Alira Health is an international patient-centric and technology-enabled advisory firm whose mission is to humanize healthcare.
We provide a suite of integrated services designed to help healthcare and life sciences organizations innovate and grow, impacting the patient experience and ushering in a new standard of care.
The MyReco® platform - which includes the MyReco® app and MyReco® dashboard - is tailored for information capture in clinical studies, to improve patient experience while providing improved workflow for clinical sites and high-quality Real-World Evidence for our customers.
When using MyReco®, Alira Health can be qualified differently.
Alira Health is directly responsible for the processing of your information for the following activities:
Alira Health acts as a sub-contractor under the instructions of its customers, for all the information processed in the context of the clinical trial.
All information relating to the information process has been provided to you in the Informed Consent Form (ICF) and all your questions have been answered by the Principal Investigator before ICF signature . However, please refer to the clinical trial team for any questions related to this process.
This Notice therefore only provides information for Processing where Alira Health is Controller.
The protection of personal information is a priority for Alira Health as protecting your information means protecting you.
This is the reason we process your information securely and with the utmost prudence, respecting your rights and ensuring maximum transparency.
Please read this notice carefully before you start using MyReco®, as it is important to us that you know how we process your information.
Please note that this notice does not apply to the processing of your clinical information collected during the clinical trial.
If you have any questions about these matters, you may contact the clinical trial team or you may refer to the ICF given to you during the enrolment process.
We consider the careful and secure processing of your personal information to be of the highest importance and we are committed to:
In the frame of the clinical trial, we may have to collect several types of personal information from and about you including information that falls within the categories listed below. In addition, we have provided you with examples of personal information that we may collect that corresponds to such categories.
| Category | Examples |
|---|---|
| Demographic, socio-economic and health information | Unique personal identifier, age, national origin, gender (including gender identity and gender expression), marital status, education, employment, military or veteran status, medical or health insurance information, race, color, ancestry, religion, sexual orientation, medical condition, sex (including pregnancy, childbirth and other related medical conditions), mental disability, genetic information |
Collectively, the information described above and any other personally identifying information we may collect from and about you shall be referred to as “personal information.” We may collect personal information:
In the frame of our App management, we also process:
| Category | Examples |
|---|---|
| Internet or other electronic network activity | Information regarding user’s interaction with the application.
At connection time:
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The personal information we collect is used to enable us to perform the following activities:
MyReco® needs to collect some information about you in order to function and thus allow you to participate in the clinical trial through this App. For this purpose, first, you will be asked to enter the activation code that the clinical trial team has provided you in order to create your account and offer you tailored content (for instance, showing you content in your local language and relevant to your disease).
The initial information required for your login and the information collected to run our application is collected by Alira Health based on the Terms and Conditions (T&Cs), the contract, you have agreed to for using MyReco®.
Once your account has been activated, you can start interacting with the chatbot, and filling in your diary and questionnaires with information about your health and lifestyle.
We process your information in order to provide you with assistance and support, to fulfill your requests, and to respond to complaints or questions you ask us via the App, by email or by other means.
We may do so based on the T&Cs, the contract, you have agreed to for using MyReco® and based on our legitimate interest. We consider that we have a lawful interest in answering your requests. We understand that the processing of this information is also beneficial to you to the extent that it enables us to assist you adequately and answer the queries raised.
For complaints or questions about the clinical study, please contact your clinical trial team.
We use your information to notify you of changes to the T&Cs or this Privacy Notice, or changes to App functionality. We may do this based on the consent you have explicitly provided while agreeing to the T&Cs of MyReco®.
Alira Health created MyReco®. Canadian law, and the good privacy practices for developing mobile apps issued by the Canadian Privacy Commissioner, require Alira Health, as the manufacturer of MyReco®, to collect and analyze proactively the app usage in order to identify any need to proceed immediately with corrective or preventive actions.
We use your information to ensure and improve the security of MyReco®, resolve any technical issues, and analyse and test the system performance. This also includes fraud prevention (e.g., cyber-attacks prevention), App improvement and maintenance, and taking steps to ensure the quality and security of MyReco®.
Some of this information is collected automatically by the App, and some is collected by Alira Health via surveys or other methods.
We can do this on the basis of our legal obligation related to Good Clinical Practice (GCP) and App security and functionality needs.
Alira Health collects and processes a large amount of information, including via third-party software.
In order to do this, MyReco® collects information such as:
Your information will be previously anonymized and, therefore, you will not be identifiable.
If you have any questions about the App, you can find more information in the T&Cs available in the "Profile" section of the App, or you can contact Alira Health.
The information is stored only for the period necessary to achieve the purposes for which it was collected (end of clinical trial or if you withdraw your consent) and to comply with applicable laws, rules, or regulations.
The duration of the processing of information collected for the purpose of clinical trials is not established by Alira Health but is specified in the information provided to you by the Clinical Center or the Sponsor or the CRO.
We are committed to protecting the information and personal information you share with us.
Therefore, we take all appropriate technical and organizational measures to prevent any destruction, loss, alteration, dissemination, interference, or unauthorized access to such information, whether accidental or unlawful.
The cybersecurity program implemented by Alira Health adheres to current industry standards and is continuously updated.
Despite all our efforts, we need your help to protect your information and prevent others from accessing your information. For this reason, we recommend you never share your activation code with anyone and that you close the application at the end of each session.
As a principle, your information will not be communicated, disclosed, or sold to third parties.
However, your information may be shared only:
Your personal information is processed in Italy, where Alira Health is headquartered, but may also be processed in countries where our employees and suppliers are based. This means that your information may be processed in other countries than your country of residence, which may not have a comparable level of protection towards personal information.
Alira Health is committed to transferring information only to countries that provide a comparable level of security.
In case Alira Health transfers your information outside your country of residence, this will be carried out in one of the ways permitted by PIPEDA, such as on the basis of a contract including the appropriate provisions necessary for the protection of such information in accordance with the applicable privacy legislation.
According to the applicable law, you have a series of rights regarding your personal information.
You may contact us if you wish to exercise the following rights:
We will reply to your requests, free of charge, as soon as possible, in compliance with applicable laws.
Please remember that information collected in the frame of the clinical trial cannot be deleted (refer to the ICF). Please be informed that if your requests are manifestly unfounded or excessive, we may charge a reasonable fee to respond to your request or we may refuse to act on the request. If we choose not to act on your request, we will notify you of the reasons behind our decision.
You have the right to make a complaint about the manner in which your personal information is being or has been processed, or about the management of a complaint you have submitted, by lodging a complaint to the Office of the Privacy Commissioner of Canada.
https://www.priv.gc.ca/en/report-a-concern/Herein we have tried to explain to you all the most important privacy aspects regarding MyReco®.
However, if you have any other questions or wish to exercise any of your rights, as described above, please contact us.
Alira Health S.r.l., Via Dante n. 14, 2021, Milano (MI), Italy.
You may contact our Information Protection Officer by e-mail at: alirahealth.dpo@mydata-trust.info
We may make changes to the App and, therefore, may need to revise this Privacy Notice where necessary. If so, we will notify you through a notice on the App home page or other appropriate means of communication.
Please remember to check this page periodically to stay informed about how Alira Health uses and protects your personal information. Your continued use of the App after we make changes is deemed to be acceptance of those changes.
MRC-APP-PN-CA English V1.0 2022-10-21