Effective Date: 27 July 2020
Who we are
We are Data Cubed, LLC d/b/a Datacubed Health. We can be reached at firstname.lastname@example.org and at:
15 Metrotech Center
Brooklyn, NY 11201
Datacubed Health is a pioneering technology company making better science and healthier communities a reality. We apply individualized solutions for the capture of data, including smartphone apps, wearable, in-home, and environmental sensors, for remote engagement with patients and for virtual clinical studies. In connection with the research, trials, studies, patient-engagement initiatives or projects that we conduct on behalf of companies, heath care organizations and educational institutions (“Studies”), we sometimes collect information from children under the age of 13 or from parents or legal guardians (“Caregivers”) about their children and/or patients who are under the age of 13. References to “we,” “us” and “our” mean Datacubed Health. References to “third-party” mean someone who is not you or us.
Who you are
In the Policy, you means you as a:
- Client – an employee or a representative of a business that uses Datacubed Health
- Client Participant – an individual solicited by a business who participates in a Study conducted by Datacubed Health on behalf of the business and who may be a child under the age of 13
- Datacubed Health Participant – an individual who participates in a Study conducted by Datacubed Health on its own behalf and who may be a child under the age of 13
Legal basis for collecting children’s information
- We do not collect personal information from children below the age of 13 without the consent of a Caregiver except in special, limited circumstances
What information do we collect about children and why?
To provide the Services, we may collect information about children from their Caregivers, or we may collect personal information directly from children. On behalf of our Clients, to conduct the Studies, we may collect a child’s:
- Name and date of birth
- Demographic information (ethnicity, gender, height and weight)
- Medical condition
- Medication dosage and/or dosage change details
- Medication injection site and injection date details
- Survey information for Health, Economics and Outcomes Research (HEOR) Study
Caregivers may ask us to stop collecting personal information from their child by emailing us at email@example.com; however, in such cases, the Client Participant and the Datacubed Health Participant will not be able to continue participating in any Study we are conducting on behalf of a Client or ourselves. If Caregivers direct us to stop collecting and using children’s personal information, we must disable the Client Participant’s and the Datacubed Health Participant’s use of our devices to so no information is collected.
How we use children’s information
We use personal information collected from children or from Caregivers about children for the following purposes:
- To conduct Studies on behalf of our Clients or on our own behalf;
- To provide the Services;
- To respond to customer service and technical support issues and requests.
We may use aggregate or de-identified information about children for research, analysis and similar purposes to improve the Services. When we do so, we strip out names, email addresses, contact information and other personal identifiers. We may use aggregate or de-identified information for the following purposes:
- To conduct research or analysis including research and analysis by Client;
- To better understand how our devices are accessed and used; and
- To improve our devices and respond to user preferences.
How we share children’s information
We do not sell children’s information, and children may not make their personal information public through the Services. We only share Client Participant personal information with the Client on whose behalf we are collecting the personal information, to otherwise provide the Services, to conduct the Studies, to comply with the law and to protect our and other users of the Services. For example, we may share children’s personal information as follows:
- Service Providers. We may share the information we collect from children with our business associates, consultants, service providers, advisors, and affiliates, contractors, or agents on a confidential basis in order for them to provide services to us, to you and to enable us to provide the Services and to conduct the Studies. For example, our host and internet service provider may have access to some of this information.
- Business Transfers. We may transfer your information to a successor in interest, which may include but may not be limited to a third-party in the event of an acquisition, sale, asset sale, merger or bankruptcy. The policies applicable to your information thereafter may be determined by the transferee, unless otherwise prohibited by law.
- In Response to Legal Process. We also may share personal information with government and/or law enforcement agencies to the extent we believe it necessary to comply with the law, such as in response to a subpoena or court order, to defend a legal claim or establish or protect our legal rights or otherwise as permitted by applicable law.
- To Protect Us and Others. We may disclose personal information in our possession in the event we believe it necessary or appropriate to prevent criminal activity, personal injury, property damage or bodily harm.
- With Caregivers. Caregivers may request information about the information we have collected from their child by contacting us at firstname.lastname@example.org.
- Aggregate and De-identified Information. We may also use and share aggregate or de-identified information with third parties
Caregivers’ rights to review, delete and control our use of children’s information
Caregivers have the right to review the information we have collected about their children and to have their children’s personal information deleted and can refuse to permit the further collection or use of their children’s information. To exercise these rights, you may contact us at email@example.com. You will be required to authenticate yourself as the child’s Caregiver to receive information about that child. Copies of information may remain in cached or archived form in our system after its deletion is requested.
How we protect children’s privacy
When we intend to collect personal information about children, we take additional steps to protect children’s privacy, including:
- Asking for a Caregiver email address in any instance where we ask for age and determine the user is under age 13 before collecting any personal information from the child on any child-targeted device or application;
- If we wish to collect personal information from a child, seeking a Caregiver’s consent by email, explaining what information we are collecting, how we plan to use it, how the Caregiver can provide consent, and how the Caregiver can revoke consent;
- In connection with the Services or the Studies, collecting a child’s online contact information (e.g. email address) in order to communicate with the child and simultaneously requiring a Caregiver email address in order to notify the Caregiver about the collection and use of the child’s information and to provide the Caregiver an opportunity to prevent further contact with the child;
- In connection with push notifications (notifications on mobile and other devices), obtaining a Caregiver email address and providing the Caregiver with notice of our interest in contacting the child and providing the Caregiver with the opportunity to prevent contact before the child can receive push notifications;
- If the device collects geo-location information that is specific enough to equate to the collection of a street address or if in using the Services persistent identifiers (e.g. cookies) collect information to make the Services more useful (e.g. type of computer operating system, IP address, mobile device identifier, web browser), notifying Caregivers and obtaining Caregiver consent prior to such collection;
- Notifying Caregivers about our practices with regard to children, including the types of information we may collect from children, the uses to which we may put that information, and whether and with whom we may share that information;
- Obtaining consent from Caregivers for the collection of personal information from their children or for providing information about the Services and the Studies directly to their children;
- Limiting our collection of personal information from children to no more than is reasonably necessary to participate in the Services and the Studies;
- Giving Caregivers access or the ability to request access to personal information we have collected from their children and the ability to request that the personal information be changed or deleted.
Changes to this policy
This policy is current as of the Effective Date set forth above. We may change this policy from time to time, so be sure to check back periodically. We will post any changes to this policy on our site at www.datacubed.com.