and, where such concepts are recognized by law, Florio GmbH is the data controller with respect to your information. If you have a question, concern, or complaint regarding our data privacy practices, or if you would like to exercise any of your rights, you may contact us at privacy@florio.com.

You can contact the data protection officer at any time using the contact details below:

Data Protection Officer

Florio GmbH

Wilhelm-Wagenfeld-Str. 22

80807 Muenchen

Germany

Email: privacy@florio.com