OMRON HYPERTENSION Plus PRIVACY STATEMENT

Version 1.0 – December 2020

This OMRON Hypertension Plus Privacy Statement (together with the OMRON Hypertension Plus Terms of Use applies to your use of:

  • Mobile application software ‘OMRON Hypertension Plus’ and any updates or supplements to it (“App”), once you have downloaded copy of OMRON Hypertension Plus onto your smartphone or other handheld device (“Device”).

Your doctor is using Omron Hypertension Plus dashboard (the ‘Dashboard’) and has invited you to use the App. In particular, you will be asked to enter certain personal data in the App which, in combination with the data entered by your doctor in the Dashboard (with may include your medical records), will allow the App to suggest to your doctor decisions regarding your medication plan. Those decisions are based on Omron’s patient management algorithm and will be shared with your doctor in the Dashboard as specific actions that your doctor can follow.

This privacy statement sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us. Please read the following carefully to understand our views and practices regarding your personal data and how we will process it.

For the purpose of applicable European data protection legislation, the data controller is Omron Healthcare Co., Ltd (“Omron”) based in Japan. Omron Healthcare Europe B.V. is Omron’s representative in the EU and shall serve as point of contact for EU data subjects and Data Protection Authorities.

Information we may collect from you

We collect and process the following data about you:

1. Information that has been entered by you in the App or by your doctor in the Dashboard (which may include data from your medical record). This information may include:

  • Your name, NHS Number ,phone and e-mail address (“Contact Information”).
  • Your, gender and date of birth (“User Profile Information”).
  • Your blood pressure, pulse (“Measurement Information”).
  • Information to set your treatment plan and the treatment plan itself, including your current and past use of medications when relevant, pregnancy state, ethnicity, data from your medical history relevant to achieve the purpose of the App (e.g. heart failure, postural hypertension), data from your responses to the health surveys (e.g. activity levels, eating and lifestyle habits) and medication intolerances (“Treatment Information”).

2. Information that you give us if you contact us for support, in which case we will keep a record of that correspondence. This information may include:

  • your name and e-mail address (“Contact Information”)
  • your date of birth (“User Profile Information”)
  • the model of Device you use, your mobile operation system, number and type of registered Omron health devices, storage capacity and available storage information of the Device, application error log and your region (“Technical Information”).

3. Details of your use of the app including, but not limited to traffic data, application usage data and other communication data (“Log Information”).

How we use your information

We use information held about you in the following ways:

For the performance of our agreement with you

  • Contact Information: to handle your enquiries and to operate the service 
  • User Profile Information: to operate the App, to handle your enquiries.
  • Technical Information: to handle your enquiries.
  • Log Information: to handle your enquiries

For our legitimate commercial interests

  • Contact Information: to handle your enquiries
  • Measurement Information and Treatment Information: to develop or improve our products and services and to analyse anonymized, aggregated data to understand usage trends and health data trends.
  • User Profile Information: to ask you to fill in questionnaires, to develop or improve our products and services, to provide healthy lifestyle advice or promotional information, and to analyze anonymized , aggregated data to understand usage trends and health data trends
  • Log Information: to develop and improve our products and services.

Following your explicit consent: 

  • Contact Information: to inform you of products and/or services we offer, to ask you to fill in questionnaires, to develop or improve our products and services.
  • Measurement Information: to operate the App/Service, to handle your enquiries and to share with your doctor
  • Treatment Information: to operate the App/Service, to handle your enquiries and to share with your doctor.

How to cancel your account

You may request to cancel your account by using the ‘cancel account’ function within the App, by contacting the support service by using the ‘contact us’ function within the App or by sending an email with such request [e-mail].

Upon receipt of your cancellation request, we will process your request within 14 calendar days. We will confirm cancellation of your account within 30 calendar days of your request. When your account is cancelled, your User Profile Information and Contact Information is deleted. As a result, your information is anonymized and cannot be linked back to you.

Disclosure of your information

We may disclose the data we collect from you to the following third parties:

Category of data Recipient Purpose
Log information
User Profile Information
Google Firebase

Google Cloud Platform

Google Data Studio

Omron Software Co. Ltd.

Omron Healthcare Europe B.V.

Application usage analytics
Contact Information
User Profile Information
Measurement Information
Treatment Information
The Dashboard that will be accessible by the doctor that invited you to hypertension plus and their nominated representatives / affiliates

Omron Healthcare Europe B.V.

To perform the hypertension plus service
Contact Information
User Profile Information
Measurement InformationTreatment information
Amazon Web Services Data storage
Technical Information
Contact Information
User Profile Information
Measurement Information
Treatment information
Omron Healthcare Europe B.V.

Omron Software Co. Ltd.

Customer support
Technical Information
Contact Information
User Profile Information
Measurement Information
Treatment Information
Omron Healthcare Europe B.V. Data analysis and marketing

We may disclose your personal information to (other) third parties:

  • In the event that we sell or buy any business or assets, in which case we may disclose your personal data to the seller or buyer of such business or assets.
  • If we are under a duty to disclose or share your personal data in order to comply with any legal or regulatory obligation or request.
  • In order to enforce or apply the OMRON Hypertension Plus Terms of Use [link] or to investigate potential breaches; or 
  • In order to protect the rights, property or safety of OMRON, our customers, or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection.

Transfer of your information outside the EEA

The data that we collect from you will be transferred to, and stored at, a destination inside the European Economic Area (“EEA”). Your personal data may also be transferred to and used in countries outside the EEA for the purposes described in this privacy statement. Such countries may not have the same level of protection for your information as the country in which you reside. OMRON guarantees that all such data transfers are in accordance with applicable privacy legislation. OMRON will enter into ‘Model Clauses’ with entities in such countries. Model Clauses are standardized contractual clauses used in agreements between data controllers (such as OMRON) and their data processors to ensure that any personal data leaving the EEA will be transferred in compliance with EU data protection law and meet the mandatory requirements.

Security measures

When we act as data controller, we have implemented technical and organizational measures to protect your information against unauthorized access, use and disclosure. All information you provide to us is stored on secure servers. Any data transfer will be encrypted using Secured Sockets Layer technology. Where we have given you (or where you have chosen) a password that enables you to access the App, you are responsible for keeping this password confidential. We ask you not to share a password with anyone including support staff.

Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to the App; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to prevent unauthorised access.

Retention of your information

We will retain your information unless you request us to cancel your account or until we cancelled your account due to inactivity. We will consider your account ‘inactive’ if you don’t use the App during a two-year period. Before your account becomes inactive, we will notify you by email requesting you to use the App to prevent your account becoming inactive. We will cancel your account within 31 calendar days of it becoming inactive at which time your User Profile Information will be deleted. As a result, we will only keep your information if it is anonymized in a way that it cannot be linked back to you.

Your rights

Based on European data protection legislation you have several rights with regards to our processing of your personal data, including:

  • Right of access. You may ask us for confirmation as to whether we process your personal data. If so, we will grant you access to that personal data and provide you with a copy of the data upon request.
  • Right of rectification. If you discover errors in the personal data that is being processed by us, you have the right of rectification. Likewise, you have the right to complete the data if incomplete. Please contact our customer service.
  • Right to erasure. You may ask us for erasure of your personal data. Please contact our customer service.
  • Right to restrict. If you want to restrict processing, you cannot continue to use the App. Please refer to the process described in section ‘How to cancel your account’.
  • Right to withdraw consent. If you want to withdraw your consent to our processing of your personal data, you cannot continue to use the App. Please refer to the process described in section ‘How to cancel your account’.
  • Right to data portability. If you want to export your data, you can contact our customer service.
  • Right to lodge a complaint. In case you may have a question or complaint about how we process your personal data, you may contact us as described in the ‘Contact’ section. Alternatively, you may consider lodging a complaint with a supervisory data protection authority

Partners

The App may contain links to and from our partners and affiliates. If you follow any of these links, please note that they have their own privacy policies and that we do not accept any responsibility or liability for these policies or for any personal data that may be collected by them. Please check their policies before you submit any personal data to them.

Changes to privacy statement

Any changes we may make to our privacy statement in the future will be notified to you when you next start the App. We will ask you to read and accept any such changes to the privacy statement. If you choose to not accept these changes, you cannot continue to use the App.

Contact

If you have any concerns, questions, comments or requests about this document or the App, you can contact us through our representative in the EU via email to [],the ‘contact us’ function within the App, or by regular mail to:

Omron Healthcare Europe B.V., Marketing and Communication Department
Scorpius 33
2132LR Hoofddorp
The Netherlands

Omron Healthcare Co., Ltd.
53 Kunotsubo, Terado-cho, Muko, Kyoto
Japan

Further information can also be found on [link].