Binnovate Digital Health B.V. The Netherlands,
Binnovate Digital Health US., Inc. USA,
Updated 29 January 2021
Binnovate offers a range of products and services focused on helping users learn how to manage their Chronic Kidney Disease. They include the RenalTracker Program and other related products. The RenalTracker Program includes an online learning module, coach chat functionality, and digital renal dieting support tools (all collectively “Services”). Your data is necessary for us to provide the Services.
The prime purpose of collecting and using your data is to allow us to properly measure your learning progress and create a more personalized self-management experience. The use of your collected personal data is necessary for Binnovate to deliver Services that involve analyzing and evaluating your current experience with the Services. We do not and will not sell your data to third parties.
Why we process your personal data and the legal basis for processing
We process your personal data only if you consent to this processing for purposes of providing you the RenalTracker program.
Under certain laws we are required to state the legal basis for processing your personal data and special category data. We process your personal data on the legal basis that processing is required to provide you with the RenalTracker program and that processing is required to comply with our legal obligations. We rely on your consent to process any health data that is classified as a special category of personal data.
How We Collect and Use Personal Data
Binnovate collects data to operate effectively and provide you with the appropriate advice and recommendations to follow according to the general clinical guidelines in the daily management of CKD. You have the option to decline when asked to provide personal data. But if you elect not to provide data that is necessary to a product or service feature, you may not be able to use all Services products or features given the provided information is necessary for us to perform certain critical Services tasks and to support Services features.
Binnovate does not sell your data to advertisers, nor does it use what you provide in your health profile, answers to questionnaires, or other interactions to target external ads to you. We use the data through our interactions with you to personalize education/diet advice and insights along with recommendations of relevant Services that may help you learn about CKD management based on analysis of your collected learning/profile data.
We use collected data to continually improve our product and services including adding new features and enhancing accuracy of the platform. For example, we use learning data and demographics to improve the relevancy of the CKD education advice, insights and recommendations we provide by training models and algorithms.
The data we collect varies based on your interactions with Binnovate, and your selections regarding various Services product settings and the specific product and features you may utilize. The following are a list of the categories of data we collect:
Personal Contact Data, Credentials and Protected classified information
Data We Collect: Basic account data that includes your first and last name, phone number, email, IP address, postal address, username and password. This may also include preferred language. All of our databases are encrypted, additionally within the database certain identifiers including your name, password and email address are all further encrypted so administrative staff cannot view them to help safeguard against a data breach. If access to this information is required for a customer service request, consent will first be requested of the user.
Why: We collect this information to authenticate, secure and provide you with access to our Services. We also use this information to communicate with you as to your account, learning progress, news and other information that may be pertinent to you which you may opt out of.
In the case where you communicate interest in being connected with a local healthcare provider, we will forward (with your written permission) your first and last name, phone number, and email to them. Our partner healthcare providers are Nephrology that provide services in the area from which the personal information was collected.
Personal Nutrition Data:
Data We Collect: In order for your coach to specify which nutrients to restrict with the food checker, during onboarding you are asked to send a message discussing your relevant lab results. Under Settings, you are also recommended to input your medical comorbidities, food allergens, and lifestyle habits.
Why: While there are general nutrition guidelines, more personalised advice can be more effective in helping you make kidney-friendlier choices.
During a coaching call or chat, your Coach has access to the info you provided in your profile. This info is needed to give you more relevant recommendations based on your situation.
The ingredient checker displays information based on default nutrient restrictions upon account creation. To get personally relevant information on an ingredient, these nutrient restrictions should be based on the lab results provided to the coach. The coach is then able to specify these nutrient restrictions for your account.
Kidney Function Data:
Data We Collect: You have the option to input your GFR readings based on your lab results.
Why: Keeping track of your GFR, an indicator of how well your kidneys are filtering, helps you and your coach determine what progress has been made over time.
Blood Pressure Data:
Data We Collect: If you set up and enable a connection between your Withings BPM, your Withings Accounts, and the RenalTracker App, we are able to display your Blood Pressure readings on your RenalTracker profile. If you do not have a Withings BPM can also choose to manually input your Blood Pressure readings in the App.
Why: Combined with your GFR and personal nutrition data, your blood pressure helps you and your coach understand what progress has been made over time.
Data We Collect: Through questionnaires pre-/during/post-program, we may ask you questions relating to your CKD management knowledge and your beliefs about your ability to manage CKD. This information may include quizzes, assignments, surveys, reflections prompts, and other related information pertaining to your daily management of your CKD.
Why: We collect information regarding your perceived ability to manage your condition in order to match your profile to the learning modules.
Data We Collect: Data about your device and how you and your device interacts with Binnovate and our products and services can be necessary to provide you a more personalized experience.
Technical Information: We collect information from your browser, computer, or mobile device when you access or use our Products and Services, such as browsing history and search history within our sites. This information includes device and network information, cookies, log files and analytics information which we use to increase our ability to improve our services.
Customer Service / Troubleshooting: When you engage with customer service, we collect data about you, your device, software, app, and other details related to the issue. When you contact us for customer support, any phone conversations, email correspondences or chat sessions with our representatives may be monitored and recorded. These may also include error and performance reports used to help customer support in identifying potential issues.
Why: We use data to improve customer service and efficient troubleshooting of potential user issues. We use data to develop aggregated analysis and business intelligence to enable us to operate, improve, make informed decisions, secure, and report on performance of the business.
Data We Collect: We collect content that you may share with Binnovate which may include posts, feedback, reviews, files, questions, information, or comments through your social media, learning course discussions, customer service including your coach, or the community.
Why: We may use data we collect at an aggregated level (no personal identifiers included) to gain new insights into CKD management which may be used by the company or its partners to improve the overall state of CKD management and patient engagement. Such insights may be published from time to time. All data will have any personal identifiers removed. This information is a valuable contributor toward accurate CKD management and patient engagement as scientific insights gained from this information can be used to continually improve Binnovate’s products and services.
Reasons We Share Personal Data
We only share your personal data with your consent or as necessary to complete any transaction or provide any product or service you have requested or authorized. For example, you may wish to share your blood pressure data with a connected third-party partner, which can occur only with your consent.
When you provide payment data to make a purchase, we or authorized agents of the company share payment data with banks and other entities that process payment transactions or provide other financial services, and for fraud prevention and credit risk reduction.
We share personal data with subsidiaries, vendors, partners or agents working on our behalf for the purposes described in this statement to provide our Service. An example being we use 3rd parties for cloud hosting of data and customer service support. These companies must follow our data privacy and security requirements and are not allowed to use personal data they receive from us for any other purpose.
We may share your information with third parties who provide services to Binnovate such as supporting and improving the Services, promoting the Services, processing payments, or fulfilling orders. These service providers will only have access to the information necessary to perform these limited functions on our behalf and are required to protect and secure your information. We may also engage service providers to collect information about your use of the Services over time on our behalf so that we or they may promote Binnovate or display information that may be relevant to your interests on the Services or other websites or services. Binnovate is not responsible for the terms or policies of third parties.
Subject to your privacy settings, your information and content may be publicly accessible should you authorize that, which is your choice.
We may preserve and share your information with third parties, including law enforcement, public or governmental agencies, or private litigants, within or outside your country of residence, if we determine that such disclosure is reasonably necessary to comply with the law, including response to court orders, warrants, subpoenas, or other legal or regulatory process. We may also retain, preserve or disclose your information if we determine that disclosure is reasonably necessary or appropriate to prevent any person from death or serious bodily injury, to address issues of national security or other issues of public importance, to prevent or detect violations of our Terms of Service or fraud or abuse of Binnovate or its members, or to protect our operations or our property or other legal rights, including by disclosure to our legal counsel and other consultants and third parties in connection with actual or potential litigation.
We may share your information with third parties when we forward Digital Millennium Copyright Act (DMCA) notifications, which will be forwarded as submitted to us without any deletions.
Please note some of our products and services include links to those of third parties whose privacy policies differ from Binnovate. Additionally, through affiliate product or service recommendations, you may elect to select links to partner sites whose privacy policies differ from Binnovate. Should you provide personal data to any of those products and services or partners, your data shall be governed by their respective privacy policies. We are not responsible for third-party practices or policy terms.
We may also have to disclose personal data necessary to:
- Protect our customers security, or to prevent the loss of life or severe injury
- Operate and maintaining the security of our products which include internal and 3rd party computer systems and networks vital to the operation of our products;
- Protecting the rights or property of Binnovate, including enforcing the terms governing use of the services.
While Binnovate continues to work hard to protect your personal information, no data transmission over the Internet can be guaranteed to be absolutely secure, and Binnovate cannot ensure or warrant the security of any information you transmit to Binnovate. Transmitting personal information is done at your own risk.
To learn more please also refer to the Binnovate Terms & Condition document.
Access and Control of Your Personal Data
You can view and manage your data via the respective Binnovate app or website portal based on the product you are using to view and manage your data. For example, you can view and update your profile data, user settings, and view messages exchanged with your coach.
Deleting Information and Accounts
You may request that your account is deleted by contacting the company at firstname.lastname@example.org or by phone at +1 888 207 0580. Once deleted, your data, including your account, activities and messages cannot be reinstated.
Note that content you have shared with others or that others have copied may also remain visible after you have deleted your account or deleted the information from your own profile. Your public profile may be displayed in search engine results until the search engine refreshes its cache.
Access and Porting
You can access much of your information by logging into your account. If you require additional access or if you are not a Binnovate member, contact us at email@example.com or by phone at +1 888 207 0580.
Rectify, Restrict, Limit, Delete Requests
You can also rectify, restrict, limit or delete much of your information by logging into your account. If you are unable to do this, please contact us at firstname.lastname@example.org. Binnovate will generally respond to your request within thirty (30) days or less.
Where we process your information based on our legitimate interests explained above, or in the public interest, you can object to this processing in certain circumstances. In such cases, we will cease processing your information unless we have compelling legitimate grounds to continue processing or where it is needed for legal reasons.
Where you have previously provided your consent, such as to permit us to process health-related data about you, you have the right to revoke or withdraw your consent to the processing of your information at any time. For example, you can revoke or withdraw your consent by updating your settings. In certain cases, we may continue to process your information after you have withdrawn consent if we have a legal basis to do so or if your withdrawal of consent was limited to certain processing activities.
Should you wish to raise a concern about our use of your information (and without prejudice to any other rights you may have), you have the right to do so with your local supervisory authority.
Retention of Information
Information about you that is no longer necessary and relevant to provide our Services may be de-identified and aggregated with other non-personal data to provide insights which are commercially valuable to Binnovate, such as statistics of the use of the Services. This information will be de-associated with your name and other identifiers.
Should you delete your Binnovate Account, aggregate de-identified product data may be retained in our database for use in Services product maintenance and improvements, and to otherwise advance CKD self-management analytics.
When you submit personally identifiable information to us through the Registration Pages as part of the Service, you may be given an opportunity to opt in to receiving additional information from or on behalf of Binnovate entities as part of the Service and otherwise, including notifications and program tips forwarded by parties providing the Service App, and/or selected third parties at the time of submitting your personally identifiable information to us. By using our product, you have opted in to be added to our list of users who will receive promotional and marketing communications from us, our partners and/or other third parties. You can opt out of sharing information with us by contacting us at email@example.com.
You can opt out of receiving products and services recommendations by discontinuing use of our product and/or Service or communicating a request to opt-out of receiving that information from us. If you discontinue your use of our product and/or the Service for a period of ninety days or more, we may require you to re-register or otherwise stop communicating with you electronically.
If you cannot access, edit or delete your personal data collected by Binnovate using the mechanisms above or directly using the products, apps, website, or related interfaces you can always contact Binnovate Customer Support via firstname.lastname@example.org. You can cancel your account at any time as well by contacting Customer Support. We will work to respond to requests to access, edit or delete your personal data within 30 days.
How can you exercise your rights provided under the CCPA?
Under the CCPA, Californians have the following rights, we extend these rights to all US users:
Right to Know:
You have the right to request that we disclose to you the Personal Information we collect, use, or disclose, and information about our data practices;
Right to Request Deletion:
You have the right to request that we delete your Personal Information that we have collected from you;
Right to Non-Discrimination:
We will not discriminate against you for exercising any of these rights.
To exercise your “right to know” or your “right to request deletion,” contact us by email on email@example.com or by phone at +1 888 207 0580.
Cookies and Similar Technologies
- Sign-in and Authentication: When you sign into the Application or Website using your Binnovate account, we store a unique code in an encrypted cookie on your device. This will allow you the ability to access without having to sign in each time you use the Application or Website.
- Storing Preferences and Settings: Allowing you to save preferences and settings so that you do not have to be reset each time you use the Application or Website.
- Security: Utilizing cookies to detect fraud and abuse of our Applications, Websites and services.
- Social Media: To provide ability to share content on social media we may include social media cookies to provide such a service feature.
In addition to the cookies and other similar technologies Binnovate sets when you visit our Application and Website properties, third parties may also set cookies when you visit our sites which in many cases are parties we have hired to provide services on our behalf including site performance analytics or content. In such cases you may be connected to those third-party servers to retrieve that content or services and they may be able to set or read their own cookies on your device and collect information about your online activities.
To help us monitor site performance analytics we use web beacons or similar technologies from third-party analytics providers. These technologies enable the analytics providers to set or read their own cookies or other identifiers on your device, through which they can collect information about your online activities across applications, websites or other products. However, we prohibit these analytics providers from using web beacons on our sites to collect or access information that directly identifies you (such as your name or email address). You can opt out of data collection or use by some of these analytics providers by clicking the following links:
- Google Analytics: tools.google.com/dlpage/gaoptout (requires you to install a browser add-on)
- Mixpanel: https://help.mixpanel.com/hc/en-us/articles/360001113426-Opt-Out-of-Tracking
Other Important Privacy Information
Below, you will find additional privacy information you may find important. Should you have any questions please contact us at Customer Support at firstname.lastname@example.org.
Security of Personal Data
Binnovate is committed to protecting the security of your collected personal data. We use a variety of security technologies and procedures to help protect your personal data from unauthorized access, use or disclosure. For example, we store the personal data you provide encrypted and on computer systems that have limited access and are in controlled facilities.
Collection of Data from Children
We do not intend to market to or interact with, or secure any User Data from, children sixteen (16) years old or younger. Our Service is not by design reasonably likely to attract children sixteen (16) years old or younger to purchase or otherwise use our Service.
You must be over the age of eighteen (18) to create an account and use our Service.
If you are a minor and wish to utilize our product or the Service, your parents or legal guardians (hereafter your “Parents”) must engage in purchasing the product or Service and additionally if you are over eighteen (18) years old give us their written consent by contacting our customer service department. Our teams will answer any questions that you or your Parents may have concerning the use of our products and services and the rules relating to the collection of personal data.
Personal Data Breach Response
Should a data breach occur the company shall announce breach response for affected users within seventy-two (72) hours of such an event.
Retention of Personal Data
Binnovate retains personal data for as long as necessary to provide the products and fulfill the transactions you have requested or for other essential purposes such as complying within our legal obligations, resolving disputes, financial records and enforcing our agreements. Because these needs may vary for different data types in the context of different products the retention period may vary significantly.
- How long is personal data needed to operate our Products and Services? Apart from where the law stipulates a specific period, we retain your User Data for a period not exceeding the period required for the purposes for which it was collected and processed. But general formation from the system after 7 years of inactivity or as local legal requirements dictate.
- What is the duration by which personal data is deleted? Upon confirmation personal data, not necessary for legal, contractual, or similar obligation will remain on our system for up to 30 days before final deletion. Aggregate product usage data with Personal Identifiable Information removed will still be retained in our database for use in product maintenance and improvements and sleep science analytics.
- Is Binnovate subject to a legal, contractual, or similar obligation to retain the data? Situations including mandatory data retention laws in the applicable jurisdiction, government orders to preserve data relevant to an investigation, or data that must be retained for the purposes of litigation may result in varying retention periods.
Self-Management Intervention Study or Beta Releases
From time to time, Binnovate may offer opportunities to participate in CKD self-management intervention studies or access to beta products and features. As a result, these may change the data collected and the user experience that employ different privacy and security measures from those typically present in our products. If you participate in such a study or beta release you may need to enter into a different agreement for access.
Where We Store and Process Personal Data
Personal data collected by Binnovate is stored and processed in the United States and accessed by authorized users for support in regions where Binnovate or its affiliates or service providers maintain facilities.
Email, name and basic sleep data is shared with a communication platform to send updates from Binnovate.
How to Contact Us
If you have any technical or support questions, please contact us at email@example.com.
If you have any privacy concerns, complaints or inquiries for the Data Protection Officer of Binnovate, Chloe Tuvilla, please contact us via email at firstname.lastname@example.org.
Unless otherwise stated, Binnovate Digital Health BV is a data controller for personal data we collect through products and services subject to this statement. Our address is at:
Binnovate Digital Health BV
6534 AT Nijmegen
Note: The Services (including the App and related self-management curriculum and product recommendations) do not constitute a medical device or the practice of medicine. If you are seeking information on how to diagnose and/or treat CKD, you should consult with your healthcare professional.