Cambridge Cognition Limited

Privacy Policy for the CANTAB Software Application

Introduction

Cambridge Cognition Limited (“we”, “us” or “our”) respects your privacy and is committed to protecting your personal data. This privacy policy, together with our end-user licence agreement as set out for Android users in https://cambridgecognition.com/cambridge-cognition-cantab-app-android-end-user-licence-agreement/ and for Apple users in https://www.apple.com/legal/internet-services/itunes/dev/stdeula/, applies to your use of our CANTAB Software Application (“the App”). This privacy policy will (a) tell you how we look after your personal data when you use the App and (b) inform you about your privacy rights and how the law protects you.

About the App

The App has been developed by us to assess registered patients or volunteers (“Clinical Study Participants”, “you” or “your”) taking part in certain clinical studies (each a “Clinical Study”) being undertaken by an organisation or an academic institution (the “Study Administrator”). The App is only for use by Clinical Study Participants.

Please only install the App if you are a Clinical Study Participant. Before you can use the App as a Clinical Study Participant, you must activate it for a Clinical Study as instructed by a Study Administrator. The App can only be used to take part in a Clinical Study.

Controller

Cambridge Cognition Limited is the controller and responsible for your personal data in respect of the collection and processing of your personal data through your use of the App.

Contact details

If you have any questions about this privacy policy or our privacy practices, please contact us in the following ways:

Full name of legal entity: Cambridge Cognition Limited

Email address: [email protected]

Postal address: Tunbridge Court, Tunbridge Lane, Bottisham, Cambridge, CB25 9TU, UK

Please contact our Data Protection Officer (DPO) in the following way:

Email address: [email protected]

If you have any concerns about how we process your personal data, you have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK’s supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO, so please contact our DPO in the first instance using the contact details referred to above.

Changes to the Privacy Policy

We keep our privacy policy under regular review. The date of the last update can be found at the end of this document.

 

The data we collect about you

Personal data, or personal information, means any information relating to an identified or identifiable natural person (‘data subject’). An identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person. Anonymous data is information which does not relate to an identified or identifiable natural person or to personal data rendered anonymous in such a manner that the data subject is not or no longer identifiable.

We may collect, use, store, and transfer different types of personal data about you, which we have grouped together as follows:

• Identity Data includes first name and last name, date of birth and gender
• Contact Data includes email address and telephone numbers
• Technical Data includes your login data (such as your unique code as a Clinical Study Participant), browser type and versions, operating system and platform, and other technology on the device you use to access the App
• Usage Data includes information about how you use the App
• Audio Data includes recordings of your voice.

The App collects, uses, stores, and transfers the following Technical Data and Usage Data:

What information are we collecting?	How are we storing it?	What do we use it for?
A record that the App requested activation, with the associated details: the make and model of the device on which it is installed the version of the operating system installed on the device the version of the web- browser (user agent) that is installed on the device whether the App activation was successfully completed	The data is stored on third-party servers based in the US, EU or China which meet stringent standards set by the applicable regulations/legislation.	The main reason we retain a record of when you installed the App, along with some details of the device, is to better support your use of the App. It allows us to understand when you installed the App and helps us diagnose and resolve any problems quickly. In aggregate the data also allows us to understand the range of devices that Clinical Study Participants use, allowing us to better tailor our App to support and promote more effective clinical trials.
Once the App is activated we record significant events in how a Clinical Study Participant is using the App, e.g. when it was opened from a notification, when a task was administered, and any errors the App software encountered.	The data is stored on third-party servers based in the US, EU or China which meet stringent standards set by the applicable regulations/legislation.	As described above, we use this data in order to improve the App and related components of the CANTAB Connect Clinical Trials Management Platform which will support and promote more effective clinical trials.

We may also collect the following Identity Data and Contact Data:

What information are we collecting?	How are we storing it?	What do we use it for?
Any personal information you choose  to reveal to us while contacting us directly. For example, to raise a query about this privacy policy or to exercise your legal rights (see below). This may include Identity Data (such as your name) and Contact Data (such as an e-mail address and telephone number) and the nature of your query.	The information is held in our helpdesk system. The data is stored on third-party servers based in the UK and the EU which meet the standards of UK GDPR and EU GDPR.	Only for customer support purposes relating to this privacy policy and our role as controller of your personal data. We shall not relate or link your Identity Data or Contact Data to any specific Technical Data or Usage Data collected by the App.

We may also collect the following Audio Data:

What data are we collecting?	How are we storing it?	What do we use it for?
Audio recording of your voice only when administering voice tasks	The data is stored on third-party servers based in the UK, US, EU and China which meet all relevant standards.	Administrative: customer support purposes relating to this privacy policy and our role as controller of your personal data. Research: to support and conduct internal and external, academic and commercial clinical research and trials, in compliance with protocols approved by the relevant regulatory boards. Commercial: to develop and improve our tools, products, and services.

The App also collects information that is used directly for your participation in the Clinical Study. The Study Administrator is the controller and responsible for your personal data collected for the Clinical Study. Exactly what type of information is collected will depend upon the nature of the Clinical Study, but may include your responses to questionnaires or tasks (including speech tasks) that you are asked to complete within the App. Such collection of information may involve collection of personal data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, genetic and biometric data, data concerning your health or data concerning your sex life or sexual orientation (these are known as ‘Special Categories of Personal Data’). For information on the purpose(s) for which the Study Administrator as controller may process your personal data, including Special Categories of Personal Data, please read the Study Administrator’s privacy notice and raise any questions about such information with the Study Administrator.

As the App developer, and in order to protect your identity, we do not have access to your personal data collected for the Clinical Study so we are unable to assist you directly if you have any questions about any aspect of the Clinical Study and/or the privacy practices involved with the Clinical Study.

In order to protect your identity, we are also unable to provide you with technical support on your use of the App in general or use of the App within the Clinical Study. If you require technical support with the App, please contact the Study Administrator for assistance.

 

If you contact us with a technical support query about the use of the App, we will immediately direct you to the Study Administrator. Any personal information you provide to us under such circumstances, in error or otherwise, will be deleted from our systems within a reasonable timeframe once we have fulfilled our support with your query.

 

How your personal data is collected

We use different methods to collect data from and about you, including through:

• Automated technologies or interactions. As set out in the first table above, as you interact with the App, we will automatically collect Technical Data and Usage Data about your device.
• Direct interactions. As set out in the second table above, you may give us your Identity Data and/or Contact Data by corresponding with us. This includes personal data you provide when you raise a query about this privacy policy or when you wish to exercise your legal rights.

Once the App is activated, your Technical Data and Usage Data are linked to your Clinical Study Participant number for the purpose of enabling our customer support service. This allows us to know which site enrolled you into the Clinical Study and hence the physical location you are visiting in the Clinical Study (if any). This also allows us to be aware of any demographic or preferences information set up by the Study Administrator after the Study Administrator’s consultation with you (examples include gender, age, level of education, and how and when you will participate in the Clinical Study via the App). All of this information is required for the App to work as needed for the Clinical Study in which you are registered.

 

Your Clinical Study Participant number is provided to us by the Study Administrator, and it is comprised of a unique identification number for the particular Clinical Study in which you are enrolled which is not derived from any personal identifying information. For some Clinical Studies, e.g. as you progress from screening to the randomised phase of a study, the Study Administrator may provide us with more than one such Clinical Study Participant number for you.

We do not collect, process, or have access to any other personal data that the Study Administrator may store that would personally identify you (e.g. your name, address or other contact details such as email address and telephone numbers).

 

If the App requests you to provide a name when you interact with it, this name remains on the device and is not linked to the Technical Data or Usage Data we collect about you.

 

The internet protocol (IP) address of the device using the App is not retained by us. We are, therefore, unable to link your App usage back to your internet connection or service provider.

 

In cases where you have installed the App on your own device, we do not store any identifier that uniquely identifies your device.

 

How we use your personal data

We will only use your personal data when the law allows us to and in the following circumstances:

• Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
• Where we need to comply with a legal obligation.

Purposes for which we will use your personal data

We collect and process your personal data to:

• register you as a Clinical Study Participant; and
• monitor, support and improve the App and related components of the CANTAB Connect Clinical Trials Management Platform.

Basis for processing your personal data

It is necessary for our legitimate interests (and those of the Study Administrator) to process your personal data in order to monitor, develop and support the App for you and other users of the App. The processing of your personal data is proportionate to that purpose and does not override your legal rights.

 

Do you have to provide your personal data?

It is your decision whether to provide us with your personal data. If you fail to provide the Technical Data when requested, we are not able to grant you access to the App. If you fail to provide your Identity Data and/or Contact Data we may not be able to fully assist you with any query related to this privacy policy or your legal rights.

 

With whom do we share the personal data?

Study Administrator. We may share your personal data with the Study Administrator’s site staff operating the Clinical Study but only in the course of resolving a customer support query for the specific Clinical Study Participant to whom it relates.

Third parties. We may share your personal data with the persons set out below:

• Service providers such as consultants and sub-contractors who provide services in IT and system administration and help monitor, develop and support the App on our behalf.
• Third parties to whom we may choose to sell, transfer or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this Privacy Policy.

We require all third parties to respect the security and confidentiality of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

 

International transfers

Your personal data may be transferred for processing by our external third parties, some of whom may be based outside the UK.

 

We will only transfer your personal data outside of the UK (a) to countries that provide an adequate level of protection for personal data (for which see below) (b) if the transfer is subject to appropriate safeguards (as required under UK data protection law) or (c) in the absence of an adequate level of protection or appropriate safeguards being provided, if the transfer meets one of seven conditions set out under UK data protection law which permits such a transfer.

Currently all countries in the European Economic Area (“EEA”), which is comprised of all European Union member states plus Norway, Iceland and Liechtenstein, have been found to provide adequate data protection as well as Andorra, Argentina, Canada (only data that is subject to Canada’s Personal Information Protection and Electronic Documents Act (PIPEDA)), Faroe Islands, Gibraltar, Guernsey, Isle of Man, Israel, Japan (only private sector organisations), Jersey, New Zealand, Switzerland, and Uruguay.

 

Please contact us using the contact details referred to above if you want further information on how we protect your personal data when transferring your personal data outside of the UK.

 

Data security

We have put in place, and will maintain, appropriate security measures to prevent your personal data from accidental or unlawful destruction, loss, alteration, unauthorised disclosure or access. In addition, we limit access to your personal data to those of our employees, agents, contractors and other third parties who have a business need to access your personal data. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected breach of security leading to the accidental or unlawful destruction, loss, alteration, unauthorised disclosure of or access to your personal data and will notify you and any applicable supervisory authority of such a breach where we are legally required to do so.

 

How long will you use my personal data for?

We will only retain your personal data for as long as reasonably necessary to fulfil the purposes for which we collected it, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.

To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.

Your legal rights

Under certain circumstances, you have rights under data protection law in relation to your personal data.

You have the right to:

Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.

Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.

Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.

Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.

Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios:

• If you want us to establish the data’s accuracy.
• Where our use of the data is unlawful but you do not want us to erase it.
• Where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims.
• You have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.

Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.

Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain services to you. We will advise you if this is the case at the time you withdraw your consent.

If you wish to exercise any of your legal rights, please contact us using the contact details referred to above.

No fee usually required

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances.

What we may need from you

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

Time limit to respond

We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

Version: 1.3

Last updated: 7/02/2024