Privacy Policy

This Privacy Policy applies to your use of the OsteoApp mobile device application (the “App”) operated by Atnahs Pharma UK Limited (“Atnahs”, “we” or “us”). Atnahs is committed to protecting and respecting your privacy and this Privacy Policy explains how we will handle any personal information that you provide to us or that we collect from you in connection with your use of the App and the rights you have under data protection law. Atnahs is the data controller of your personal information collected via or in connection with the App. If you do not agree to the terms of this Privacy Policy, please do not use the App.

Our App is not intended for children and we do not knowingly collect data relating to children.

If you have any questions in relation to this Privacy Notice or Atnahs’ handling of your information please get in touch using the contact details outlined at the end of this Notice.

1. Information we may collect from you through the App

We collect information which you provide to us directly and information related to your use of the App. For example, we use cookies or other online tracking technologies to collect information automatically about your use of the App, see our Cookies Policy for more information.

We will also collect information you provide to us directly when you register and create a profile with us. The categories of Personal Data we may collect, therefore, include the following:

• Identity Data includes first name, maiden name, last name, username or similar identifier, marital status, title, date of birth and gender.
• Contact Data includes email address and telephone numbers.
• Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access this App.
• Profile Data includes your username and password, your interests, preferences, feedback and survey responses.
• Usage Data includes information about how you use our App and services.

We also collect some Special Categories of Personal Data which you share with us when you register. This includes Medical Data such as:

• The medication you take (Bonviva)
• The date you take your medication
• The date of your prescriptions
• How often your take your medication

We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific App feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy policy.

2. How do we use your information?

Depending on how you use our App, your interactions with us and the reasons for which you provide your information, we will use your personal information for the following purposes:

• Supplying our services to or otherwise doing business with you;
• To customise and personalise the content for example we will use your medication information to send you reminders on when to take your medication and reorder your prescription;
• To help diagnose problems with our servers and to make our service more useful;
• Performing our obligations under a contract with you,
• Managing our relationship with you;
• Operating and administering our business;
• Fraud prevention, legal and regulatory compliance;
• General communication- We will send emails or other communications regarding general adherence information, Service maintenance, updates, or changes to this Privacy Policy or any other relevant agreements;
• Information collected automatically using cookies and other tracking technologies, such as details of the web pages you have visited from on our App and the content that you access.

As we collect some Special Category of Personal Data from you, we rely on you providing your consent as a legal basis for processing your personal data. Where we need to obtain your consent, and you fail to provide that when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with services). In this case, we may have to cancel a service you have with us including access to the App, but we will notify you if this is the case at the time. You have the right to withdraw such consent at any time by unticking the ‘I consent to share my medical data’ box in the App within Personal Details. .

3. Purposes for which we will use your personal data

We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.

Purpose/Activity	Type of data	Lawful basis for processing including basis of legitimate interest
To register you as a new customer	(a) Identity (b) Contact (c) Medical Data	Performance of a contract with you and your specific consent in relation to Medical Data.
To manage our relationship with you which will include: (a) Notifying you about changes to our terms or privacy policy (b) Asking you to leave a review or take a survey	(a) Identity (b) Contact (c) Profile (d) Communications	(a) Performance of a contract with you (b) Necessary to comply with a legal obligation (c) Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services)
To administer and protect our business and this App (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)	(a) Identity (b) Contact (c) Technical	(a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise) (b) Necessary to comply with a legal obligation
To use data analytics to improve our App, products/services, marketing, customer relationships and experiences	(a) Technical (b) Usage	Necessary for our legitimate interests (to define types of customers for our products and services, to keep our App updated and relevant, to develop our business and to inform our marketing strategy)

Cookies

You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this App may become inaccessible or not function properly. For more information about the cookies we use, please see our Cookies Policy. You can activate and/or deactivate usage data in the App Personal Details.

Change of purpose

We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.

If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so or obtain your explicit consent.

Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

Disclosure of your Personal Data

We may share your personal data with a company called Lean-Production Limited (a company registered in England and Wales with company number 07476526 with its registered office at Suite 2 First Floor, Braywick House West, Windsor Road, Maidenhead, Berkshire, United Kingdom, SL6 1DN) for the purposes set out in the table above as Lean-Production Limited host the server for this App on our behalf.

We require all third parties to respect the security 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.

Storing your personal information

We only keep your personal information for as long as necessary to meet legal, regulatory and business requirements. You have certain rights to have your personal information erased or corrected (see section 6 below). Please inform us if you believe we hold inaccurate personal information about you.

The security of personal information regarding you is a high priority. We take such steps as are reasonable to securely store personal information regarding you so that it is protected from unauthorised use or access, misuse, loss, modification or unauthorised disclosure. This includes both physical and electronic security measures. Examples include the use of passwords, locked storage cabinets and secured storage rooms. Other features include:

• storing information on secured networks consistent with industry standards, which are only accessible by those employees who have special access rights to such systems;
• using industry-standard encryption technologies when transferring or receiving personal information, such as SSL technology;
• restrictions are placed on the electronic transfer of files; and
• our IT networks undergo necessary vulnerability testing to continually identify and remediate potential opportunities for unauthorised data access.

We will keep your personal information for as long as we need it for the purposes set out above. This period will vary depending on the nature of your interactions with us.  Where we no longer have a need to keep your information, we will delete or anonymise it. 

4. Sharing your personal information

If we engage a third party to process personal information on our behalf, we contractually require them handle your personal information appropriately and in accordance with relevant data protection laws.

We generally do not share personal information collected via the App with third parties. However, personal information may be shared with third parties where one of the following circumstances applies and where we are legally able to do so:

• you have explicitly consented to us doing so;
• we are under a legal or regulatory obligation to disclose your personal information, protect the rights, property, or safety of Atnahs, our customers or others;
• Atnahs’ assets are merged or acquired by a third party, in which case your personal information may form part of the transferred or merged assets;
• if we have contracted with third parties to supply products and services to you on our behalf. These may include payment processing, delivery of goods;
• to provide anonymous statistical information about users of the App and related usage information to reputable third parties; or
• we are using a third-party service provider to provide services that involve data processing (for example, hosting the App).

Where any of your information is required for such a purpose, we will take all reasonable steps to ensure that your information will be handled safely, securely, and in accordance with your rights, our obligations, and the obligations of the third party under the law.

Identity, Contact and Profile data which you submit in accessing the Application via the iTunes store or Google Play store, is held by Apple and Google under their privacy policies.

Wherever we transfer personal information outside of the UK or European Economic Area (EEA), we will take legally required steps to ensure that appropriate safeguards are in place to protect it.  You may contact us for an explanation of the basis on which we have transferred your personal information and, where relevant, to request a copy of the legal safeguards which we have put in place.

We may compile statistics about the use of our App including data on traffic, usage patterns, user numbers and other information. All such data will be anonymised and will not include any personally identifying data, or any anonymised data that can be combined with other data and used to identify you.

In certain circumstances, we may be legally required to share certain data held by us, which may include your personal information, for example, where we are involved in legal proceedings, where we are complying with legal requirements, a court order, or governmental authority.

5. Links to third party websites

The App may contain links to third party websites, that we do not control including options to share content you have read on third party websites, for example, we may share articles from various osteoporosis patient sites. If you follow a link to any third-party website, please be aware that these websites have their own privacy policies and that we do not accept any responsibility or liability for their handling of your personal information.

6. Your rights

You have certain rights in relation to your personal information, including:

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 products or services to you. We will advise you if this is the case at the time you withdraw your consent.

Any request to exercise one of these rights will be assessed by us on a case-by-case basis.  There may be circumstances in which we are not legally required to comply with your request because of relevant legal exemptions provided for in applicable data protection legislation. 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.

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.

You may also have the right to contact the relevant data protection authority (the Information Commission’s Office) if you think we have processed your personal information in a manner which is unlawful or breaches your rights. If you have such concerns, we request that you initially contact us at the email address below so that we can investigate, and hopefully resolve, your concerns.

7. Updates to this Privacy Notice

This Privacy Notice may be amended by us at any time. Please check this page periodically to inform yourself of any changes. It was last amended in February 2021.

8. How to contact us

If you have any questions, need further information about our privacy practices, or would like to let us know that your details require updating, please contact us at info@atnahs.com. Atnahs Pharma UK Limited, Sovereign House, Miles Gray Road, Basildon, Essex SS14 3FR.