Dawn Health believes that it is very important to protect your personal information. Please read this document carefully as it contains important information about the way your data is used.
Dawn Health is a company formed under the laws of Denmark. As data controller, Dawn Health is responsible for the processing of your information. You will find relevant contact details below:
Dawn Health A/S
CVR-nr: 37683264
Sundkaj 153
2150 Copenhagen
Denmark
support@ekiva-ms.com
This Privacy Policy explains why and for what purpose Dawn Health collects and processes your personal data, whether there are other recipients of your personal data; whether your data is to be transferred to another country, and what your rights are in relation to Dawn Health’s collection, processing, and storage of your personal data.
Your privacy is important to Dawn Health, which complies with the European Union General Data Protection Regulation (hereafter “GDPR”) when processing your data, supports the protection of your privacy and respects your privacy choices. If you share personal data with Dawn Health, the data will be processed in accordance with this policy.
We encourage you to read this Privacy Policy.
Dawn Health will use your information for the purpose of providing you with access to the app and its content. This use of your information is based on the necessary performance of a contract (Article 6(1) b, GDPR), or your consent (Article 6(1) a, GDPR). As Ekiva is an app that prepares patients with multiple sclerosis (MS) for consultations with their healthcare professional, it uses health data based on your consent (Article 9(2) a, GDPR).
Dawn Health also relies on legitimate interest to secure the app and maintains its regular operation (Article 6(1) f, GDPR). Lastly, Dawn Health may need to process your information to comply with legal or regulatory obligations (Article 6(1) c, GDPR).
When the term "personal information" is used in this policy, it means information that relates to you and that allows Dawn Health to identify you, either directly or in combination with other information. Your personal information may include, for example, your name, contact information, or information about how you use our platform or how you interact with it.
Dawn Health may collect or receive your personal data in different ways, including where you provide it directly, for example via direct interactions with the app, such as completing a survey, and where monitoring is used.
When you register as a user of the application, the following personal data is collected:
Dawn Health will ask for your consent to collect the following information in connection with your usage of the app:
For the secure and regular maintenance of the app, the following information is processed:
For tracking mobile analytics and attribution, the following information is processed:
Dawn Health also processes analytics to track the performance and functionality of the app on an anonymized basis. In connection with this purpose, insights or usage analysis reports will be generated using aggregated data, so none of this data can be used to identify you.
The application may contain fields to collect notes. Please note that these are only stored within the app on your own device, meaning Dawn Health does not have access to them.
When you register your contact information on ekiva-ms.de, your name and email address are collected with your consent to send you notifications about Dawn Health’s own products and services.
Furthermore, information is collected by cookies or similar technologies when you visit the website, either automatically, or with your consent. Strictly necessary cookies are activated without user consent because these are necessary for the website to work properly and in a secure way, and therefore strictly necessary cookies are processed based on legitimate interest. All other cookies and tracking technologies not classified as strictly necessary are subject to consent from website visitors. For more information on how cookies are managed and used, please check the Cookie Policy found on ekiva-ms.de.
You may choose to share the information within the Ekiva app with your healthcare professional or any other third party. For that purpose, you can export a report of your logged data.
Dawn Health is responsible for using your information for the purposes described in this Privacy Policy. Your healthcare professional is separately responsible for using your information to provide medical treatment and care. This Privacy Policy does not apply to the use of your information by your healthcare professional. You can ask your healthcare professional about their use of your information.
Dawn Health shares your personal data with third parties to provide you with the application and to keep operations secure. Whenever possible, your data will be shared with third parties in a pseudonymized form.
Your information may be processed by Dawn Health’s personnel; affiliates and subsidiaries; independent agents or brokers and vendors; suppliers and services providers (such as identity providers, cloud providers and analytics tools); any third party to whom rights or obligations are assigned; advisors and external lawyers in the context of the sale or transfer of any part of the business or its assets, and when required by law or to respond to legal processes.
By law, these persons and organizations must protect the confidentiality and security of your information.
Certain business partners and suppliers process personal data on behalf of Dawn Health and may only process your personal data in accordance with the instructions provided by Dawn Health, and in accordance with this Privacy Policy, a signed data processing agreement, and other relevant confidentiality and security measures. These third parties may not process your personal data for their own purposes. To the extent Dawn Health discloses or transfers your personal data to these third parties, who may use your personal data for their own purposes, such disclosure or transfer will only take place if it is in accordance with applicable law, or after first obtaining your consent.
Dawn Health may also disclose other information that is not considered personal data to third parties. In this case, such information will be shared in an aggregated and anonymized form, that does not identify you or any other individuals.
Dawn Health will, as far as possible, refrain from sending personal data to countries outside the EU/EEA. However, it may be necessary in some cases, and if so, such transfers will only take place for the specific purposes mentioned above and appropriate safeguards will be in place for such transfers, such as adequacy decisions of the Commission of the European Union, Standard Contractual Clauses, or other appropriate safeguards for the transfer pursuant to Articles 46 or 47 of the GDPR.
Dawn Health will store your information for as long as necessary to fulfil the purposes described above and to comply with the retention period in accordance with applicable laws and internal policies.
When you require your account to be removed, or if you are inactive in the app for more than five years, your personal data will be deleted. It may take up to one month after the account deletion request or the completion of the five years of inactivity to complete the deletion.
Personal data provided via the website form will be deleted after six months.
For the retention period of cookies, please check our Cookie Policy.
You can easily stop all collection of information by uninstalling the app. You can use the default uninstall processes that may be available as part of your mobile device, or through the mobile app store or network. If you uninstall the app, all future collection of information through the app will cease.
Please note that if you do not request the removal of your account, your personal data will still be kept after the app is uninstalled in accordance with our retention policy.
Dawn Health has taken all necessary and appropriate measures to protect your personal data and safeguard your rights, which are listed below. The rights available to you depend on the reason for processing your information. If you want to exercise your rights, please contact Dawn Health.
You have the right to request access to personal data processed about you. Under certain circumstances, you have the right to receive personal data in a structured, commonly-used and machine-readable format, and the right to have your personal data transferred to another data controller.
You have the right to rectify personal data that you think is inaccurate. This includes correcting personal data you think is incomplete.
Under certain circumstances, you have the right to have your personal data deleted.
Under certain circumstances, you have the right to object to the processing of your personal data.
Under certain circumstances, you have the right to restrict the processing of your personal data.
When the processing of data is based on your consent, you may withdraw your consent at any time. However, please note that this does not affect Dawn Health’s processing of your personal data before you withdraw your consent.
If you wish to withdraw your consent, you can do so by deleting your account within the app itself, on the settings page.
Please note that if you withdraw your consent from the processing of your health data, Dawn Health will no longer be able to provide you with the app.
If you have any questions or want to exercise any of the above rights, you can send an email to the address below. If you have any concerns, you can address those to the Data Protection Officer. You also have the right to complain to the applicable data protection supervisory authority.
Dawn Health’s data protection is solicited by DPO Danmark. You can find DPO Danmark’s contact details below:
DPO Danmark ApS
Højbro Plads 10
DK-1200 København
E-mail address: DPO@dawnhealth.com
Website: www.dpo-danmark.dk/dpo-hotline
If you have any questions or concerns related to your rights as a data subject, you are always welcome to contact DPO Danmark who will respond on behalf of Dawn Health.
Please note that you also have the right to contact the relevant data protection authority to lodge a complaint:
Danish Datatilsynet
Borgergade 28, 5
DK-1300 Copenhagen K
Phone number: +45 33 19 32 00
E-mail address: dt@datatilsynet.dk
Website: www.datatilsynet.dk
You can find the contact details of the EU national data protection authorities on the European Data Protection Board’s website.
This Privacy Policy is updated regularly and when necessary due to changes in applicable law or to comply with the duty of transparency. It will always be published in its latest version. You will be notified of any changes to the Privacy Policy by an update as part of a general application update and on ekiva-ms.de. If the changes to this Privacy Policy are considered significant, you will be informed accordingly.