Privacy policy

PLEASE READ THIS POLICY CAREFULLY BEFORE USING COVID-19 MONITORING SERVICES.

You must be 18 years or older to use our Services.

Protecting your data, privacy and personal data (as defined under Article 4(1) of the General Data Protection Regulation (EU) 2016/679 (“GDPR”)) is very important to Lobachevsky University (“us”, “our” or “we”). It is vitally important to us that our customers (the “users”) feel secure when using our products and services.

This privacy policy (the “Privacy Policy”), sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed. Please read this Privacy Policy carefully to understand the types of data we collect from you, how we use it, the circumstances under which we will share it with third parties, and your rights in relation to your personal data.

This Privacy Policy describes our data processing when using “COVID-19 Monitoring” through our mobile application (the “App”) or simply accessing our website http://www.dpm-ageing.unn.ru/en/covid-19-monitoring/ (the “Website”) – together the “Services”.

1. Who we are

This Privacy Policy applies to any personal data processed by Lobachevsky University, 603022, Gagarin Avenue 23, Nizhny Novgorod, Russia being the data controller (as defined under Article 4(7) GDPR) of all processing activities in connection with the Services.

Questions, comments and requests regarding this Privacy Policy are welcome and should be addressed at krivonosov@itmm.unn.ru

2. General overview of the data processing

Before starting using our Services, you have to confirm that you have read our Privacy Policy carefully, and to consent us to analyzing the personal health data you supply in order to be provided with an information about COVID-19 severity.

This section aims at giving you a quick high-level overview of the data processing activities in connection with the Services we provide you.

If you wish to read in detail all the data processing activities we undertake, we advise you to read the following section 3 relating to each specific data processing activity, and sections 4 to 9 that relate to:

  • where we store your personal data (section 5),
  • when we may disclose your personal data (section 6),
  • your data subjects’ rights (section 8),

Information that you provide to us: we may collect and process personal data that you will be asked to provide when you:

  • fill in forms on our Website;
  • use our Services;
  • report a problem with our Services.

The information that we may ask you to provide includes, but is not limited to, gender, date of birth, biochemical data, and epigenetic data.

Information we collect about you: although we will not use it to identify you, we may collect the following data during each of your visits and use of our Services:

  • Usage data: technical information about your device, including device-specific information such as your hardware model, operating system version, unique device identifiers, and mobile network information; details of your visits, including the full Uniform Resource Locators (“URL”) clickstream to, through and from our Services (including date and time);
  • Analytics data: your IP address, operating system and browser type; information about which app store you downloaded our App from.

If you are using our Services on behalf of a third party, you must have obtained clear permission from the individuals whose data you provide us with before sharing that data. For the avoidance of any doubt, any reference in this Privacy Policy to “your data” shall include data about other individuals that you have provided us with.

Our Website may contain links to third-party websites. If you follow a link to any of those third-party websites, please note that they have their own privacy policies and that we do not accept any responsibility or liability for their policies or processing of your personal data. Please check these policies before you submit any personal data to such third-party websites.

3. Which personal data we may collect and process, why and for how long

3.1 When you use our Website

  • Types of data: IP address of the requesting device, date and time of access, name and URL of the requested file, website from which access is obtained (“Referrer URL”), browser used and, where applicable, your device’s operating system and the identity of your access provider.
  • Purpose of processing: We use the above data to provide you with access to our Website, ensure that the Website can establish an internet connection smoothly and is easy to use, and to analyze the system security and stability, as well as for additional administrative purposes.
  • Use justification: Legitimate interest (Article 6(1)(f)GDPR). Our legitimate interest is based on the data collection purposes listed under “Purpose of processing”. We do not use the data collected for the purpose of identifying you. You are not obliged to provide the above personal data; however, you will not be able to access the Website if such personal data are not provided.
  • Storage duration: Your data is removed after 30 days, unless any security-relevant event occurs (e.g. a DDoS attack). If there is a security-relevant event, server log files are stored until the security-relevant event has been eliminated and clarified in full.

3.2 Use of health data for statistical and research purposes

  • Types of data: age, gender, risk factors, blood test result, assessment results such as potential causes of illness symptoms, time and date of assessment, and other relevant and related health data that you may have provided us.
  • Purpose of processing: We process pseudonymized data to carry out aggregate statistics on the geographical prevalence of certain types of illness symptoms and conditions and may present such summarized statistics to our partners, always on an irreversibly anonymized basis.
  • Use justification: The processing is necessary for statistical purposes, and we only provide our partners with anonymized and summarized statistics from which the identification of a specific natural person is impossible (Article 9(2)(j) GDPR; Sec. 27 (1) BDSG). Our legitimate interest in processing data for these purposes is to support progress in medical research in line with our entrepreneurial goals which is also in the public interest to improve healthcare such as, but not limited to, analyzing the occurrence and characteristics of diseases. You may, for reasons arising from your particular situation, object to such a processing at any time by writing us here.
  • Storage duration: The storage duration of your data on the basis of which we create the statistics corresponds to the period of processing. When you request deletion of a specific case, your case data will no longer be used for this purpose. The statistics are anonymous.

3.3 Use of health data for public health purposes

  • Types of data: age, gender, risk factors, blood test result, assessment results such as potential causes of illness symptoms, time and date of assessment, and other relevant and related health data that you may have provided us.
  • Purpose of processing: We process pseudonymized data for public health purposes (as defined by GDPR recital 54) such as analyzing case data regarding public health trends, rare diseases and threats, and to identify factors that could improve public health such as finding out about the prevalence of specific conditions, the attributes of specific conditions and get insights in specific aspects of assessments.
  • Use justification: The processing is necessary for reasons of public interest in the area of public health (Article 9(2)(i) GDPR, Article 22 (1)(1)(c) BDSG). Our legitimate interest in processing data for these purposes is to support public health progress by protecting against serious cross-border threats to health.  You may, for reasons arising from your particular situation, object to such a processing at any time by writing us here.
  • Storage duration: The storage duration of your data on the basis of which we create the statistics corresponds to the period of processing. When you request deletion of a specific case, your case data will no longer be used for this purpose. The statistics are anonymous.

4. Changes to this policy

Any changes we make to our Privacy Policy in the future will be here, and you will be notified via an App notification, or by any other available means. Therefore, we encourage you to review it from time to time to stay informed about the way we collect and process your data.

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